Online Webinar: Registration of Existing MSBs with the Bank of Canada under RPAA Regulations
Regulatory framework

Life after MSB registration

Money services businesses (MSBs) are Canadian companies that provide certain financial services and are registered with the regulatory authority called FINTRAC. In terms of the range of permitted activities, MSBs are similar to European and British Electronic Money Institutions (EMIs), but can also be engaged in cryptocurrency operations.

Compliance program

Developing and implementing a compliance program is mandatory prior to starting operations. Compliance program is a set of guidelines and procedures designed to ensure that the MSB operates within the legal and regulatory framework set by Canadian authorities. These policies aim to prevent and combat money laundering and terrorist financing, ensure ethical business practices, and protect both the business and its clients from financial crimes and fraud. Advapay Canada drafts compliance programs for various types of money services businesses.

Compliance officer

MSBs must appoint a compliance officer responsible for implementation, updating and reviewing effectiveness of the compliance program.

Although there is no such legal requirement, it is strongly recommended to hire a local person with relevant experience in Canada to ensure smooth operations and increase credibility of the company in the eyes of banking partners.

Advapay Canada provides outsourced compliance officers as a part of compliance-as-a-service package.

KYC/KYB

MSBs must identify their individual and business customers upon establishing a business relationship with them.

Advapay Canada provides KYC/KYB services for its customers as a part of compliance-as-a-service package.

Reporting

MSBs are considered as reporting entities and must report eligible transactions to FINTRAC.

Main reports are:

  • Suspicious Transactions report (STR)
  • Electronic Funds transfers report (EFTR)
  • Large Cash Transactions report (LCTR)
  • Large Virtual Currency Transaction report

Advapay Canada provides reporting services for its customers as a part of compliance-as-a-service package.

Working with banking partners

Starting from November 1, 2024, a new law comes into effect, requiring some MSBs to store client funds in a safeguarding account in a regulated financial institution.

In addition, every MSB, being part of the global fintech ecosystem, needs to build a network of banking and payment partners. To effectively tackle this task, it's necessary to develop a partnership development program with banks and other financial institutions, as well as a set of documents typically requested by banks when MSBs open correspondent accounts. In addition to compliance policies, this includes a business plan, design of the flow of funds and outsourcing arrangements structure, information about UBOs, directors, and the company itself.

Advapay Canada provides assistance in opening accounts in banks and financial institutions, including preparation of necessary documents.

Core banking software

Although there is no legal requirements related to a core banking platform, it is strongly recommended to deploy such software to ensure smooth operations, especially:

  • KYC and KYB
  • Transaction Monitoring
  • Reporting
  • Automation of working with correspondent banks
  • Data protection
  • General management and control over customer database and account balances

Advapay Canada provides in-house-made core banking platform called Macrobank used by more than 40 regulated financial institutions across the globe.

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