Money Services Business Requirements for ATM Operators
- Alex Jackson
- Jul 7
- 7 min read
As an experienced ATM operator, you're already analyzing the regulatory changes coming October 1, 2025. The new Money Services Business requirements for ATM operators represent the most significant compliance shift since you started your business. Companies that provide acquiring services for white-label ATMs must now register with FINTRAC and implement comprehensive anti-money laundering programs.
This regulatory change affects approximately 10,000 ATM owners across Canada, but the compliance burden falls primarily on the three main acquiring companies that connect these machines to payment networks. If your business provides acquiring services, you're facing a fundamental transformation in how you operate.
What makes you subject to these rules
The Fall Economic Statement Implementation Act, 2023 defines white-label ATMs as "privately owned and operated cash machines, often located in retail locations." If you're an acquirer - meaning you connect these ATMs to payment networks like Interac - you must register as an MSB.
FINTRAC defines an acquirer as "an entity that connects a private automated banking machine to a payment card network, as defined in section 3 of the Payment Card Networks Act, to facilitate transactions." This means if you provide the technology that lets ATMs process bank cards, you're covered by these rules.
The Canada Gazette regulatory impact analysis shows that only three main companies currently provide acquiring services for Canada's white-label ATMs. These companies connect approximately 10,000 independently-owned ATMs to payment networks. If you own ATMs but use someone else's acquiring services, you're not directly affected - but your acquirer is.
Understanding Money Services Business Requirements for ATM Operators
The new Money Services Business requirements for ATM operators represent the most significant regulatory change in the Canadian ATM industry since EMV chip card adoption.
These rules apply specifically to companies that provide acquiring services for white-label ATMs.
The five pillars of compliance you must implement
FINTRAC's compliance program requirements mandate five specific elements that every MSB must have:
1. Appoint a compliance officer Your compliance officer needs real authority to implement your program. They must understand anti-money laundering rules and report to senior management. Budget $73,102 CAD on average for a full-time officer, according to 2024 Canadian salary data.
2. Create written policies and procedures You need detailed, written rules covering every aspect of compliance. A senior officer must approve these policies. They must explain how you'll identify clients, monitor transactions, and report suspicious activity. Update them whenever regulations change.
3. Complete a risk assessment Document the money laundering risks in your business. Consider your ATM locations, transaction volumes, and client types. The 2023 RCMP assessment found criminals could launder $315 million to $1 billion annually through white-label ATMs. Your assessment must show how you'll reduce these risks.
4. Train your staff continuously Everyone who works with your compliance program needs training. This includes your tech staff, compliance team, and anyone who handles reports. Document who gets trained, when, and on what topics. Budget $2,000 to $5,000 annually for training costs.
5. Review effectiveness every two years You must test whether your compliance program actually works. Start your first review within 24 months of registration. Document what you tested and what you found. Report results to senior management within 30 days. Professional reviews cost $10,000 to $25,000.
Exact reporting requirements and deadlines
FINTRAC's reporting guidance sets specific thresholds and deadlines:
Large Cash Transaction Reports must be filed within 15 calendar days for any cash transaction of $10,000 or more. The 24-hour rule means you must add up multiple transactions by the same person within any 24-hour period.
Suspicious Transaction Reports have no dollar threshold. File them "as soon as practicable" after finding reasonable grounds to suspect money laundering. FINTRAC interprets this as immediately after completing your assessment.
Electronic Funds Transfer Reports follow the same $10,000 threshold and 15-day deadline as cash reports. This covers transfers into or out of Canada.
Keep all records for at least five years from creation date. You must be able to provide any record to FINTRAC within 30 days of their request, as outlined in FINTRAC's record-keeping requirements.
Technology and systems you'll need
FINTRAC's technology requirements include:
You must register for FINTRAC's Web Reporting System to submit reports online. Large cash transaction reports submitted after November 6, 2023 must use FINTRAC's API system. Your systems must handle batch reporting following FINTRAC's standard format.
Electronic signatures can be numeric (like PINs), character-based, or biometric. They must be unique to each person and reviewable during FINTRAC examinations.
Budget $5,000 to $25,000 annually or more for AML compliance software that handles transaction monitoring, reporting, and record-keeping.
Criminal and monetary penalties for non-compliance
FINTRAC's enforcement data shows serious consequences for violations:
Administrative penalties range from $1 to $500,000 per violation. Failing to register as an MSB can cost up to $100,000. In 2020, Apadana Forex paid $206,250 for three violations including failure to report suspicious transactions.
Criminal penalties under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act include:
Failure to report suspicious transactions: Up to $2 million fine and/or 5 years imprisonment
Failure to register as MSB: $250,000 to $2 million fine and/or up to 5 years imprisonment
First-time failure to report large cash transactions: Up to $500,000 fine
Recent enforcement actions demonstrate FINTRAC's commitment to compliance. Analysis of FINTRAC penalties shows the regulator has imposed over $5 million in fines in recent years across various sectors.
