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Specialist Advisory

Canada FINTRAC & MSB Compliance

The only UAE-based advisory firm with dedicated Canada FINTRAC and Money Services Business compliance capability — built for Canadian MSBs, payment firms, and crypto businesses operating across the UAE-Canada corridor.

FINTRACMSBAML/CFTCanadaPCMLTFA
Overview

Canada's MSB Regime: Strict, Specific, and Frequently Penalised

Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) imposes specific AML/CFT obligations on Money Services Businesses (MSBs) — including currency exchange, money transfer, virtual currency dealing, and payment services. All MSBs must register with FINTRAC and maintain a fully documented compliance programme.

FINTRAC is one of the most active AML supervisors globally — conducting examinations, issuing administrative monetary penalties (AMPs), and publishing named enforcement decisions. In 2024-2025, over 52% of examined MSBs received findings of non-compliance. The penalties are significant and the reputational damage of a published enforcement decision is lasting.

Marensa Advisory brings UAE-based cross-border expertise to Canadian MSBs operating internationally — helping you maintain a FINTRAC-ready compliance programme that works whether you are based in Toronto, Dubai, or both.

Discuss Your Canada MSB Compliance
Our Canada MSB Services
  • FINTRAC registration and renewal support
  • AML/CFT compliance programme design (PCMLTFA-aligned)
  • Policies, procedures, and controls documentation
  • Compliance officer designation and training
  • Business-wide risk assessment (BWRA)
  • Transaction monitoring setup and guidance
  • Ongoing compliance management retainer
  • FINTRAC examination preparation and support
  • Suspicious Transaction Report (STR) guidance
  • Virtual currency / crypto MSB compliance
Compliance Requirements

What FINTRAC Requires from MSBs

FINTRAC Registration
All MSBs must register with FINTRAC before commencing MSB activities. Registration must be renewed every two years. Foreign MSBs with Canadian clients must also register as FMSBs. Registration failure is itself an offence under the PCMLTFA.
Compliance Programme
A documented five-pillar compliance programme is mandatory: (1) appointed compliance officer, (2) written policies and procedures, (3) risk assessment, (4) ongoing compliance training, and (5) effectiveness review (two-year cycle). All five pillars must be evidenced — FINTRAC examiners review documentation in detail.
Know Your Client (KYC)
MSBs must verify the identity of clients for transactions at or above $1,000 CAD (single or aggregated). Virtual currency MSBs must verify identity for transactions at or above $10,000 equivalent. Enhanced due diligence applies to politically exposed persons, high-risk countries, and business relationships.
Transaction Reporting
MSBs must report to FINTRAC: Large Cash Transactions (LCTRs) over $10,000 CAD, Suspicious Transactions (STRs) when there are reasonable grounds, Electronic Funds Transfers (EFTs) over $10,000 CAD, and Virtual Currency Transactions (LVCTRs) over $10,000 equivalent.
Record-Keeping
MSBs must maintain detailed records of all transactions, client identification, and compliance activities for a minimum of five years. Electronic records must be in a readable, accessible format. FINTRAC examiners routinely request records during examinations — gaps are penalised.
Virtual Currency MSBs
Since June 2020, businesses dealing in virtual currencies (including crypto exchanges, ATM operators, and payment processors) are classified as MSBs and must comply with all PCMLTFA requirements. This is an area of significant FINTRAC enforcement activity — and where most non-compliance findings arise.
The UAE Connection

Why This Matters for UAE-Canada Businesses

A growing number of Canadian businesses — particularly in payments, fintech, and crypto — have established UAE presences to access the Gulf and African markets. This creates dual regulatory obligations: FINTRAC compliance in Canada and CBUAE/VARA compliance in the UAE.

Marensa Advisory is uniquely positioned to advise on both sides of this equation — managing your FINTRAC programme alongside your UAE regulatory compliance, eliminating the need for two separate advisory firms with limited cross-border awareness.

We also advise UAE-headquartered businesses considering Canadian expansion on FINTRAC registration, programme design, and the practical steps needed before commencing MSB activities in Canada.

52%
MSBs with non-compliance findings
5
Mandatory compliance programme pillars
2yr
Registration and effectiveness review cycle
AMP
Administrative monetary penalties — publicly named
Our Process

How We Build Your FINTRAC Programme

01
MSB Activity Assessment
We identify which MSB categories apply to your business (currency exchange, money transfer, virtual currency, payment services) and confirm your FINTRAC registration status and renewal timeline.
02
Business-Wide Risk Assessment
We conduct a documented BWRA covering your products, services, customer types, channels, and geographies — identifying inherent risks, controls, and residual risk. This is the foundation of your entire compliance programme.
03
Programme Design & Documentation
We draft all five pillars: compliance officer mandate, policies and procedures manual (covering KYC, EDD, transaction monitoring, reporting), training programme, and two-year effectiveness review schedule.
04
Implementation Support
We support implementation — reviewing KYC processes, transaction monitoring thresholds, and reporting workflows. We also train your compliance team and designated compliance officer on PCMLTFA obligations.
05
Ongoing Compliance & Exam Prep
We provide ongoing compliance management and FINTRAC examination preparation — ensuring your records, policies, and training are current before an examiner arrives. Proactive compliance is always cheaper than remediation.
Get Started

Is Your MSB FINTRAC-Ready?

Whether you are registering for the first time or preparing for an examination, we can help. Tell us about your MSB activities and we will advise on next steps.

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