NON-BANK FINANCIAL INSTITUTIONS AND SERVICE PROVIDERS

The AML Shop's team of experts have extensive experience with non-bank financial institutions and service providers. Some of our clients include MSBs, PSPs, mortgage, finance and leasing companies, as well as dealers in virtual currency and precious metals and stones. We know that each provider has unique needs when it comes to AML compliance and it is our mission to ensure our clients are compliant with the most current regulatory requirements. 

RETAIL PAYMENT ACTIVITIES ACT

In Canada, the newly released Retail Payment Activities Act (RPAA) impacts compliance for how payments function for MSB’s, FMSB’s and PSP’s.  Being aware of the latest best practices when it comes to sending, receiving or holding electronic payments is vital for your businesses compliance. The AML Shop’s team of experts are here to assist and are qualified to help you navigate these new regulations to ensure your business is compliant with all the latest requirements. 

RETAIL PAYMENT ACTIVITIES ACT NEW SUPERVISORY POLICIES - APRIL 2024

The Bank of Canada (the “Bank”) has released new supervisory policies under the Retail Payment Activities Act (RPAA). These policies are the Bank of Canada’s way of communicating how they intend on enforcing the RPAA with regulated entities - known as Payment Services Providers, or PSPs.  

We found a few of these policies to be important for payments businesses and have outlined them and our view of their implications below.  

PRESCRIBED SUPERVISORY INFORMATION 

The new policies set out the types of information supplied by a PSP to the Bank of Canada that cannot be used as evidence in certain court cases, and information and communications provided by the bank that payments companies cannot disclose further.

These new policies are important as they lead to more certainty about how information will flow between the Bank of Canada and PSPs. For more information, please contactus@theamlshop.ca 

RECORD KEEPING

The record-keeping policy outlines what PSPs should retain to meet their obligations.

The list of record keeping requirements is extensive and includes these categories of records:

• Operational Risk Management and Incident Response Requirements

• Incident notification requirements

• Holding funds

• Other requirements to provide information to the Bank of Canada include items such as annual reports, significant changes or new activity, registration changes, PSP information changes, change in prescribed information of a registration application, special audits information requests relating to assessment fees and requirements around end user funds.

The full guidance and case studies can be reviewed on the Bank of Canada’s Website.

As these new policies are highly intricate, our RPAA Experts are on Standby to help your business navigate within its specific need and context.

For further information about these new supervisory policies or anything to do with the Retail Payment Activities Act, Contact an AML expert today for advice.

OUTSOURCING YOUR AML 

Have a FINTRAC exam coming up or are you considering outsourcing your compliance role completely? The AML Shop was created by AML professionals, for AML professionals and in November 2019 OSC announced it will make it easier for smaller firms to outsource their compliance duties related to AML - now's the time to get in touch.

The following are businesses and service providers we work with