Remittance and Money Transfer Businesses
Six obligations that run every day after registration, which leg of a transfer reports, and five recent penalties.
Download the Guide
Fill in your details to unlock the PDF of Remittance and Money Transfer Businesses.
If you send money for clients, you are a money services business
In five penalties FINTRAC published on money transfer and currency exchange businesses between May 2025 and February 2026, the same finding recurs: written compliance policies that were missing, out of date or not applied. All five were set under the old penalty scale, which rose up to 40 times on 26 March 2026.
What you owe
Registration lets you open. Six obligations run every day after that.
Register before the first transfer, and keep it current
Registration with FINTRAC lasts two years and is renewed before it expires. Any change to what you told FINTRAC, such as a new branch or agent, is reported within 30 days.
Check every agent before they act for you
Confirm the agent is eligible and review their criminal record check before engaging them, then again within 30 days of every second anniversary.
Know who sends and who receives
Verify identity when a client sends $1,000 or more, when you pay out $1,000 or more, and on a currency exchange of $3,000 or more. Sender and recipient details go with every transfer you send, and records are kept five years.
Three reports, three clocks
A suspicious transaction report (STR) as soon as practicable, at any amount. An electronic funds transfer report (EFTR) within five business days for an international transfer of $10,000 or more. A large cash transaction report (LCTR) within 15 calendar days for $10,000 or more in cash.
Russia, Iran and North Korea: every transaction, any amount
Ministerial directives make every transaction from or to these countries high risk: verify identity, source of funds and purpose, and keep the record.
Since 26 March 2026, the program has to work
Compliance officer, approved policies, documented risk assessment, training and a two-year review, now reasonably designed, risk-based and effective. Some failures are now very serious violations.
A transfer you start is yours to report, even when your bank sends it
The transfer report attaches to where an international transfer begins and where it is paid out, not to whoever carries it in between. A transfer inside Canada never needs one.
Sending abroad: your client in Canada sends money overseas
Leg 1, money in: an LCTR if it is cash of $10,000 or more, and verify the sender from $1,000. Leg 2, money out: an EFTR at $10,000 or more, within five business days. You started it, so it is yours, even if a bank or partner sends it on.
Paying out from abroad: money sent from overseas reaches a person here
Leg 1, money in: an EFTR at $10,000 or more, when you are the one paying the beneficiary. Leg 2, money out: no new report. Cash paid out is not an LCTR. Verify the beneficiary from $1,000.
Inside Canada: both ends of the transfer are in Canada
No EFTR in either direction. Cash of $10,000 or more coming in is still an LCTR, and the sender is still verified from $1,000.
A suspicious transaction report has no threshold and no direction: any leg, any amount, completed or only attempted. Money to or from Russia, Iran or North Korea is high risk on every leg, at any amount.
What it costs
One finding in five recent penalties Each was cited for compliance policies that were missing, out of date or not applied.
Maximum per violation, as set in the Administrative Monetary Penalties Regulations from 26 March 2026. The figures beneath are the previous maximums for a business, from FINTRAC's penalty policy.
Transfer and exchange penalties, set under the old scale
How ComplyFactor helps
This is the work we do every week Money services businesses, payment service providers and fintechs are ComplyFactor's core practice. We file the reports, run the reviews and sit in the compliance officer seat.
Registration and agents
MSB registration and renewal, 30-day change filings, and the eligibility and record checks on every agent.
Risk assessment
Documented and tailored to your corridors, clients, payout partners and delivery channels.
Policies that match the counter
Written to fit how your branches and apps actually run, kept current, and approved by a senior officer.
Reporting and the 24-hour rule
EFTR, LCTR and STR filing, complete and on time, and the aggregation logic that quietly drops reports.
Ministerial directive controls
Screening that treats Russia, Iran and North Korea as high risk at any amount, with the records to show it.
Two-year effectiveness review
An independent review against the new effective standard, run before FINTRAC runs its own.
Start with a transfer reporting gap check
We sample a month of your international transfers and cash against what was actually filed, and tell you how many reports are missing before FINTRAC counts them for you.
contact@complyfactor.com · +1 807 806 0444
Sources: FINTRAC identity verification and EFT reporting guidance for MSBs; FINTRAC MSB guidance, directives and changes page; FINTRAC public penalty notices; AMP Regulations s. 5; FINTRAC penalty policy. ComplyFactor Remittance and Cross-Border Payments Leave-Behind, current to 22 September 2026.
Book a free Canada AML consultation
Tell us about your business and we'll confirm which services you need — free, no obligation, 30 minutes.
