FINTRAC Policy Interpretations for Proceeds of Crime Act

Detected March 6th, 2026

Summary

FINTRAC has updated its policy interpretations database concerning the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Notably, certain policy positions regarding payment processing and merchant servicing activities have been retracted as of April 27, 2022, with affected entities now subject to money services business requirements.

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What changed

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has updated its policy interpretations database, which provides guidance to entities obligated under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. A significant change noted is the retraction of policy interpretations (PI-7670) concerning payment processing and merchant servicing activities, effective April 27, 2022. Entities previously operating under these interpretations may now be classified as money services businesses or foreign money services businesses, requiring adherence to all associated obligations.

Regulated entities should review the updated guidance and archived interpretations to ensure ongoing compliance. The retraction of specific policy interpretations means that certain payment service providers must now register with FINTRAC and comply with the full scope of requirements for money services businesses. While the document provides general information and is not legal advice, it highlights that legislative and regulatory amendments may impact previous determinations, emphasizing the need to consider the date of each policy interpretation's answer and any subsequent changes to the Act and Regulations.

What to do next

Review updated FINTRAC policy interpretations for the Proceeds of Crime Act.
Assess if previous payment processing or merchant servicing activities now classify the entity as a Money Services Business or Foreign Money Services Business.
Ensure compliance with all associated obligations if reclassified.

Source document (simplified)

Policy interpretations database

From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

FINTRAC has been providing policy interpretations to persons and entities with obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations since 2008.

Note

Policy interpretations are based solely on the information provided to FINTRAC and may be subject to change if additional information becomes available. They are provided as general information. They are not legal advice, and are not intended to replace the Act and associated Regulations.

Each policy interpretation reflects the requirements of the Act and associated Regulations in force at the time they were written. Legislative and regulatory amendments may have taken place since the policy interpretation was issued that may impact the determination made at the time. Therefore, please take note of the date each policy interpretation request was answered.

As of April 27, 2022, the policy positions in the following PI (PI-7670) concerning payment processing and merchant servicing activities have been retracted. Certain payment service providers are now subject to the requirements under the Act and associated Regulations as money services businesses and foreign money services businesses, with all of the associated obligations, as described in the notice on Crowdfunding platforms and certain payment service providers must register with FINTRAC and the EFT definition was amended. See the Sector-specific guidance on Money Services Businesses for more information on who is a money services business or foreign money services business.

Most recently published interpretations 2022-11-21

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Archived policy interpretations

The following policy interpretations have been archived as a result of the coming into force of the amended Regulations on June 1st, 2021. This content will be removed on March 31, 2023.

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