82 Revocations: How MSBs Are Losing Their FINTRAC Registration

FINTRAC's 2025–26 annual report, published on 26 October 2026, shows that it revoked 82 money services business (MSB) registrations during the fiscal year, up from 12 the year before. The report connects the increase to businesses that did not respond to FINTRAC's clarification requests or demands for information.

A revocation is FINTRAC withdrawing an existing registration. It is not the same as a registration expiring, and it is not a fine. Once a registration is revoked, the business is no longer registered to provide money services in Canada.

For MSB owners, compliance officers and buyers of registered companies, the lesson goes beyond money laundering findings. A registration can be put at risk because a business cannot be reached, does not answer, or has let its registration information go out of date. This article looks at what the 2025–26 figures show, the legal grounds behind revocation, and the controls that protect a registration.

What FINTRAC's 82 revocations actually show

Several points matter when reading these figures:

• Fiscal year, not calendar year. The figures cover FINTRAC's fiscal year, April 2025 to March 2026, not calendar 2026.
• More enforcement action, not individual risk. The count shows that FINTRAC took far more revocation action. It does not tell any particular MSB how likely it is to be revoked.
• No breakdown published. FINTRAC does not break down the 82 by activity, province or foreign status, so none is given here.

The revocations happened against a background of heavy supervision of the sector. According to FINTRAC's results by the numbers, more than 55% of all its assessment activities were directed at MSBs. The annual report counts 625 targeted examinations and information demands, 433 of which involved MSBs. Not all of those were full-scope examinations.

Supervisory contact on that scale means more requests, and more deadlines that a business has to meet.

Why unanswered FINTRAC requests can put registration at risk

FINTRAC's revoked registrations page lists the situations in which it can deny or revoke a registration. Two of them are about not responding:

• not answering a clarification request within 30 days
• being slow to respond to FINTRAC's demands for information

Clarification requests. FINTRAC uses these to confirm or complete registration information: the business's activities, its owners, its locations, its agents. Under s. 11.17 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, a registered business must provide the clarification within 30 days after the request is made. If it does not, FINTRAC may revoke the registration. FINTRAC's update and renewal page states the same 30-day rule.

Demands for information. These are different. During a compliance examination, FINTRAC can serve a notice under s. 63.1 of the Act requiring documents or other information "in accordance with the time and manner stipulated in the notice". The Act does not fix one deadline for every notice. The deadline is the one written in the notice. The Act also requires businesses to give examiners reasonable assistance (s. 62(2)). Under s. 11.171, FINTRAC may revoke the registration of a business that fails to comply with either obligation.

Several practical points follow:

• The contact. Requests go to the contact person and contact details on file. If those are out of date, the request may never reach anyone who can act on it.
• Foreign MSBs. A foreign MSB also depends on its Canadian representative for service. The Act requires FINTRAC to deny or revoke the registration without delay if a change to the representative's name or address is not reported in time (s. 11.13).
• What counts as a response. It must be complete, accurate and sent through the channel FINTRAC specifies. A draft that was never submitted, a partial reply or an email to the wrong address does not meet the obligation.

Illustrative example (not a real case). A Canadian virtual currency MSB receives an email from FINTRAC asking it to confirm its current activities and ownership. The only employee who monitored the registered email address left the company two weeks earlier. Nobody else sees the email, no response is logged, and the 30-day period runs out. The registration is now exposed to revocation, even though the business may have been operating legitimately.

Four controls would have prevented this:

• a shared regulatory inbox with at least two monitors
• a register of every FINTRAC request with a named owner and deadline
• an escalation rule for requests not answered within a set internal period
• updating the registered contact details as soon as staff changed

Other legal grounds for FINTRAC registration revocation

Not every compliance deficiency leads to revocation. Missing reports or weak policies are usually dealt with through examination findings and, where FINTRAC decides, administrative monetary penalties or other measures. The grounds below are the specific statutory routes to denial or revocation.

Ineligibility is narrower than "any criminal record". It covers the listed offences under the Act and Regulations, including some offences under foreign law, plus listed persons and sanctioned persons. For the mechanics of reporting changes, see our guide to FINTRAC change of information.

Revoked, expired, denied or ceased: why the distinction matters

These are separate measures, and they should not be added together. FINTRAC's report notes that the expired total includes registrations that were later renewed. Cessation is its own category: the report gives no breakdown of why the 91 businesses ceased. Only revocation is a decision by FINTRAC to remove an existing registration.

What a Canadian MSB or FMSB should do before its registration is at risk

The 30-day deadlines and the obligations to report changes and assist examiners are legal requirements. How a business meets them is up to the business. The controls below are recommended practice, not legal requirements.

What international MSB founders and buyers should verify

International companies registering in Canada. Founders based in the UAE, India, Cyprus, Germany, Turkey, Ukraine and elsewhere first need the correct classification:

• Canadian MSB: the business has a place of business in Canada.
• Foreign MSB (FMSB): the business directs and provides services to clients in Canada without a place of business here.

Owners being outside Canada does not invalidate a registration. The eligibility of the business's leaders and 20% owners does matter. So does how reliably FINTRAC can reach the business, across time zones, through a Canadian representative for an FMSB and in English or French. Our MSB and FMSB registration service covers classification.

Buyers of FINTRAC-registered companies. A current registry entry is only a starting point. Buyers acquire the company that holds the registration; the registration cannot be transferred on its own. Due diligence should confirm:

• registration status and expiry date
• any open clarification requests or other FINTRAC correspondence
• ownership and control as recorded with FINTRAC
• the eligibility of current and incoming directors and owners
• whether the registered activities match what the company actually does
• the compliance records and any outstanding remediation
• the updates required after closing
• any banking or RPAA dependencies

A target with unanswered FINTRAC correspondence may be closer to revocation than its registry entry suggests. Buying a registered company does not avoid regulatory scrutiny or guarantee that the business can operate immediately. Our Canadian MSB acquisition page explains how acquisition reviews are scoped.

What happens if FINTRAC has already revoked your registration?

FINTRAC must give its decision and reasons in writing (Act s. 11.18). Under s. 11.3, a business may request a review within 30 days of receiving the decision. FINTRAC's reviews and appeals page explains how to apply. A further appeal to the Federal Court is possible within 30 days after the review decision is served.

FINTRAC's guidance does not say that a review request suspends the revocation. The business should therefore:

• keep all correspondence and records
• confirm its status on the registry
• assess immediately whether it can lawfully continue any regulated activity
• get legal advice where deadlines or proceedings are involved

Our revocation response guide covers the process in more detail.

The real compliance lesson from FINTRAC's 2025–26 results

The 82 revocations are a reminder that registration is not a one-time event. A business that registered successfully can still lose its registration if it cannot keep its information accurate, show that it remains eligible, or answer FINTRAC on time. In practice, that comes down to who reads FINTRAC's emails, who owns each deadline, and whether the registry still describes the business as it operates today.

If you want an independent check of your registration status, FINTRAC correspondence readiness or eligibility controls, or due diligence on a registered company you are considering buying, ComplyFactor's AML advisory services in Canada can assess the risks and help close the gaps. No review can guarantee that a registration will not be revoked, or that a revoked one will be reinstated.