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FAQ

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What can a Canadian or Montana MSB offer?

Both Canadian and Montana MSBs can offer cryptocurrency exchange services, money transmission (payment services), foreign exchange dealing (forex) and more. 

How about Cryptocurrencies?

Certainly! MSBs can act as Crypto Exchange internationally and across Europe. In the US are generally regulated specifically as Money Service Businesses under the US Bank Secrecy Act (BSA) and FINCEN supervision and in Canada regulated under FINTAC. Please also see www.paywithcrypto.tech for our turnkey white-label Crypto Banking and Crypto Processing Platforms, no license required!

How about AML/CFT compliance?

The Canadian MSB are regulated by FINTRAC and Montana MSB is registered with FINCEN as Supervisory Authority for AML/CFT purposes. As a Regulated Provider, the MSB needs extensive AML/CFT compliance policies with regards to KYC, Suspicious Transaction Reporting, Risk Assessments etc. Our MSB Companies come complete with the required AML/CFT policies documentation.

Are there annual MSB renewal fees?

No. FINTRAC dont have any renewal fees for Canadian MSB. Montana MSB has only for Registered Agent and Registered Office address. FINCEN is not charging annual license or registration fees.

Are there Residency Requirements?

No, a Canadian and Montana MSB can be formed with owners of any nationality and resident anywhere in the world.

Are MSB services not limited to Canada only?

No, Canada puts no restrictions on where you can offer services nor are you required to offer any services in/within Canada. However, if you would target other specific jurisdictions, e.g. other US states, you would likely trigger state license requirements there. See our MSB Resources section for more information. 

How much time to launch a new MSB?

Processing time for the formation of a new Canadian MSB with the name of your choice is 1-2 weeks. We also have existing off-the-shelf entities for sale from time to time.  Deployment time for the PaywithCrypto White Label Banking Software is 1 week.

Can a Canadian MSB be verified online?

Yes, please visit our Resources section for links to the site where you can verify the FINTRAC and US FINCEN MSB registration status.

Registration and setup

How long does it take to get an MSB operating?
A ready-made Canadian MSB transfers in one to two weeks. A new registration takes one to two weeks to set up, with FINTRAC or FinCEN registration following. Montana is generally faster than Canada because there is no state MSB licence to obtain.
Do I need to live in Canada to own a Canadian MSB?
No. Canadian MSBs can be owned and directed from outside Canada. What matters is that the business has a real presence, a compliance officer who can carry out the role, and accurate registration details with FINTRAC.
What is the difference between an MSB and a foreign MSB?
An MSB is registered where it has a place of business in Canada. A foreign MSB directs services at Canadian customers from outside the country. Both register with FINTRAC and carry the same core obligations, but the registration category differs.
Can I buy an MSB that is already registered?
Yes, that is what our ready-made option is. You acquire the company with its registration in place. We handle the transfer of directorship and ownership, and update the registration so the details are accurate after the change.
Will you help me open a bank account?
We prepare the compliance documentation banks ask for and guide you through the application. No provider can guarantee an account, and any that promises one is not being straight with you.

Compliance obligations

What exactly does a compliance programme have to include?
Five things: a designated compliance officer, written policies and procedures, a documented risk assessment, an ongoing training programme, and an independent effectiveness review at least every two years. Our AML compliance programme service builds all five.
Can the compliance officer be outsourced?
Yes. FINTRAC permits an external compliance officer provided they genuinely have the authority, knowledge and time to run the programme. See our fractional MLRO service.
What has to be reported, and when?
Suspicious transactions must be reported as soon as practicable after suspicion is established. Large cash transactions and large virtual currency transactions are reported at the prescribed thresholds, as are qualifying electronic funds transfers. Terrorist property reports are filed immediately.
How often does the risk assessment need updating?
At minimum when the business changes materially, and in practice at least annually. An assessment that still describes a business model you have moved on from is one of the most common examination findings.
What happens during a FINTRAC examination?
You receive notice and an initial document request covering policies, the risk assessment, training records, reporting history and a sample of customer files. Examiners then interview staff and compare what they say to what the documents claim. Findings are issued with deadlines for remediation.

Crypto and payments

Can an MSB deal in virtual currency?
Yes. Virtual currency exchange and virtual currency transfer are both reportable MSB activities in Canada. They must be listed on the registration and covered explicitly in the risk assessment and procedures.
Do I need separate custody infrastructure?
If you hold client assets, yes. Segregation between client assets and your own treasury is expected, and the controls around it are examined. Our crypto custody solution is built for exactly this.
What is the RPAA and does it apply to me?
The Retail Payments Activities Act brings payment service providers under Bank of Canada oversight. If you perform retail payment activities, you may need to register there as well as with FINTRAC. The two regimes overlap but are not the same, and a single programme has to satisfy both.
Can I serve customers outside Canada?
Generally yes, subject to sanctions screening and to the rules of the countries you are serving. Canadian MSBs are widely used for cross-border activity, which is part of why the licence is in demand.

Working with us

Why do you publish your prices?
Because hiding them wastes everybody's time. If the number does not work for your business, you should learn that in thirty seconds rather than after two sales calls and an NDA. See our pricing page.
What support is there after setup?
Ongoing compliance support is available and priced separately, from a periodic programme review through to a fractional compliance officer running the programme month to month.
How do we start?
A free scoping call. We look at what you are trying to build, tell you honestly which route fits, and follow up with a written engagement letter covering scope, timeline and fee before anything begins.