Karsten Wenzlaff, Advisor
August 26th, 2025
MinervaAI.io | Jennifer Arnold and Charlene Sebastian | Dec 7, 2021

Canada’s innovation landscape is evolving like never before. With Payments Modernization, Open Banking, and the approval of Canada’s first crypto-asset custodian, Canadian regulators are also stepping up to the plate, ensuring protection for consumers. This means constant and rapid adjustment of regulatory frameworks to ensure regulations reflect the nuances that innovation brings, while addressing customer demand for advanced technology and simplified experiences through leveraging digital options.
That can make it hard for startups and even established organizations to keep up with the changes, let alone ensure that they have the right tools and resources to operationalize complex legislative requirements.
When it comes to compliance for FinTech, Security and Data protection often take the lion’s share of focus and can eat up a significant chunk of capital along the way. For example, the average cost of SOC 2 Type 2 compliance, a precursor for the vendor management process, ranges from $30-40K – not including the costs to get there, which can be well over $100K.
The mainstream adoption of virtual assets in the retail consumer space (e.g., cryptocurrencies, NFT’s and the like), coupled with modernized payment rails and consumer directed finance, points to a likely increase of entrants into the payments market – a historical “sweet spot” offering for startups. Along with this comes an increased focus on consumer protection while trying to balance innovation and competition.
This is the driver for the new Retail Payments Activities Act (RPAA), passed on June 29, 2021, and continued updates to the Proceeds of Crime (Anti-Money Laundering) and Terrorist Financing Regulations (PCMLTFR).
The RPAA defines the nature of a Payment Service Provider (PSP) and requires PSPs to register with the Bank of Canada who will administer and enforce the RPAA, including financial penalties for violations.
A PSP is defined as “an individual or entity that performs payment functions as a service or business activity that is not incidental to another service or business activity” and covers “any retail payment activity that is performed by a payment service provider that has a place of business in Canada…(or) performed for an end user in Canada by a payment service provider that does not have a place of business in Canada but directs retail payment activities at individuals or entities that are in Canada.”
While there are some exceptions, this aligns directly to the FINTRAC definition of a Money Services Business (MSB) including services dealing with virtual currencies. This evokes the requirement to also register with FINTRAC and directly connects a PSP to the obligations outlined in the PCMLTFR for an MSB. It’s important to note that the PCMLTFR already accounts for Money Services Businesses (MSB’s) and Virtual Asset Service Providers (VASP’s) and has for several years.
If you are unsure whether you fall under these categories, please reach out to us and we’d be happy to review the criteria together.
In short, MSB’s must set up a compliance program that consists of knowing your customer (KYC - verifying their identity) and conducting a risk assessment of your customer base to determine the level of due diligence and ongoing monitoring required. Risk assessments should be updated regularly to and in accordance with detailed FINTRAC guidance.
In addition to screening for Sanctions compliance and Politically Exposed Persons (PEP), there are multiple reporting requirements depending on the types of transactions conducted and in relation to customer risk. There are also special requirements when certain types of transactions are above a specified monetary threshold.
It depends. Factors like customer risk, volume, and velocity of transactions weigh into the costs of establishing a compliance program.
...but making sure you get it right, protects you from fines. FINTRAC actively enforces penalties for violations, and if the US and UK examples are any indicator, monetary penalties are positioned to grow. Even a small fine can cripple a smaller firm.
Trust is also a huge factor in influencing retail adoption for new entrants, especially for newer players in the crypto space. An enforcement action can have significant reputational risk, something a startup may never recover from.

What we do know is that leveraging established Regulatory as a Service tools like MinervaAI can help you deliver on your obligations and are proven to be much more effective and efficient than traditional methods alone.
Firms like MinervaAI are led by professionals with deep knowledge of the regulations, the investigations process, and the machine and deep learning expertise to “plug and play” into your existing technology and process ecosystem. AI innovations coupled with cloud scalability allows investigators to do in minutes, what would traditionally take hours and days to do.
Compliance doesn’t have to be scary or slow down customer onboarding. In fact, having an efficient and accurate risk assessment process upfront, with automated ongoing monitoring behind the scenes, ensures that your customers will be able to transact without interruption.


