Company Registration in Canada (British Columbia) and Obtaining a Money Services Business Licence. Service offer

The activities of MSBs are regulated by Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Under this Act, companies engaging in one or more of the following activities are required to obtain an MSB licence:

• Foreign exchange dealing (conducting transactions where one currency is exchanged for another); however, purchases made with foreign currency are not exchange transactions;
• Remitting or transmitting funds (transferring funds from one party to another using an electronic funds transfer network or any other method such as Hawala, Hundi, Fei ch'ien, and Chitti).

‘Remitting or transmitting funds’ also includes the activities of payment agents. Even if a company itself does not execute a cross-border payment but accepts funds from a client and makes a payment to a third party as instructed by the client, this transaction falls under the definition of ‘remitting or transmitting funds’.

• Issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments; this activity does not include cashing cheques issued to a specific person;
• Dealing in virtual currency (virtual currency exchange and/or virtual currency transfer);

Virtual currency exchange services include exchanging:

1. fiat funds for virtual currency;
2. virtual currency for fiat funds;
3. virtual currency for another virtual currency.

Virtual currency transfer services include:

1. transferring virtual currency at the request of a client;
2. receiving a transfer of virtual currency for remittance to a beneficiary.

‘Dealing in virtual currency’ also includes the activities of payment agents that use virtual currency in their operations. Even if a company itself does not execute a cross-border payment but receives funds from a client and makes a payment to a third party as instructed by the client, this transaction falls under the definition of ‘dealing in virtual currency’.

• Crowdfunding platform services (providing a crowdfunding platform for use by other parties to raise fiat funds or virtual currency);
• Armoured cars (transporting currency, money orders, traveller’s cheques, and other similar negotiable instruments);
• Cheque cashers (providing cheque cashing services);
• Acquirer services in relation to private automated banking machines;
• Other prescribed activities, i.e., it is an open-ended list.

If a company provides one or more of the above services, the requirement to obtain a licence depends on where its ‘place of business’ is: a licence is mandatory if a company has a place of business in Canada. This is true if any of the following conditions are met:

• The company is incorporated in Canada;
• The company has a physical office in Canada; or
• The company has employees, agents, or branches in Canada.

If a company has a place of business outside Canada, it is necessary to determine whether the company meets the criteria for an FMSB (Foreign Money Services Business) licence.

The minimum number of directors is 1 A director must be an individual; there are no residency requirements.

A Compliance Officer is a company employee responsible for overseeing and monitoring the company’s AML/CTF* compliance. There are no residency requirements. The CO must be appointed before submitting an application to the regulator – Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

*Anti-Money Laundering /
Counter-Terrorism Financing.

The minimum number of shareholders and beneficial owners of a company is 1.

A shareholder can be either an individual or a legal entity; there are no residency requirements. A company’s beneficial owner is always an individual who ultimately controls the company.

All directors, the Compliance Officer, senior officers, shareholders, and beneficial owners of the company must be fit and proper to hold their positions. This means, in particular, that these persons:

• must not have criminal record and/or be disqualified from engaging in financial activities;
• must not be subject to bankruptcy proceedings or be undischarged bankrupts;
• if the shareholder is a legal entity, that entity must not be subject to bankruptcy, dissolution, or winding up proceedings.

The assessment of whether the company officers are fit and proper is not something only the Regulator must do (upon licence application or renewal, or during spot inspections), the company must also monitor this on an ongoing basis.

A company is required to maintain an office in Canada from which it directly conducts its operations within the country. The company’s address is publicly available and will be listed on the Regulator’s website. The company must keep all its records (primarily accounting records) at this office address and be able to make them available for inspection at any time. Furthermore, all official notifications from Canadian authorities will be sent to this address. The Regulator does not accept companies that have a virtual office only.

There is no minimum share capital requirement.

1. Incorporate a company in the province of British Columbia. Find an office and appoint a Compliance Officer to the company;

2. Submit a pre-registration application for MSB to the Regulator and the Bank of Canada, and pay application fees. The application must be accompanied by, among other things, the following documents:

• Business plan,
• Compliance manual and AML/CTF risk management policy,
• Description of the payment infrastructure required for MSB operations;

3. Submit an application for an MSB licence to the Regulator.

The review of the application by the Regulator and the Bank of Canada takes approximately 15 weeks. In total, if all necessary steps are completed promptly, the entire process of obtaining an MSB licence in Canada takes approximately 4 to 12 months (depending on how many queries the Regulator raises during the application process).

The licence is valid for 2 years. Before it expires, it must be renewed if the company still wishes to provide services as MSB. The renewal procedure is largely similar to the initial application.

The company is also required to submit an Annual Return as part of the standard annual renewal process.

Payment for MSB licence application services is made in two stages:

Stage I – services of:

• company incorporation and first-year administration;
• finding office premises for an MSB;
• appointing local Canadian staff as director and Compliance Officer; OR
• appointing your foreign staff as director and Compliance Officer.

Payment must be made before we proceed with incorporation of the company.

Stage II – services of:

• drafting a compliance manual, an AML/CFT risk management policy, and other policies required by the company based on the specific MSB activities it intends to conduct;
• preparing and submitting a pre-registration application for MSB to the Regulator and the Bank of Canada;
• preparing and submitting an application for an MSB licence to the Regulator;
• supporting the MSB licence application process and liaising with the Regulator regarding the licence application.

Payment must be made before we proceed to draft the policies and submit the application.

*The fees are valid as of October 2026.