FINTRAC MSB registration: when crypto activity becomes an MSB service
Status as of October 30, 2026. In Canada, dealing in virtual currency is a money services business (MSB) activity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, and an MSB must register with FINTRAC before it offers MSB services. This page explains how FINTRAC describes that activity, the exclusion that matters most to merchants, and where payment service providers fit. It is general information, not legal advice: for a determination about your business, ask FINTRAC directly or speak with a lawyer.
Key points
- FINTRAC says dealing in virtual currency includes both virtual currency exchange and virtual currency transfer services.
- A business that solely accepts payment for goods or services it supplied to its own customer is listed as an exclusion.
- If you also move, convert or collect crypto-assets for other people, the exclusion may not fit.
- FINTRAC treats payment service providers for invoices, goods and services as MSB activity (notice of July 21, 2022).
- An MSB must register with FINTRAC before it offers MSB services, not after.
What FINTRAC means by dealing in virtual currency
FINTRAC's MSB registration questions page (last modified August 22, 2024) says dealing in virtual currency covers two kinds of service: virtual currency exchange and virtual currency transfer. Both phrases are worth reading literally.
Notice that each one describes a service performed for someone else: converting a client's value, or moving it on to a beneficiary. Keep that thread in mind when you compare your own business model with the exclusions below.
- Virtual currency exchange: exchanging funds for virtual currency, virtual currency for funds, or one virtual currency for another.
- Virtual currency transfer: transferring virtual currency at a client's request, or receiving virtual currency to remit it to a beneficiary.
The merchant exclusion and why “solely” matters
FINTRAC also lists exclusions. The one merchants ask about most covers a person or entity that “solely accepts a payment for goods or services that they supplied to their own customer.” FINTRAC separately excludes a business that solely provides hardware, such as a payment terminal.
The word solely carries the weight. A shop that takes a crypto-asset from its own customer for its own product is the situation the wording describes. A business that also collects payments on behalf of other sellers, converts value for customers or forwards funds to third parties is doing more than accepting payment for its own supply, and may not fit the exclusion.
A useful way to frame it is to ask whose value is moving. If the only value is your own customer's payment to you, for goods or services you supplied, you are reading the exclusion. If value that belongs to someone else passes through your hands, you are reading the definitions, and the answer deserves a closer look.
Adding a feature such as paying out other vendors, offering customers conversion to Canadian dollars or holding balances for users can move a business outside the “solely” wording. Review your model again whenever you add a payment feature.
Common patterns and how they line up
This table is a reading aid, not a determination. The same label can describe very different arrangements, and FINTRAC looks at what a business actually does.
| Business pattern | How it relates to FINTRAC's descriptions | What to confirm |
|---|---|---|
| A retailer accepts a crypto-asset from its own customers for its own goods | Matches the wording of the “solely accepts a payment” exclusion, if that is all it does | That it offers no other payment services |
| A marketplace collects crypto-assets from buyers and pays out third-party sellers | Receiving value for remittance to someone else resembles virtual currency transfer | Ask FINTRAC for a determination before launch |
| A business offers customers conversion between a crypto-asset and Canadian dollars | Resembles virtual currency exchange | Registration status before offering the service |
| A company only sells or leases payment terminals | FINTRAC lists a hardware-only exclusion | That it does not handle the payments itself |
| A software provider receives crypto-assets for merchants' invoices and passes the value on | FINTRAC's July 21, 2022 notice treats such payment service providers as MSB activity | Its registration status, and whether other regimes apply |
Where payment service providers fit
On July 21, 2022, FINTRAC published a notice about crowdfunding platforms and certain payment service providers. It says payment service providers for invoices, goods and services are treated as remitting or transmitting funds or dealing in virtual currency. A business that sits between a payer and a merchant and handles the value is in MSB territory, even when the merchant itself is not.
For a merchant, this matters when you evaluate a provider. Ask whether it is registered with FINTRAC, how you can confirm that, and what it will need from you. The vendor evaluation checklist and questions to ask a payment provider cover these points. A provider may also have separate obligations under the Retail Payment Activities Act, which the Bank of Canada supervises.
Register before you offer MSB services
FINTRAC's rule is about timing as well as status: an MSB must register before it offers MSB services. Launching first and registering later is not the order the rules describe. The readiness quiz can help you list the questions to work through before any launch.
- Write down every way value moves through your business: who pays, who receives, who holds and who converts.
- Compare each flow with FINTRAC's descriptions of virtual currency exchange and transfer, and with the listed exclusions.
- Treat any flow that involves value belonging to someone other than you and your own customer as an open question.
- Read FINTRAC's MSB pages, including its registration page, to see what registration involves.
- If you are unsure, contact FINTRAC through its MSB pages and describe the specific model before you launch it.
- Keep a dated note of what you asked, what you were told and by whom.
What registration brings with it
Registration is not the end of the work. FINTRAC-regulated businesses take on ongoing obligations, including these:
- Records must generally be kept for at least five years.
- MSB virtual currency transfers of $1,000 or more carry specific record-keeping and identity verification requirements.
- The travel rule, in effect since June 1, 2021, requires originator and beneficiary information to travel with virtual currency transfers.
- Reporting entities file large virtual currency transaction reports for receipts equivalent to $10,000 or more.
FINTRAC invites specific questions about MSB status through the contact options on its MSB pages. Describe your flows concretely, including who sends, who receives and who holds the private keys, rather than asking in general terms. FINTRAC's guidance sets out the full list of obligations; check current guidance rather than relying on a summary.
Questions people ask
Does accepting crypto at my shop make me an MSB?
FINTRAC lists an exclusion for a person or entity that solely accepts a payment for goods or services it supplied to its own customer. If that is all you do, the wording describes your situation; if you do more, ask FINTRAC for a determination.
Is a crypto payment processor an MSB?
FINTRAC's July 21, 2022 notice treats payment service providers for invoices, goods and services as remitting or transmitting funds or dealing in virtual currency. Ask any provider to confirm its own registration status.
Can I register after I launch?
FINTRAC says an MSB must register before it offers MSB services.
Does BlockchainPayments.ca register businesses with FINTRAC?
No. This site is an independent educational resource. It is not registered with any regulator and does not process payments; registration questions go to FINTRAC.
Sources
- FINTRAC — MSB registration questions
- FINTRAC — Money services businesses
- FINTRAC — Register a money services business
- FINTRAC — Notice on crowdfunding platforms and certain payment service providers (July 21, 2022)
Reviewed October 30, 2026. Educational information only; not financial, legal, tax or investment advice. This site does not process payments or hold funds.