New MSB-Style Obligations, 2024–2025: Cheque Cashing, Private ATMs, Armoured Cars

The MSB definition in the PCMLTFA has never been a closed list. Section 5(h) captures Canadian money services businesses and s. 5(h.1) captures foreign businesses directing services at people in Canada, and both include services prescribed by regulation — a mechanism that lets the government add activities without amending the Act. Between mid-2024 and late 2025 that mechanism brought three business models into the regime: transporting currency or negotiable instruments (the armoured car sector), in force July 1, 2024; cheque-cashing services, prescribed under PCMLTFR s. 29.1; and acquirer services for private automated banking machines, in force October 1, 2025.

The pattern across all three is the same: the obligation attaches to a specific service, not to a business category or to owning particular equipment. The scoping question — which service do we actually provide, and since when — matters more than anything downstream, because registration, the compliance program, and reporting all flow from it.

PCMLTFR s. 29.1 prescribes cheque-cashing services (alongside crowdfunding platform services) as MSB services for the purposes of PCMLTFA s. 5(h)(v) and s. 5(h.1)(v). The captured activity is cashing cheques for clients in exchange for funds — a storefront or online service that gives a customer cash or a transfer for their cheque, usually less a fee, instead of the customer depositing it into their own account.

The threshold question is whether you provide this to clients as a service. Cashing cheques made payable to your own business is handling receivables, not serving clients. But a business that offers, advertises, or charges for cashing other people's cheques sits squarely in the prescribed activity, and typically responds by reviewing registration, client identification, record-keeping, reporting, and compliance-program obligations against the current FINTRAC guidance.

The first of the three additions to take effect was the transportation of currency and negotiable instruments, with obligations in force July 1, 2024. The scoping logic mirrors the others: the trigger is providing transport of cash or certain instruments as a service, not moving your own float between your own locations. Exactly which instruments and transport arrangements are covered is set out in the current FINTRAC guidance, so businesses in this sector typically map each contract type — retail cash pickup, ATM replenishment, transfers between financial institution branches — against that guidance and document the conclusion for each service line.

Acquirer services for private automated banking machines — white-label ATMs not operated by a financial institution — became a registerable MSB/FMSB activity in force October 1, 2025. The regulated role is the acquirer: the party connecting the machine to the payment card networks and settling its transactions. Owning the physical machine, hosting it in a convenience store, or loading the cash are different roles, and they are not what the provision targets.

Because a single private ATM can involve several parties — site owner, machine owner, cash loader, network, acquirer — the first step is mapping which role your contracts actually assign you. If you provide the acquirer service, registration and the full obligation set follow. If you host or own hardware without acquiring, your position differs, but write the analysis down rather than assuming: the roles blur in practice, particularly where one company both owns machines and settles their transactions.

Registration under PCMLTFA s. 11.1 is the visible step, but the substantive work is the compliance program. PCMLTFA s. 9.6 requires a program that is reasonably designed, risk-based, and effective, and PCMLTFR ss. 156–157 set out the elements: an appointed compliance officer, written policies and procedures, a documented risk assessment, training, and an effectiveness review every two years. For a newly scoped business the realistic sequence is to confirm which prescribed service it provides and from what in-force date, register, appoint the officer, write policies that reflect the actual product flow, and keep a dated memo of the scoping analysis itself — that memo is the document FINTRAC will ask about first.

One caution on older research: FINTRAC withdrew its PI-7670 policy interpretation positions on merchant servicing and payment processing effective April 27, 2022. Scoping analysis that leans on pre-2022 interpretation letters — still common in the private-ATM and payment-processing space — needs to be redone against the current Act, regulations, and guidance.