For businesses considering registering a new MSB in Canada, the registration process itself has often been one of the biggest practical hurdles. Applications can involve multiple stages, supporting documents and follow-up communication with FINTRAC, with more complex applications sometimes taking longer to process.
Many existing MSBs that have undergone various changes have faced similar concerns.
There are now signs that this process is beginning to change.
FINTRAC is moving forward with a broader modernization of its systems, including the development of a new Reporting Entity Portal that will integrate MSB registration into a more centralized digital platform. According to FINTRAC, the new system is intended to streamline interactions with regulated businesses, provide more timely guidance and updates, improve data quality, and automate parts of the process.
A More Streamlined Registration Process?
For MSB applicants, this is a welcome development.
FINTRAC's current registration process begins with a pre-registration request, followed by direct communication with a FINTRAC compliance officer. Applicants must then provide detailed information about the business, its owners and management, locations, anticipated transaction volumes and other aspects of its operations, along with supporting documentation. This process could extend over several months, but direct communication with a FINTRAC officer also allowed applicants to request extensions when needed.
A Short Submission Window and No Extensions
Under its new approach, FINTRAC will notify applicants of a very short window (up to 15 days) during which they can submit their documents using FINTRAC's dedicated secure file exchange system. Only complete applications will be accepted and no extensions will be allowed, meaning missing information can result in an application being closed and needing to be resubmitted.
Under the new approach, coming well prepared, with all necessary information and documents ready in advance, is crucial.
Some documents, such as criminal record checks, can take longer to obtain, which could result in applications being dismissed. Your Canadian address should also meet FINTRAC's current physical location requirements. This is why proper guidance and step-by-step instructions on when to obtain which documents will make the difference between a successful and a failed application.
Important FINTRAC Reminder: Keep Your Contact Information Up to Date
FINTRAC typically communicates registration clarification requests by email, so it is important to make sure the contact information associated with your MSB registration is current and actively monitored.
If FINTRAC sends a clarification request, you will generally have 30 days to respond. Failure to respond within the required timeframe can result in serious consequences, including the revocation of your MSB registration.
Take a moment to confirm that FINTRAC has your current contact information, and make sure the email account associated with your registration is checked regularly.
How Approved MSB Services Can Help
The Approved MSB Services team, a proud affiliate of CBES Group, can help you assess your proposed structure, prepare the required documentation, and manage the FINTRAC registration process from the initial application through to approval.
Our extensive experience with FINTRAC regulations and our daily involvement with its systems give us the knowledge to guide you through the process with a proactive approach. We provide the step-by-step instructions you need and make sure all of your documents and information are prepared before FINTRAC requests them.
Contact us to discuss your plans and whether now may be the right time to move forward.
This article is for informational purposes only and does not constitute legal advice. For specific guidance on your MSB registration, please consult a qualified professional or contact our team directly.
FAQ
What is FINTRAC's new Reporting Entity Portal?
It is part of FINTRAC's broader modernization of its systems and will integrate MSB registration into a more centralized digital platform. FINTRAC says it is intended to streamline interactions with regulated businesses, provide more timely guidance and updates, improve data quality and automate parts of the process.
How will the new MSB registration process work?
FINTRAC will notify applicants of a very short window, up to 15 days, during which they can submit their documents through FINTRAC's dedicated secure file exchange system. Only complete applications will be accepted and no extensions will be allowed.
What happens if an MSB application is incomplete?
Missing information can result in the application being closed and needing to be resubmitted, which is why having all documents and information ready in advance is crucial.
Which documents should applicants prepare early?
Some documents, such as criminal record checks, can take longer to obtain. Knowing which documents to obtain and when can make the difference between a successful and a failed application.
How long do I have to respond to a FINTRAC clarification request?
You will generally have 30 days to respond. Failing to respond within the required timeframe can have serious consequences, including the revocation of your MSB registration.
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