Toronto, ON - April 6, 2026 - Substance Law, Canada's law firm for regulated substances and fintech, is alerting Money Services Businesses (MSBs) that FINTRAC registration revocations are accelerating, with enforcement activity in 2026 reflecting a markedly stricter regulatory environment for MSBs operating in Canada.
The Financial Transactions and Reports Analysis Centre of Canada, or FINTRAC, is the country's national financial intelligence unit and anti-money laundering regulator with which all of Canada's money services businesses must register.
In a recent statement by the Minister of Finance on Canada’s progress in combating money laundering, the federal government confirmed a significant escalation in enforcement, including multiple same-day revocations as part of broader anti-money laundering efforts - including 23 revocations on March 16, 2026.
This trend has continued, with 51 MSB registrations revoked on March 24, 2026, alone, underscoring FINTRAC’s increasingly assertive approach.
“Risks associated with potential FINTRAC MSB registration revocation are now a real threat for businesses in this space,” says Substance Law founder and managing lawyer Harrison Jordan. “The regulator is acting faster, and in greater numbers, than ever before.”
FINTRAC’s Authority to Deny or Revoke MSB Registration
FINTRAC may deny or revoke a registration if a money services business (MSB) or foreign MSB:
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is not eligible for registration;
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does not answer a clarification request within 30 days;
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does not respond, in a timely manner, to demands for information from FINTRAC;
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does not notify FINTRAC of updates to operating information (such as name or address); or
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fails to provide assistance to the Centre
These criteria demonstrate that failures in communication and responsiveness alone can result in revocation, even where a business is otherwise operational.
Review Process and Judicial Oversight
If a FINTRAC MSB registration is denied or revoked, businesses may request a review of their file within 30 days.
The review process involves an internal reconsideration by FINTRAC, after which businesses may seek an appeal before the Federal Court of Canada if they are dissatisfied with the outcome. This creates a limited and time-sensitive opportunity to challenge enforcement decisions.
Substance Law notes that engaging legal counsel early in this process can materially impact the strength of a review request and any subsequent court application.
How Legal Counsel Can Help
With FINTRAC ramping up enforcement, experienced legal counsel can play a critical role in protecting MSBs by:
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Preparing substantive and compliant responses to FINTRAC inquiries
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Managing timelines and communications with the regulator
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Identifying and correcting compliance deficiencies
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Representing businesses in reviews
Three Key Compliance Tips for MSBs
To reduce the risk of FINTRAC registration revocation, Substance Law recommends:
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Keep All Contact Information Up to Date Ensure FINTRAC has accurate and current business details at all times.
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Respond Substantively to All FINTRAC Enquiries Provide complete, timely, and well-supported responses—partial or delayed replies can trigger enforcement.
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Do Not Assume Extensions Are Granted If you request an extension, do not assume you have been granted one unless and until FINTRAC expressly confirms it.
A Clear Enforcement Signal
The increase in FINTRAC MSB registration revocations—highlighted by dozens of actions in a single day—signals a clear regulatory direction: heightened scrutiny, faster enforcement, and reduced tolerance for non-responsiveness.
“MSBs must treat every FINTRAC communication as potentially consequential,” Jordan adds. “Proactive compliance and timely legal advice are now essential.”
About Substance Law
Substance Law is a Canadian law firm specializing in regulatory compliance, including FINTRAC matters, anti-money laundering (AML), MSB registration, and Retail Payment Activities Act matters. The firm advises clients on navigating enforcement risks and maintaining compliant operations.
Media Contact
Company Name: Substance Law
Contact Person: Harrison Jordan
Email: Send Email
Phone: +1 (647) 371-0032
Country: Canada
Website: https://substancelaw.ca
