A FINTRAC money services business (MSB) registration ends in one of two ways: it expires because it was not renewed within two years, or FINTRAC revokes it. Either way the business must stop offering MSB services in Canada until it is registered again. FINTRAC's published registry data, last updated 16 October 2026, shows 165 registrations revoked with a revocation date in 2026, the latest on 16 September 2026, against 23 in 2025. About 76% of those revoked in 2026 offered virtual currency services.
Since 26 March 2026, operating without registration is also more expensive. Failing to register is classed as a serious violation, with a maximum penalty of C$4 million per violation, and it can lead to criminal charges.
This guide explains why registrations are revoked or expire, what follows for the business and its bank, and how to re-register with a compliance programme that will hold up. For the full registration process, see our guide to Canada MSB registration with FINTRAC.
Revoked, expired, ceased: what each status means
FINTRAC's Money Services Business Registry shows a status for every business that has registered. Each status has a different cause and a different way back.
| Status | What it means | Typical cause | Route back |
|---|---|---|---|
| Registered | Registration is current | Not applicable | Renew before the expiry date |
| Expired | The two-year period ended without renewal | Renewal form not filed in time | New registration application |
| Revoked | FINTRAC cancelled the registration | Unanswered clarification request, ineligibility, stale information | Review within 30 days, or a new application once the cause is fixed |
| Ceased | The business told FINTRAC it stopped | MSB services ended | New application if services restart |
The registry data at 16 October 2026 listed 4,191 businesses as registered, 2,584 as expired, 1,629 as ceased and 407 as revoked.
Why FINTRAC revokes MSB registrations
FINTRAC's list of revoked registrations states that it can deny or revoke a registration where the business:
- is not eligible for registration
- does not answer a clarification request within 30 days
- does not respond in time to demands for information from FINTRAC
- does not notify FINTRAC of updates to its name or address
- fails to give FINTRAC assistance
A clarification request is a FINTRAC email asking the business to confirm or explain registration information. It goes to the contact person or representative for service on file. If that person has left, or the mailbox is not monitored, the 30 days can pass unnoticed.
Foreign MSBs carry an extra risk. A foreign MSB has no place of business in Canada but serves Canadian customers, and it must name a representative for service who lives in Canada. If the representative's name or address changes and FINTRAC is not told within 30 days, FINTRAC states that the registration will be revoked.
Ineligibility is the other main ground. A business cannot register if it, its chief executive, president, any director or anyone owning or controlling 20% or more has certain convictions, including money laundering, terrorist financing and some fraud and drug offences, or is a listed terrorist or a sanctioned person under specified Canadian laws. A change of director or owner can therefore make a registered business ineligible. See FINTRAC's list of who is not eligible to register.
Why MSB registrations expire
Registration lasts two years. FINTRAC states that it is the business's responsibility to renew before the expiry date and that the majority of complete applications are processed within three months. A renewal filed a few weeks before expiry may not be decided in time.
The registry recorded 262 registrations with an expiry date in 2026 that now show as expired. Common reasons are an expiry date not diarised after a change of compliance officer, a renewal form that was incomplete and closed, and a business that assumed renewal was automatic.
| Date | Action |
|---|---|
| Registration plus 20 months | Start the renewal pack and check every item of registered information |
| Registration plus 21 months | File the renewal form |
| Within 30 days of any request | Answer FINTRAC clarification requests |
| Before the expiry date | Confirm the renewal has been approved |
What revocation or expiry means for the business
Once registration ends, the business is unregistered. Offering MSB services in that state breaches section 11.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. For violations after 26 March 2026, the penalty ranges are:
| Classification | Maximum per violation after 26 March 2026 | Maximum before 26 March 2026 |
|---|---|---|
| Minor | C$40,000 | C$1,000 |
| Serious, including failing to register | C$4,000,000 | C$100,000 |
| Very serious | C$20,000,000 | C$500,000 |
These figures come from the amended administrative monetary penalties regulations. Bill C-12, the Strengthening Canada's Immigration System and Borders Act, also made compliance agreements mandatory where a penalty is imposed and gave FINTRAC a new power to issue compliance orders. Criminal charges remain possible, although FINTRAC cannot pursue both a penalty and a criminal charge for the same non-compliance.
The commercial effect is often faster than the legal one. Canadian financial entities must confirm that a foreign MSB is registered with FINTRAC before opening an account for it or providing correspondent banking. The registry is public, so banks, payment partners and enterprise customers can see a revoked or expired status at once. Accounts can be frozen or closed while the business is unregistered.
Can a revocation be challenged?
Yes, within limits. FINTRAC gives written reasons for a denial or revocation, and the business can ask for a review of its file within 30 days. A review is worth pursuing where FINTRAC's records are wrong, for example where a clarification answer was sent but not received. Where the underlying failure is real, the faster route is usually a clean new application.
During a review the business remains unregistered. It should stop offering MSB services in Canada until it is registered again.
How to re-register after revocation or expiry
Re-registration is a new application. FINTRAC accepts only complete applications and closes incomplete ones. The steps are:
- Fix the cause. Answer the outstanding information request, correct the registered details, or remove the person who made the business ineligible.
- Submit FINTRAC's pre-registration form. A FINTRAC officer then sends the registration form.
