Money Services Business Premises in Ontario: FINTRAC Registration, Security and the Lease

By Jatin Dua · Broker of Record, RE/MAX Quantum Realty · Updated 18 October 2026 · 8 min read — what FINTRAC registration and the compliance program mean for each location, how to secure a currency exchange or money transfer counter, landlord and insurer concerns, zoning and the lease.

Looking for money services business space in Toronto or the GTA? Tell me what you need and I will send you units that fit, with the zoning and the lease checked before you commit.

Register with FINTRAC before you open the doors

A currency exchange, money transfer or remittance counter is a money services business under the federal Proceeds of Crime (Money Laundering) and Terrorist Financing Act. FINTRAC’s registration page says MSBs operating in Canada must register with FINTRAC before they begin to operate, that provincial or territorial registration or licensing does not replace FINTRAC registration, and that failure to register may result in administrative monetary penalties or criminal charges. FINTRAC does not charge a registration fee.

The registration is built around your locations. FINTRAC asks for detailed information about every location and every agent or mandatary acting for you, along with bank account details, your compliance officer, owners and senior management, and estimated annual transaction totals for each service. It also asks for criminal record checks, issued within six months before the application, for the CEO, president, directors and anyone who owns or controls 20 per cent or more. FINTRAC says most complete applications are processed within three months, and incomplete ones are closed.

That timeline drives the lease. Three months of rent on an empty counter is a real cost, so I negotiate a fixturing period or a condition tied to registration where the landlord will agree to it.

Every location is part of your registration

FINTRAC defines a branch as a part of your business at a distinct location other than your main office, and an MSB agent as an individual or entity authorized to deliver services on your behalf that is not an MSB branch. The difference matters when you sign leases.

• A new branch is new registration information. Section 11.13 of the Act requires a registered MSB to notify FINTRAC of any change to the information in its application within 30 days after becoming aware of it.
• A move changes your address, and FINTRAC’s public registry shows each MSB’s business address, services, status and registration and expiry dates.
• Renewal is due every two years under section 11.19, and section 11.2 requires notice within 30 days if you stop an activity you are registered for.

This is not paperwork that gets ignored. In December 2025 FINTRAC announced a $67,150 penalty against a Toronto MSB, imposed in August 2025. Among the violations it listed were missing compliance policies and a risk assessment, missed large cash and electronic funds transfer reports, and failing to give notice of a change to its MSB registration. FINTRAC also reported a record 23 notices of violation in 2024-25.

The compliance program and what it means for the space

FINTRAC’s compliance program guidance lists the required elements: a compliance officer, written and current policies and procedures approved by a senior officer, a documented risk assessment, a written ongoing training program and plan for employees and agents, and a documented review of the program’s effectiveness at least every two years. The risk assessment must consider the geographic locations where you operate, so the neighbourhood you choose becomes part of your compliance file.

Record keeping drives some of the physical setup. FINTRAC’s MSB record-keeping guidance includes:

• A large cash transaction record when you receive $10,000 or more in cash in a single transaction.
• A transaction ticket for every foreign currency exchange, regardless of amount, with full client details at $3,000 or more.
• Records for international electronic funds transfers of $1,000 or more and for remittances of $1,000 or more by other means.
• Retention for at least five years, kept so you can provide them to FINTRAC within 30 days of a request.

In the unit, that means a workstation where staff can identify clients and complete records without the next customer reading over their shoulder, secure storage for paper records, and a reliable network connection for reporting.

What the unit must have

Landlord and insurer concerns

Some landlords are wary of cash businesses, and it helps to answer their questions before they ask. Expect them to want your FINTRAC registration status, your security plan, proof of insurance and sometimes a larger deposit or a personal guarantee. Some plazas have tenants with exclusive or prohibited-use clauses that exclude cheque cashing or payday lending; currency exchange and remittance are different services, so the use clause has to describe exactly what you do.

Insurers look at cash and currency on premises, overnight limits, safe rating, alarm monitoring and staff procedures. Get the insurer’s requirements in writing before you finalize the fit-out, because alarm wiring, a safe anchored to the slab and camera placement all need landlord consent.

If the business sits inside another store, such as a remittance counter in a grocery or a currency counter in a jewellery store, the host’s lease must permit it and the host’s landlord may need to consent. Check whether you are a branch of your own MSB or an agent of a larger one; FINTRAC treats them differently.

