GI-2024-27-reg3: Regulations Amending Certain Regulations Made Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Money Services Business Registration)

If you run a money services business in Canada — whether that's a foreign exchange shop, a money transfer service, a virtual currency dealer, or a crowdfunding platform — you now face the same criminal record check requirements that foreign MSBs have faced for years. Every two years at re-registration, you'll need to pay roughly $64 per check to obtain criminal record checks (issued within the last six months) for your CEO, president, directors, anyone owning 20% or more of the business, and all your agents — and if any agent is a corporation, its key officers need checks too. With an estimated 22,886 agent checks required per two-year cycle across the roughly 2,566 MSBs in Canada (98% of which are small businesses), the biggest cost is simply the check fees themselves, estimated at nearly $7 million in present value over 10 years. You'll also need to keep these records on file for five years and report the results to FINTRAC, with new administrative monetary penalties applying if you don't comply.