Running a money services business (MSB) in Canada is already complex, but as of October 1, 2025, the rules are tightening even further. The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has introduced new obligations that affect how MSBs operate, especially when it comes to oversight of agents and verifying beneficial ownership. These updates are designed to close loopholes, prevent money laundering, and strengthen Canada’s overall financial system.
For MSBs and foreign MSBs, this means more responsibility and more scrutiny. It also means that the time to prepare is now. Let’s break down the three biggest changes and what your business should do about them.
Strengthening Oversight of Agents and Mandataries: What MSBs Must Do by October 2025
One of the most significant updates for MSBs is the new requirement to verify the eligibility of any agent or mandatary that provides services on their behalf. This includes conducting a criminal record check for agents, which must be part of your due diligence before they can deliver services under your business name.
Why does this matter? Agents and mandataries act as extensions of your MSB. If they fail to meet FINTRAC compliance standards, it is your business that will be held accountable. These new rules are meant to ensure that only trustworthy and transparent individuals are handling financial transactions in Canada’s money services industry.
To meet the msb regulatory requirements, MSBs should:
- Establish a process to request and review criminal record checks for all agents or mandataries
- Document all steps taken to verify eligibility and maintain these records for audit purposes
- Update your compliance policies and procedures to reflect this obligation
- Train your staff on how to recognize potential risks when onboarding or monitoring agents
If you’re unsure about building these processes, Comply North can help. Our Chief Compliance Officer as a Service offers professional, reliable oversight with direct experience working with FINTRAC. We’ll help you set up cost-effective systems that pass regulatory inspection.
You can read more about the obligations of MSBs and foreign MSBs in FINTRAC’s own guidance for money services businesses.
New Beneficial Ownership Verification Rules and How to Stay Compliant
The second major beneficial ownership update affects all reporting entities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Starting October 2025, businesses must go beyond simply collecting beneficial ownership details. If a client is incorporated under the Canada Business Corporations Act and is considered high risk, you are now required to perform a Corporations Canada database search to validate the individuals with significant control.
If there is a conflict between the information you gathered from your client and what appears in the federal database, you must file a discrepancy report with Corporations Canada. This is a major shift from previous requirements, where recordkeeping alone was enough.
To stay compliant with this new rule, your MSB should:
- Identify high-risk corporate clients during the onboarding process
- Cross-check their beneficial ownership information against the official Corporations Canada database
- Record any discrepancies and submit a report without delay
- Maintain an internal log of all searches and reports for audit purposes
This may sound overwhelming, but it doesn’t have to be. Comply North specializes in FINTRAC compliance and can help your MSB design a streamlined verification process. Our affordable compliance services ensure your business meets the highest standards while avoiding penalties.
For more detailed guidance, visit FINTRAC’s beneficial ownership obligations page.
Preparing for Enforcement: Practical Steps MSBs Should Take Now
With these new obligations, FINTRAC is signaling that enforcement will only increase. Failing to follow the updated rules could mean hefty penalties, reputational damage, and even the loss of your MSB registration. The best defense is preparation.
Here are five practical steps every MSB should take before October 1, 2025:
- Review and update your compliance program with the new requirements
- Build checklists for both agent verification and beneficial ownership searches
- Train employees to understand the changes and how to apply them
- Schedule regular audits to test the effectiveness of your compliance program
- Consider outsourcing oversight to a professional compliance service like Comply North
By acting now, your MSB will be ready when regulators come knocking. You’ll not only meet the msb regulatory requirements but also demonstrate that your business takes compliance seriously.
Final Thoughts
The October 2025 updates are not optional. From verifying agents with criminal record checks to conducting database searches for beneficial ownership, the expectations on MSBs are higher than ever. While the changes may seem demanding, they are manageable with the right systems in place.
By staying proactive and leveraging expert support, your money services business can not only stay compliant but also build trust with clients and regulators alike.
If you want peace of mind knowing your compliance program is in the best hands, reach out to Comply North today. We’ll make sure your business is prepared, protected, and positioned for success.