That choice also changes the lease conversation. As an agent of a larger MSB, you typically rely on the principal’s registration and compliance program, but the principal will want to approve your location, train your staff and review your agreements, and FINTRAC’s guidance says effectiveness reviews may include agent agreements. As your own MSB with branches, every branch lease is your responsibility, and so is the 30-day notice when it opens. Decide which model you are in before you sign, because it determines whose approval the landlord’s condition should reference.

Plan cash logistics as well. Ask where an armoured car or your own staff would park and enter for deliveries and pickups, whether the rear door opens onto a lit, monitored area, and whether the landlord’s other tenants share that corridor. A unit that is perfect for walk-in customers can still be unsafe for cash movement.

Zoning, licensing and the name on the sign

In Toronto, Zoning By-law 569-2013 defines a Financial Institution as premises used to provide financial services to the public, other than exclusively through an automated banking machine. Ask the zoning desk whether your currency exchange or remittance counter falls under that use or another one, and whether it is permitted in the zone for that unit. Mississauga, Brampton and the other GTA cities have their own zoning by-laws and use names.

Payday lending is a different regime. Toronto Municipal Code Chapter 545 requires payday loan establishments to hold both a licence under Ontario’s Payday Loans Act, 2008 and a City licence, caps the number of licences and locations at the 2018 level, and says no new licence may be granted except on renewal. If a payday or cheque-cashing component is part of your plan in Toronto, find out early whether it is even available.

Watch the name too. Section 983 of the federal Bank Act makes it an offence for an entity other than a bank to adopt or use a name, domain name or identifying mark that includes the word bank, banker or banking to describe its business in Canada, unless authorized. Keep it off the fascia, the window and the website. The sign itself needs landlord approval and, in Toronto, a permit under Chapter 694.

The lease clauses that matter for a money services business

1. Permitted use. Name each service: foreign currency exchange, money transfer and remittance, and any others you are registered for. Avoid wording that sweeps in payday lending if you do not offer it. See how to word a use clause.
2. Regulatory condition. A condition or early termination right tied to FINTRAC registration or to adding the location to your registration.
3. Fixturing period. Rent-free time to build the counter, install the safe and alarm, and finish registration.
4. Security alterations. Consent to a secure counter, floor-anchored safe, alarm, cameras and reinforced rear door, and what must be removed or left at the end.
5. Access. Restrictions on landlord entry without notice to the cash area, with an emergency exception.
6. Hours. Your right to open evenings and weekends, which is when many remittance customers come.
7. Insurance. Coverage amounts the landlord requires, aligned with what your insurer will actually write.
8. Assignment. Consent to assign on a sale of the business, recognizing that the buyer will need its own FINTRAC registration.

Deal-killers to check on a viewing

• A plaza with an existing tenant’s exclusive or a prohibited-use list that captures money services.
• A landlord who refuses floor anchoring, alarm wiring or a reinforced rear door.
• A dark parking lot or a unit at the back of the plaza with no sight lines from the road.
• Shared rear corridors where cash deliveries cannot be made securely.
• A neighbourhood your risk assessment would flag, without a plan to address it.

Cash-heavy retailers face similar security questions; my notes on pawn shop premises and convenience store premises cover them from other angles.

Where I fit

I help currency exchange and money transfer owners across Toronto and the GTA find visible, secure plaza units and landlords who are comfortable with cash businesses, and I check zoning before you sign. I read the lease with you for the use, security and regulatory condition clauses, and if you are buying an existing counter, the retail store valuation tool gives a first read on value.

Frequently asked questions

Sources

• FINTRAC — Register your money services business — who must register, location and agent details, timelines
• FINTRAC — Money services business registry — published address, status and expiry
• Justice Laws — Proceeds of Crime (Money Laundering) and Terrorist Financing Act — ss. 11.13, 11.19, 11.2: changes, renewal, cessation
• FINTRAC — Compliance program requirements — five program elements, two-year review, branches and agents
• FINTRAC — Record keeping requirements for MSBs — thresholds and five-year retention
• FINTRAC — News release, 11 December 2025 — penalty against a Toronto MSB
• Justice Laws — Bank Act, section 983 — restriction on using the word bank
• City of Toronto — Municipal Code Chapter 545, Licensing — payday loan establishment licensing caps
• City of Toronto — Zoning By-law 569-2013, Chapter 800 Definitions — financial institution definition

Related reading

• Pawn shop and second-hand dealer premises
• Jewellery store premises
• Travel agency office space
• Convenience store premises in Ontario
• The commercial lease use clause
• The use clause in a commercial lease