Payments Studio · Regulatory preparation
Operational preparation for RPAA, FINTRAC and US money transmitter requirements
Regulators, partner banks and auditors ask the same core questions: how funds flow, who holds them, how they are safeguarded and how balances are reconciled. We prepare that material with your team, and your counsel handles the legal position and filings.
Preparation, not legal advice
This is preparation, not legal advice. Registrations, filings and legal opinions are handled by your counsel. [LEGAL]
Canada
Retail Payment Activities Act (RPAA)
Payment service providers that meet the Act's criteria must register with the Bank of Canada. Risk-management and incident-response framework [VERIFY wording] and safeguarding requirements came into force on 8 September 2025. Safeguarding means holding end-user funds in trust, or in a segregated account with insurance or a guarantee. Annual reports are due by 31 March. [LEGAL]
Source: Bank of Canada supervisory framework [link] · Last checked: Nov 2026
What we prepare
- Flow-of-funds documentation
- Safeguarding arrangement description and reconciliation evidence
- Inputs to the risk-management and incident-response framework
- Data for the annual report
Canada
FINTRAC
Businesses providing money services may need to register with FINTRAC and run a compliance program covering client identification, record keeping and reporting. [LEGAL]
Source: FINTRAC [link]
Since September 2025, PSPs registered under both the RPAA and with FINTRAC can apply for access to Interac e-Transfer. [Source: Interac, link]
What we prepare
- KYC and KYB flow design
- Record-keeping data model
- Reporting data extracts
- Operational descriptions for the compliance officer's program documents
Canada
Bank access
Opening and keeping a bank account is often the longer step. Banks ask for end-to-end transaction flow diagrams and a description of safeguarding and reconciliation arrangements. [Source: CBG-A, link] We prepare that pack.
United States
FinCEN and state money transmitter licences
Money transmission may require FinCEN registration and licences state by state. Many early-stage companies operate under a sponsor bank or a licensed partner while they assess licensing. Published estimates of the cost and time of a multi-state licence program vary widely, which is a reason to get your counsel's view early. [Sources: link, link] [LEGAL]
What we prepare
- Flow-of-funds and partner-model documentation for counsel
- Data and process descriptions for applications
- Sponsor-bank due-diligence responses
Frequently asked questions
Can you tell us whether we need to register?
No. That is a legal opinion. We give your counsel the operational facts they need to decide.
Do you file applications?
No. Your counsel or compliance officer files.
Book a 15‑minute call
Tell us what you are building, your stage, the rails or countries involved and your timeline. We'll set up a 15‑minute call. If we're not the right firm, we'll say so and suggest someone who is.