- Build a complete document pack: criminal record checks for the chief executive, president, directors and 20% owners, issued no more than six months before the application; certified English or French translations; incorporation and ownership documents; full details of locations, agents and bank accounts; and, for a foreign MSB, the representative for service.
- Upload everything through FINTRAC's secure link, which expires after 15 days.
- Answer any clarification request within 30 days.
Allow for FINTRAC's statement that most complete applications take up to three months. Plan banking conversations around that period rather than assuming a quick reinstatement.
Rebuilding the compliance programme
A revocation is a signal that the compliance programme did not work in practice. Since 26 March 2026 the Act requires the programme to be reasonably designed, risk-based and effective, so re-registering with the same documents is a risk at the first examination.
| Element | What to rebuild |
|---|---|
| Compliance officer | A named person with authority, time and a deputy who monitors FINTRAC correspondence |
| Policies and procedures | Updated for current services, approved by a senior officer |
| Risk assessment | Specific to the actual corridors, customers, products, channels and virtual currency activity |
| Training | Records for staff and agents, refreshed after the revocation |
| Two-year effectiveness review | An independent review of policies, risk assessment and training, with findings closed |
| Registration information control | A change log that triggers a FINTRAC update within 30 days |
| Agent checks | Eligibility and criminal record checks before engagement, repeated every two years; agents engaged before 1 October 2025 checked by 1 October 2027 |
Our compliance support work focuses on these controls, so that the new registration is defensible at examination.
Keeping a registration in good standing
Most revocation grounds are administrative, which means they can be prevented with simple controls. FINTRAC writes to the contact person or representative for service on file and expects a reply within 30 days. It expects changes to be reported within 30 days. It expects renewal before expiry. None of these requires a large team, but each needs an owner.
| Control | Owner | Frequency |
|---|---|---|
| Monitor the mailbox FINTRAC uses for the contact person, with a named deputy | Compliance officer | Daily |
| Log every FINTRAC request with its 30-day response date | Compliance officer | On receipt |
| Compare registered details (owners, directors, locations, agents, services, bank accounts) with the business as it operates | Compliance officer and company secretary | Quarterly |
| File a change form within 30 days of any change | Compliance officer | On change |
| Check that new directors and 20% owners are eligible before appointment | Board | On appointment |
| Diary the renewal at registration plus 20 months | Compliance officer | Every two years |
| Complete the two-year effectiveness review and close its findings | Independent reviewer and board | Every two years |
| For a foreign MSB, confirm the Canadian representative for service is current | Compliance officer | Quarterly |
Two further points are often missed. A business that stops offering MSB services must cancel its registration within 30 days, rather than letting it lapse. And copies of documents submitted with a registration application must be kept for at least five years.
Banks and payment partners usually ask for evidence of these controls during onboarding and periodic reviews. Keeping the log and the change history in one place makes those reviews shorter and shows the registration is being actively managed.
Related Canadian obligations
FINTRAC registration is one of several Canadian requirements. A business that holds customer funds or moves payments for end users may also need Bank of Canada RPAA registration, with its own annual report due by 31 March 2027; see our RPAA annual report 2027 guide. Quebec runs its own MSB licensing. Virtual currency businesses should also note that stablecoin issuers will register with FINTRAC under the Stablecoin Act. Our page on money services businesses in Canada brings these together.
Frequently asked questions
The business is no longer registered and must stop offering MSB services in Canada. The status shows as revoked on FINTRAC's public registry. Continuing to operate is a violation that, after 26 March 2026, carries a penalty of up to C$4 million and possible criminal charges.
You can request a review of your file within 30 days of the decision. FINTRAC gives written reasons. The business remains unregistered while the review is under way.
FINTRAC states that the majority of complete applications are processed within three months. Incomplete applications are closed, so the full document pack should be ready before the pre-registration form is submitted.
No. Expiry means the two-year registration was not renewed in time. Revocation means FINTRAC cancelled the registration, for example for an unanswered clarification request or ineligibility. Both leave the business unregistered.
FINTRAC's published registry data, updated 16 October 2026, shows 165 registrations with a 2026 revocation date, the latest on 16 September 2026. About 76% of them offered virtual currency services.
Often, yes. Canadian financial entities must confirm a foreign MSB is registered before opening an account or providing correspondent banking, and the registry is public. Banks and partners commonly review or close accounts when a registration is revoked or expires.
Yes. A foreign MSB must tell FINTRAC of any change to the name or address of its representative for service in Canada within 30 days. FINTRAC states that the registration will be revoked or denied if it is not told in time.
References
- FINTRAC: money services businesses with revoked registration
- FINTRAC: Money Services Business Registry
- FINTRAC: answer clarification requests, update, renew or cancel your registration
- FINTRAC: register your money services business
- FINTRAC: who is not eligible to register
- FINTRAC: administrative monetary penalties, changes following legislative amendments
- Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act
About Regulatory Counsel
Regulatory Counsel prepares FINTRAC MSB and foreign MSB registrations, renewals and re-registrations, and rebuilds compliance programmes after revocation. We work on the document pack, the programme and the banking conversation together. Every enquiry is answered the same business day with a written proposal: contact us.
This article is general information as at 20 October 2026 and is not legal advice.
Definitive guides on this topic
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