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Two deadlines every two years
Every money services business registered with FINTRAC has two separate two-year cycles, and owners often mix them up:
- The registration renewal keeps the business on the register. Miss it and the status turns to Expired.
- The effectiveness review shows that the compliance programme actually works. Miss it and the gap shows up in the next FINTRAC examination.
They rarely fall on the same date, because one follows the registration and the other follows the last review. Put both in the compliance calendar on day one, especially after buying a company.
Renewing the FINTRAC MSB registration
The Act requires a registration to be renewed every two years, and FINTRAC is clear that it is the business’s responsibility: there is no official reminder to rely on. The expiry date is shown in the public MSB registry.
- What you file: a renewal contains the same full information as a new application: owners, directors, CEO, compliance officer, address, services, bank accounts and agents.
- When: before the expiry date. The law sets no fixed lead time, but FINTRAC says most complete applications take up to three months to process, so file well ahead, ideally about three months before expiry.
- While it is processed: a renewal filed before expiry keeps the status Registered until FINTRAC decides.
- If you are late: the registration is deemed expired, and FINTRAC may treat the business as unregistered. Operating an MSB without a valid registration is a serious violation and can be an offence.
Virtual currency dealers and foreign MSBs have a special date for their first renewal, tied to the anniversary of incorporation, so check the registry date rather than counting two years yourself.
The effectiveness review: what the law requires
The effectiveness review is one of the five parts of every compliance programme, next to the compliance officer, written policies approved by a senior officer, a documented risk assessment and a training programme. Since 2026 the Act also says the programme must be "reasonably designed, risk‑based and effective".
- What it covers: the policies and procedures, the risk assessment and the training programme.
- How often: every two years. FINTRAC’s guidance expects the next review to start no later than 24 months after the previous one started.
- Who does it: an internal or external auditor if the business has one, otherwise the business itself. FINTRAC’s best practice is a reviewer who does not run the programme.
- Reporting: within 30 days, a written report to a senior officer with the findings, the policy updates made during the period and how far they have been implemented.
What a good effectiveness review actually tests
FINTRAC wants evidence that the programme works in practice, not a description of it. A review that holds up in an examination has a written plan (scope, period, methods and sample sizes) and tests things like these:
- Samples of client files: identification, beneficial ownership and high‑risk clients
- Transaction reports: suspicious transactions, large cash and virtual currency transactions and international transfers of CAD 10,000 or more, filed correctly and on time
- Record keeping: complete records, kept for five years and retrievable
- Training: who was trained, on what and when
- Interviews with staff and, where relevant, agents
The report records the review date, the period covered, who did it, the results of each test and the conclusions with an action plan. In published penalty notices, FINTRAC fined MSBs whose reviews only summarised the programme, had no scope, period or testing, or copied the previous review almost word for word.
What happens if the review is missing or weak
FINTRAC examiners ask for the last review, check that it was on time and adequate, read the report to the senior officer, and check that the findings were acted on. They may also interview the person who did the review.
Every compliance programme failure, including a missing or inadequate review, is classed as a very serious violation, with penalties of up to CAD 20 million per violation for a business. FINTRAC publishes the penalty and the company’s name.
A simple two-year calendar for MSB owners
- Day one (or the day you buy the company): note the registration expiry date and the date the last effectiveness review started.
- Ongoing: report any change in registration information to FINTRAC within 30 days; keep training records and the risk assessment current.
- About three months before expiry: prepare and file the renewal with up-to-date owners, directors, services and bank accounts.
- Before 24 months from the last review’s start: start the next effectiveness review with a written plan and sample testing.
- Within 30 days of the review: report to a senior officer and start the action plan.
How MAXCORP keeps both deadlines on track
MAXCORP runs the renewal and the effectiveness review for Canadian MSBs as part of an ongoing compliance service. As your Compliance Officer in Canada, we keep the calendar, prepare and file the renewal and keep the programme ready for its review.
Because FINTRAC prefers a reviewer who does not run the programme, our independent AML audit can carry out the effectiveness review as an external reviewer, with a written plan, sample testing and a report for your senior officer. New to Canada? See how a ready-made MSB gets you started in about 2 weeks.
Official sources (8)
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act
- PCMLTF Regulations (SOR/2002-184), s. 156: compliance program
- PCMLTF Registration Regulations (SOR/2007-121)
- Administrative Monetary Penalties Regulations (SOR/2007‑292)
- FINTRAC: MSB registration and renewal
- FINTRAC: compliance program requirements
- FINTRAC: compliance assessment manual
- FINTRAC: penalty notice, MSB effectiveness review findings (2026)
General information only, not legal or tax advice. Rules change; ask us about your case.