What you actually buy with a ready-made MSB
A ready-made MSB is an existing Canadian company that is already registered with FINTRAC as a money services business. Buying it saves the months of preparing and waiting for a new registration. You take over the company’s shares, and the registration stays with the company. There is no separate "transfer" of the registration, because FINTRAC registers the business, not the owner, and it does not issue licences.
The other side of that is simple: everything the company did before you bought it stays with it. Its reports, its record keeping and any breach FINTRAC has not found yet. FINTRAC can start penalty proceedings up to two years after it learns of a violation, so a problem from before the sale can turn into a penalty after it. That is why the checks below matter more than the price.
A new, unused MSB or one with a trading history?
Ready-made MSBs come in two kinds. Some have traded for years, with clients, transactions and a reporting record. Others are newly registered companies that have never done business. For most buyers, the second kind is the safer quick start: there are no past transactions, reports or FINTRAC findings to inherit, so most of the history checks below have nothing to find.
That is why MAXCORP offers only new ready-made MSBs, with no activity, as its main route into Canada. The company is registered with FINTRAC, incorporated in British Columbia or Ontario and transferred to you in about 2 weeks. You start with a clean file and build the compliance record yourself from day one.
The checklist: what to verify before you sign
Registration
- Status in the public MSB registry: it must show Registered, not Expired, Ceased or Revoked.
- Expiry date: a registration must be renewed every two years. A company close to its expiry date means a renewal filing straight after closing.
- Registered services: foreign exchange, money transfers, virtual currency dealing and the other services must match your business. Adding a service is a change you report to FINTRAC.
People and ownership
- Who will be listed: the registration names the CEO, the president, every director and anyone owning or controlling 20% or more. Each of them files a criminal record check, and a person under sanctions or with certain convictions makes the company ineligible.
- Directors and compliance officer: a federal (CBCA) corporation needs at least 25% resident Canadian directors, and at least one. British Columbia and Ontario companies have no such rule, and FINTRAC sets no residency requirement for the compliance officer. Know which kind of company you are buying.
Compliance and history
- The compliance programme: a named compliance officer, written policies approved by a senior officer, a documented risk assessment and a training programme.
- The last effectiveness review: required every two years and reported to a senior officer within 30 days. A missing review is a gap you inherit.
- Reporting history: suspicious transaction reports, large cash and large virtual currency transaction reports, and international transfers of CAD 10,000 or more. Records must be kept for five years, so they should exist.
- FINTRAC correspondence: examination letters, findings and penalty notices. FINTRAC publishes penalties with the company’s name, and the notices stay online for five years.
Company and banking
- Corporate records and taxes: annual returns with the corporate registry, the register of individuals with significant control, and tax filings with the Canada Revenue Agency.
- Bank accounts: the accounts the MSB uses are part of its FINTRAC registration. Banks treat MSBs as high risk and usually re-run their checks after a change of owner, so confirm before signing whether the accounts continue. One that closes has to be replaced and reported.
- Quebec: serving clients in Quebec needs a separate licence from Revenu Québec, renewed every year.
After closing: what you report to FINTRAC
Any change in the registration information must be reported to FINTRAC within 30 days of becoming aware of it. After a purchase that usually means new owners, directors and CEO, often a new compliance officer and address, and sometimes new services or bank accounts.
Take FINTRAC’s follow-up questions seriously: a request left unanswered within 30 days can lead to the registration being revoked. On our ready-made projects the share transfer itself takes about 2 weeks; the FINTRAC notices then follow within the 30‑day window.
Renewal every two years and the effectiveness review
Two deadlines run every two years and are easy to lose sight of after a purchase. The registration must be renewed before its expiry date; a renewal filed in time keeps the company Registered while FINTRAC processes it, but a late one leaves it Expired. Separately, the compliance programme needs an effectiveness review every two years by an internal or external auditor.
Put both dates in the closing checklist, so the first renewal and the first review under your ownership are planned from day one.
What a clean ready-made MSB looks like
- The registry shows Registered, with the services you need and time left before renewal
- A compliance programme in place, with a named compliance officer and written policies
- No open FINTRAC findings and no penalties
A new MSB with no activity meets all three by design. That matters, because a FINTRAC penalty can reach CAD 20 million per violation for a company, and FINTRAC publishes it.
If the company is also registered under the RPAA
Some ready-made MSBs are also registered with the Bank of Canada as payment service providers under the Retail Payment Activities Act. Here the rule is stricter than FINTRAC’s: anyone who acquires control of a registered provider needs a new application, registered before the change. That adds time to the purchase, so plan it in from the start. See our guide to RPAA registration.
How MAXCORP helps you buy a ready-made MSB
MAXCORP offers new ready-made MSBs with no activity: FINTRAC-registered companies incorporated in British Columbia or Ontario, transferred in about 2 weeks, with no resident director and no compliance officer needed in Canada. We still go through this checklist with you before you sign: registration status, people, compliance programme, reporting and FINTRAC history. We then handle the share transfer, the FINTRAC change notices and, if needed, the RPAA application.
See our Canada MSB registration for the ready-made and new-application routes. After the purchase, our Compliance Officer in Canada can take over the compliance officer role, the reporting and the two‑year effectiveness review.
Official sources (9)
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act
- Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002‑184)
- PCMLTF Registration Regulations (SOR/2007-121)
- FINTRAC: MSB registration
- FINTRAC: reporting changes to your registration
- FINTRAC: public notices of administrative monetary penalties
- Retail Payment Activities Act, s. 24
- Canada Business Corporations Act, s. 105 (resident directors)
- Revenu Québec: money-services businesses
General information only, not legal or tax advice. Rules change; ask us about your case.

