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ARTICLE · 12 NOVEMBER 2024

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Cash, Card, Or Crypto? How The RPAA May Impact Digital Assets Businesses

Cassels
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Cassels

Cassels Brock & Blackwell LLP is a Canadian law firm focused on serving the transaction, advocacy,...

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In August 2024, the Bank of Canada (the Bank) released further guidance on changes to the Retail Payment Activities Act (RPAA), which included case studies on Payment Service Providers (PSPs)...

CanadaTechnology

In August 2024, the Bank of Canada (the Bank) released further guidance on changes to the Retail Payment Activities Act (RPAA), which included case studies on Payment Service Providers (PSPs) that would need to register with the Bank under the RPAA. Now in effect, the RPAA's initial registration period opened on November 1, 2024, and will conclude on November 15, 2024.

Entities impacted by the RPAA include, but are not limited to, payroll services, e-commerce web tools, and cloud computing. The above-noted case studies also include details and guidance on “providers of services backed by cryptocurrencies.” This category has notable overlap with entities that are regulated under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), which applies broadly to companies dealing in virtual currency.

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