Equilex
  • Case study
  • Payments & crypto
  • 2026

Canadian MSB registration for a crypto-to-card payments business

DFI Capital needed a regulated entity to run a virtual IBAN and card top-up product. Equilex proposed Canada, incorporated the company on March 3, 2026, and took the FINTRAC application from filing to registration in five months. RPAA registration with the Bank of Canada is in progress.

Jurisdiction
Canada
Federal MSB registration
Regulator
FINTRAC
Bank of Canada for RPAA
Time to registration
5 months
From filing to FINTRAC listing
Incorporated
Mar 3, 2026
New Canadian company
Status
Registered
RPAA registration in progress

How the project ran

January 2026 to present

  1. Completed: Late Jan 2026

    Request received

    Three payment flows described in the first message

  2. Completed: February

    Jurisdiction and structure agreed

    One month of calls, ownership structure, services agreement

  3. Completed: Mar 3, 2026

    Company incorporated

    EU EMI onboarding and accounting setup started the same week

  4. Completed: Five months on

    FINTRAC registration

    No repeat rounds on the client side

  5. In progress: Now

    RPAA with the Bank of Canada

    Questionnaires, safeguarding account, activity perimeter

The brief

The first message from DFI Capital described the product in three lines. A customer tops up in crypto and withdraws in fiat. A customer tops up in crypto and spends from a debit card. A customer tops up in fiat and spends from the same card. Behind those lines sat a virtual IBAN program and a card program, and both needed a regulated entity the client did not yet have in the right shape.

  • Flow 1

    Crypto top-up → fiat withdrawal

  • Flow 2

    Crypto top-up → debit card

  • Flow 3

    Fiat top-up → debit card

Why Canada

The client's existing corporate structure ruled out a long licensing track for the new entity. Over several calls Equilex proposed Canadian MSB registration: FINTRAC processes applications in four to six months on average, and one registration covers the virtual currency dealing and the fiat transfers the three flows require.

Agreeing the jurisdiction, the ownership structure of the new company and the services agreement took a month. The client set that pace. There was no launch date to chase, and the structure had to sit comfortably inside the group rather than the group bending around it. That is also why the company was registered from scratch rather than bought ready-made.

Setting up the company

Equilex incorporated the Canadian company on March 3, 2026. Two workstreams started the same week. The first was onboarding with an EU EMI for an operating account in EUR, USD and GBP, so the company could pay its own costs before the MSB registration came through. The second was accounting and tax setup, which in Canada starts with the questions below rather than with a bookkeeper.

Nine questions the client answered before the first transaction

CRA compliance profile

  1. Business operations

    Activities, products, contractual flow, revenue streams

  2. Commencement of business

    First commercial activity and any pre-operating transactions

  3. Revenue profile

    Expected revenue, currencies, B2B or B2C, customer jurisdictions

  4. Corporate structure

    Legal and beneficial shareholders, shares issued, related corporations

  5. Management and control

    Where directors sit and where decisions are made

  6. Canadian presence

    Office, employees, contractors, agents, equipment

  7. Banking and accounting

    Accounts, processors, software, reporting currency

  8. GST/HST

    Program account and the nature of taxable supplies

  9. Payroll

    Canadian staff and information-return reporting

These answers fix the fiscal year-end, the accounting framework and chart of accounts, the T2 filing profile, GST/HST registration and place-of-supply position, payroll obligations and related-party reporting. Changing them later costs more than answering them in week one.

The FINTRAC application

Five months from filing to registration, which under current processing times is a good result. The application moved at the speed the client answered: operation volumes, the scope of activities and the geography of the customer base came back in full the first time, so Equilex did not lose weeks to repeat rounds.

What is running now

Registration starts the obligations rather than ending them. Equilex is now handling the client's RPAA registration with the Bank of Canada: the questionnaires on third-party agents, retail payment activities and the geographic perimeter of operations, and the opening of a bank or trust account the regulator accepts for holding end-user funds.

  • In progress

    RPAA registration, Bank of Canada

    Third-party agents, retail payment activities, geographic perimeter

  • In progress

    Safeguarding account

    Bank or trust account acceptable to the regulator for end-user funds

Services provided

Building a card or payments product that needs a regulated entity?

Tell us the flows. We will say whether Canadian MSB fits, what it will not cover, and what the timeline looks like today.

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