Step-by-step registration process
FINTRAC's registration process takes 3 to 6 months:
Step 1: Pre-registration (4-8 weeks) Complete the online form at FINTRAC's website. A compliance officer will contact you to start full registration.
Step 2: Submit detailed information Provide your business structure, expected transaction volumes, and service details. List all owners with 20% or more ownership. Include criminal record checks for key personnel.
Step 3: Document submission Submit police record checks for all major owners. Translate any documents not in English or French. Include your compliance program outline.
Step 4: FINTRAC review (30-90 days) FINTRAC reviews your application. They may ask for clarifications. Once approved, you'll receive your MSB registration number.
Registration is free, but you must renew every two years.
What compliance will actually cost you
Based on 2024-2025 Canadian market research and industry salary data:
First-year costs:
Professional registration services: $15,000 to $40,000
Compliance officer salary: $73,102 (average)
AML software: $5,000 to $25,000
Training programs: $2,000 to $5,000
Total: $95,102 to $143,102
Annual ongoing costs:
Compliance officer: $73,102
Software and systems: $5,000 to $25,000
Training updates: $2,000 to $5,000
Effectiveness review (every 2 years): $5,000 to $12,500 (annualized)
Total: $85,102 to $115,602 per year
Small operations might reduce costs with part-time compliance officers ($30,000 to $50,000) or fractional compliance services.
Important disclaimer: Compliance costs vary significantly based on individual circumstances including route size, geographic distribution, existing systems, and operational complexity. The ranges provided are for general educational purposes only. Exact costs can only be determined through professional assessment by qualified compliance specialists.
Implementation challenges to prepare for
The regulatory impact analysis identifies key challenges as ATM operators adapt to Money Services Business requirements:
Banking relationships become harder to obtain. Banks require enhanced due diligence for MSBs. Expect higher fees and security deposits. Start banking conversations before you register.
Compliance complexity requires expertise. Many acquirers currently follow voluntary industry rules from 2008. The new Money Services Business requirements for ATM operators are much more detailed and enforced.
Technology integration needs planning. Your compliance systems must connect to your ATM network while protecting data privacy. Plan for significant IT costs.
Timeline for implementation
The October 1, 2025 coming-into-force date is firm. Here's your implementation timeline:
Immediately (January-March 2025):
Assess whether you're an acquirer under FINTRAC's definition
Begin budgeting for compliance costs
Start searching for qualified compliance professionals
Q2 2025 (April-June):
Submit FINTRAC registration application
Implement required technology systems
Develop written policies and procedures
Q3 2025 (July-September):
Complete staff training programs
Test compliance systems
Finalize banking relationships
October 1, 2025:
Full compliance required
Begin ongoing reporting obligations
Professional resources and next steps
Most ATM operators need specialized help with FINTRAC compliance. Consider engaging:
AML compliance consultants who understand both ATM operations and FINTRAC requirements
Legal counsel specializing in financial services regulation
Technology vendors providing FINTRAC-compliant reporting systems
Accounting firms experienced with MSB record-keeping requirements
When evaluating service providers, ask about their specific experience with FINTRAC requirements, their track record with examinations, and how they stay updated on regulatory changes.
Conclusion
The new Money Services Business requirements for ATM operators represent a fundamental shift in regulatory oversight. With total first-year costs potentially exceeding $140,000 and ongoing annual costs around $100,000, acquiring companies face significant investment decisions.
The Department of Finance's analysis shows these rules target real risks - criminals potentially laundering up to $1 billion annually through white-label ATMs. While compliance is expensive, the penalties for non-compliance include million-dollar fines and potential imprisonment.
Start by determining if you're an acquirer under FINTRAC's definition. If you connect ATMs to payment networks, begin compliance planning immediately. Contact FINTRAC at guidelines-lignesdirectrices@fintrac-canafe.gc.ca with specific questions about your situation.
Important Disclosures: This content is for educational purposes only and does not constitute financial, legal, or business advice. Experience Innovation Consulting Inc. operates as both a lead generation service and business consulting firm. As a lead generation service, we collect contact information from ATM route owners and provide this information to our business partners, earning commission fees from successful referrals. We also offer business consulting services providing general guidance only. We do not provide brokerage services, formal business valuations, legal advice, or financial planning services. We do not pre-qualify buyers or guarantee any outcomes. Compliance costs vary significantly based on individual circumstances including route size, geographic distribution, existing systems, and operational complexity. The ranges provided are for general educational purposes only. Exact costs can only be determined through professional assessment by qualified compliance specialists. ATM route owners should conduct their own due diligence and consult qualified professionals including legal counsel, accountants, and certified business valuators before making any business decisions. Individual results may vary, and past performance does not guarantee future results.
