Substance Law provides comprehensive MSB (Money Services Business) and FMSB (Foreign Money Services Business) registration and compliance services for businesses operating in or into Canada. We assist clients with registration, audits, examinations, compliance program design, operational readiness, and ongoing regulatory support.
We regularly advise businesses dealing with Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and help fintech companies manage regulatory risk while building scalable operations.
MSB & FMSB Registration Services
We assist Canadian and foreign businesses with:
- MSB registration with FINTRAC
- Foreign MSB (FMSB) registration for non-Canadian entities
- Scope assessments and regulatory classification
- Registration updates, renewals, and changes
- Ongoing registration maintenance
Proper registration is a foundational requirement for operating legally and maintaining banking relationships in Canada.
MSB Regulatory Compliance & Advisory Services
FINTRAC Compliance Programs
We design and implement risk-based compliance programs tailored to your business model, including:
- Compliance policies and procedures
- Appointment of a compliance officer
- Risk assessment (RBA) development
- Training programs
- Ongoing monitoring and reporting frameworks
Our compliance programs are designed to meet FINTRAC expectations while remaining practical for day-to-day operations.
Audits, Examinations & Regulatory Reviews
We assist MSBs and FMSBs with:
- Preparing for FINTRAC examinations and audits
- Responding to audit findings and deficiency reports
- Remediation planning and corrective actions
- Managing regulator communications
Early legal involvement can significantly reduce enforcement and penalty risk.
Risk Assessments
We provide:
- Enterprise-wide AML/ATF risk assessments
- Product, service, customer, geographic, and delivery channel risk analysis
- Documentation aligned with regulatory expectations
- Periodic updates and reviews
Risk assessments are a core FINTRAC requirement and are frequently scrutinized during examinations.
Compliance Operations Manuals & Documentation
We prepare and update:
- AML/ATF compliance manuals
- Operational procedures and workflows
- Record-keeping and reporting guides
- Training materials and internal controls
Clear documentation is critical for both regulatory compliance and operational consistency.
Banking & Operational Readiness
Bank Account Opening Support
We assist clients with:
- Preparing compliance documentation for banks
- Addressing AML and risk-related onboarding questions
- Structuring operations to meet financial institution expectations
- Responding to bank due diligence requests
Strong compliance frameworks materially improve bankability.
Compliance Software Selection
We advise on:
- AML and transaction monitoring software selection
- KYC and identity verification tools
- Sanctions and screening solutions
- Integration considerations for fintech platforms
We help clients choose solutions that align with regulatory requirements and business scale.
RPAA & Fintech Regulatory Services
In addition to MSB compliance, we advise fintech companies on:
- RPAA (Retail Payment Activities Act) scope assessments and compliance
- Safeguarding of funds frameworks
- Incident response and operational risk management programs
- Regulatory strategy for payment service providers (PSPs)
- Ongoing advisory support for evolving fintech regulation
Our approach integrates MSB, RPAA, and broader fintech regulatory obligations into a coherent compliance strategy.
MSB Contracts & Commercial Legal Services
We provide legal support beyond compliance, including:
- Drafting, reviewing, and negotiating commercial contracts
- Payment processing and platform agreements
- Technology and SaaS agreements
- Vendor, partner, and customer contracts
- Regulatory risk allocation in commercial arrangements
Well-drafted contracts are essential to managing regulatory and operational risk in fintech businesses.
Why Choose Substance Law for MSB Legal Services?
- Experience with MSB and FMSB registration and compliance
- Practical understanding of FINTRAC audits and examinations
- Integrated AML, RPAA, and fintech regulatory expertise
- Business-focused legal advice
- Toronto-based firm serving clients across Canada and internationally
Work With an MSB & Fintech Lawyer in Canada
Whether you are launching a new MSB, registering as an FMSB, preparing for a FINTRAC audit, or scaling a fintech platform, Substance Law provides experienced legal and regulatory support tailored to your business.
Contact us today to speak with an MSB & Fintech Lawyer.
Frequently Asked Questions: MSB / FMSB Registration & Compliance (FINTRAC)
What is an MSB in Canada?
An MSB (Money Services Business) is a business that offers certain money services in Canada, such as money transfers, foreign exchange, or dealing in virtual currency. MSBs are generally required to register with FINTRAC and maintain an AML/ATF compliance program.
What is an FMSB (Foreign MSB)?
An FMSB is a non-Canadian business that directs money services at persons or entities in Canada. Foreign MSBs may be required to register with FINTRAC and meet Canadian compliance obligations, depending on their activities.
Do I need to register with FINTRAC?
If your business activities fall within MSB/FMSB scope, registration is generally required. Determining whether you are in scope can be fact-specific and may require a legal assessment of your products, services, and transaction flows.
What does an MSB compliance program include?
A FINTRAC compliance program typically includes a compliance officer, written policies and procedures, a documented risk assessment, training, and effectiveness reviews (audits), along with operational controls for record-keeping and reporting.
Can you help with FINTRAC audits or examinations?
Yes. We help businesses prepare for FINTRAC examinations, respond to information requests, address findings, and implement remediation plans to reduce enforcement and penalty risk.
Do you create MSB risk assessments and AML policies?
Yes. We develop risk assessments, AML/ATF policies, procedures, and operations manuals tailored to your business model and aligned with FINTRAC expectations.
Can you help select AML compliance software?
Yes. We advise on compliance tooling such as KYC/ID verification, sanctions screening, transaction monitoring, and case management solutions, including how to align software capabilities with your regulatory requirements.
Can you help with bank account opening for MSBs/fintechs?
Yes. We help clients prepare compliance documentation for banks, respond to due diligence questions, and present operational readiness to improve bankability.
Do you also advise on RPAA compliance and fintech regulation?
Yes. We advise payment and fintech businesses on RPAA scope and compliance, safeguarding of funds frameworks, incident response, operational risk programs, and broader fintech regulatory strategy.
Do you provide fintech contract drafting and negotiation services?
Yes. We draft, review, and negotiate fintech and commercial contracts, including platform, vendor, customer, and payment-processing agreements, with a focus on clear risk allocation and operational practicality.
