Fall 2021 Newsletter

Expanding a payment business into Canada requires navigating FINTRAC's Money Services Business registration framework. Understanding the regulatory requirements, compliance obligations, and practical steps for MSB registration helps international payment providers establish compliant operations in one of the world's most established financial markets.

The Office of the Superintendent of Financial Institutions (OSFI) published its third quarterly release of the year on September 10, 2026, noting that the targeted adjustments made to its guidance were made with a view to supporting a resilient and competitive Canadian financial system.

The Canadian Investment Regulatory Organization’s (CIRO) proposed Incorporated Approved Person model could materially change how client-facing advisors structure their businesses and receive compensation with significant impacts to sponsoring firms. The proposed rule amendments, published on July 9, 2026, would introduce a harmonized incorporated compensation option for client-facing Approved Persons across CIRO regulated dealers. Comments are due November 6, 2026.

This Bulletin summarizes key regulatory developments impacting the payments sector in 2025 and looks ahead to 2026.

Since the threats of new and increased U.S tariffs first emerged in the spring, the Ontario government has looked to reduce trade barriers and improve harmonization for licensing standards between provinces.

The Institutional Limited Partners Association (ILPA) recently released the third version of its principles (Principles 3.0), as well as a form of limited partnership agreement (model LPA, and...

The Canadian private equity landscape navigates a transition period marked by prolonged market volatility and stalled exit activity, yet demonstrates resilience through strategic investments in high-growth sectors. Q3 2026 analysis reveals how larger commitments, power and utilities investments, evergreen fund expansion, and healthcare sector dynamics are shaping the market amid escalating trade tensions and evolving investor strategies.

Bill C-12 has fundamentally transformed Canada's anti-money laundering framework by introducing penalties up to forty times higher than previous levels and expanding compliance obligations across the financial sector. The legislation now requires all reporting entities to enroll with FINTRAC and maintain "reasonably designed, risk-based and effective" compliance programs, while imposing cumulative maximum penalties that can reach 3% of global revenue.

The Bank of Canada (the Bank) has begun to exercise its enforcement powers under the Retail Payment Activities Act (RPAA), publishing its first enforcement decisions involving Notices of Violation against payment service providers (PSPs). Each published enforcement decision to date has involved a zero dollar administrative monetary penalty (AMP).

Canadian regulators have established a category-by-category framework for prediction markets, permitting certain economic and financial event contracts through securities dealers while directing sports and entertainment contracts outside that regime. This emerging approach creates distinct regulatory pathways depending on contract structure and underlying event type, raising critical questions about classification, market integrity, and compliance for platforms, dealers, and financial institutions navigatin