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How Does a FINCEN MSB License Work for Businesses in Canada?
Learn how FINCEN MSB registration works for Canadian businesses offering cross-border payment or money services and what compliance requirements apply.

BancorpTrust

A FINCEN MSB license—more accurately called a FINCEN Money Services Business (MSB) registration—is a U.S. federal registration required for companies that provide money transmission, currency exchange, prepaid access, or certain digital asset services involving U.S. customers. Canadian businesses do not receive a “banking license” from FINCEN. Instead, they may be required to register as an MSB with the U.S. Financial Crimes Enforcement Network (FINCEN) if they conduct money services activities that touch the United States or involve U.S. persons. Registration establishes federal reporting obligations, anti-money laundering (AML) compliance requirements, and ongoing regulatory responsibilities under U.S. law.

What Is a Private Label Visa Card Program?

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A private label Visa card program allows a company to issue branded payment cards using the Visa network, without becoming a bank itself.

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The key components include:

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  • Visa network membership (through a sponsor bank)

  • BIN sponsorship agreement

  • Issuer bank partnership

  • Program manager infrastructure

  • Compliance and reporting systems

  • Card processing and settlement integration

 

You control branding and customer experience.
The issuing bank controls regulatory oversight and card issuance authority.

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Can You Issue Visa Cards Directly in Canada?

No.

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To issue Visa cards directly, an entity must be a licensed financial institution and a Visa principal member. Most fintech founders and digital platforms do not meet these requirements.

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Instead, you must work with:

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  • A BIN sponsor (Bank Identification Number sponsor)

  • A licensed issuer bank

  • A compliant financial services framework

  • A settlement and reporting infrastructure provider

 

This structure ensures regulatory alignment with:

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  • Canadian financial regulations

  • Anti-money laundering (AML) rules

  • Know Your Customer (KYC) requirements

  • Visa network operating regulations

 

How the Structure Typically Works

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Step 1: Establish Your Legal & Compliance Framework

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This may involve:

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  • Canadian MSB registration (if applicable)

  • U.S. FINCEN MSB registration (if cross-border)

  • Corporate entity formation

  • Compliance officer designation

  • AML/KYC policy implementation

 

Step 2: Secure BIN Sponsorship

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A sponsor bank provides:

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  • Access to Visa network

  • BIN allocation

  • Regulatory supervision

  • Card issuing authority

 

You operate as the program manager or branded platform.

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Step 3: Integrate Card Processing & Settlement Infrastructure

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You must integrate:

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  • Core wallet infrastructure

  • Payment rails

  • Transaction monitoring

  • Fraud controls

  • Settlement gateway

  • API systems

 

This is where turnkey private-label blockchain banking infrastructure can significantly reduce build complexity.

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What Types of Cards Can You Launch?

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Depending on structure:

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  • Prepaid Visa cards

  • Debit Visa cards

  • Virtual Visa cards

  • Multi-currency cards

  • Crypto-linked debit cards (where permitted)

 

Each card type has different regulatory and capital requirements.

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What Are the Regulatory Considerations?

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Key factors include:

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  • AML compliance program

  • Ongoing transaction monitoring

  • Reporting obligations

  • Cross-border regulatory exposure

  • Cardholder fund safeguarding requirements

 

Important clarification:

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A private label Visa program does not make you a bank.
You operate under the issuing bank’s license.

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How Blockchain Infrastructure Can Support Card Programs

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Modern fintech operators increasingly integrate:

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  • Non-custodial wallet systems

  • Blockchain-based settlement

  • API-driven transaction infrastructure

  • Flat-fee settlement models

  • Digital identity integration

 

This allows card programs to operate alongside blockchain-native payment ecosystems without requiring deposit-taking structures.

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Who This Is Designed For

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A private label Visa card program in Canada may be suitable for:

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  • Fintech founders

  • Digital banking startups

  • Crypto platforms

  • Online marketplaces

  • Creator economy platforms

  • Cross-border payment networks

  • Community-based financial ecosystems

 

Common Mistakes to Avoid

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  • Attempting to issue cards without a sponsor bank

  • Misrepresenting the structure as a bank

  • Underestimating compliance costs

  • Ignoring cross-border regulatory exposure

  • Failing to implement proper AML monitoring

 

Final Clarification

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Launching a private label Visa card program in Canada requires structured partnerships, regulatory alignment, and payment infrastructure integration. Most operators reduce complexity by working with an established financial architecture provider that integrates compliance, settlement, and card issuing partnerships into one deployable framework.

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For more information you can contact:

 

BANCORPTRUST

Bankers Hall, 888 3rd Street

Calgary, AB T2P 5C5, Canada

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Phone:          +1-587-430-2692

WhatsApp: +1-610-994-1639

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 E-mail:    peter.graf@bancorptrust.com

Website: www.bancorptrust.com

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