Jennifer Arnold, CEO and Co-Founder, MinervaAI. Chief Regulatory Nerd and financial crimes enthusiast.
Charlene Sebastian, Head of Client Success and Delivery Enablement, MinervaAI. Obsessed with Data and getting *&^% done.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Bank of Canada | Dec 7, 2021

The Retail Payments Advisory Committee (RPAC) met on October 18 and 20, 2021, to discuss elements of the registration process, record keeping, annual reporting and information requests. Participants were invited to comment on:
Documents
At its meeting on November 16 and 17, 2021, RPAC discussed a preliminary approach to registration and annual assessment fees. Participants were invited to comment on:
Documents
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Finconecta | Betty DeVita | Dec 3, 2021

The Open Banking model marks a global evolution (although some experts talk about a “revolution”) in the financial market. Motivated by the increased
need to respond to customer demands, compete with new financial players and meet regulation requirements, banks are adopting API-based business models. Open Banking emerges in the financial industry as a new model of collaboration with third-party providers. By working in partnership with fintech banks, they are able to expand customer reach, accelerate the adoption of new technologies, and create new revenue streams. The underlying mindset is the realization that complex problems that demand immediate resolution, need a strategy that taps into “the wisdom of the many”, rather than siloed proprietary solutions.
While, in some countries like the US and China, Open Banking is spreading only by market forces, in other geographies the regulatory agenda is playing a central role. In Europe, some Asian and Latin American regulators, often driven by financial inclusion mandates, are promoting the shift to open ecosystems by launching directives like the well-known PSD2 in Europe and the Open Banking Standard in the UK.
Taking into account these regulatory successful practices, the government of Canada appointed an Advisory Committee (AC) in 2018 for the design and implementation of the Open Banking framework. As a first phase, the AC started with consultations with stakeholders across Canada. Based on its findings, in spring 2020 the committee started the second phase, providing advice on potential solutions and standards focusing on data.
Bringing together the government and the private industry, Canada is aiming to embrace a hybrid, made-in-Canada strategy. The scope is ambitious as all federally regulated banks will be required to participate while others regulated banks could join on a voluntary basis. Despite some delays due to the pandemic, the AC plans to have the Open Banking regime operational by January 2023.
Live Date January 2023

While the regulation is cautiously but steadily progressing in Canada, leading banks are already partnering with FinTechs using APIs to deliver new digital products. Even later adopters are exploring new technologies as COVID-19 forced them to respond, adapt and innovate. As far as fintechs are concerned, they have gained attention by proving to be the solution to navigate the crisis.
According to Accenture, Fintech Report 2020, the Canadian FinTech industry is booming with 700 FinTechs and hundreds of nascent startups. Registering record levels of investment, venture capitalists remain optimistic despite COVID-19 uncertainty. The potential of the Canadian ecosystem is massive, especially when
considering the proactive approach taken by an efficient public sector. That explains the surge of many Canadian unicorns, like Clearco, a lending platform, Coveo an AI platform and Wealthsimple, an online investment manager, to name a few.
Going beyond the Open Banking model, the Canadian financial sector is also benefiting by innovative collaborative structures like Banking-as-a-Service and Embedded Finance. As an example we have Hopper, the travel mobile-only app that uses predictive analytics to make travel recommendations. This Canadian unicorn, recently awarded as the Best Travel App, provides information about best deals on flight and hotels, sends push notifications to their users when best prices are available, suggests new destinations based on your search and most importantly allows the payment for all travel services through one single interface.
Open Banking can and should be a journey towards digital innovation. As FinConecta’s Chief Business Officer Betty deVita remarks: “Infrastructure is sexy” (and now it is trendy!) . There has never been a better time for enabling new business models. In March 2021 Amazon Web Services (AWS) and FinConecta launched Open Finance, a leading-edge platform based on FinConecta’s technology, that expands the boundaries of Open Banking to the next level”, deVita adds. “And now we landed in Canada, as the engine behind tunl., an API platform that brings together Financial Institutions and Fintechs” (To learn more about Ficanex and FinConecta’s joint launch of tunl 2.0) Banking-as-Service goes beyond the data sharing contemplated in Open Banking, including products that are embedded into the financial institution's own core, such as infrastructure, data and banking licenses on a white-labeled basis.
The future is open and Canada is ramping up. We anticipate dramatic changes in 2021 pushed by the FinTech sector growth and the regulatory framework. If financial institutions were contemplating digital transformation as a “nice to have”, now is a must-have shift.
Bottom line is, great things are to come in Canada. A flurry of fintech activity is gaining traction, bolstering the ecosystem.This API economy opens new horizons for all types of institutions, by enabling collaboration and the co-creation of new solutions leveraging what others have available, in a robust, interconnected and integrated roadmap.
As the old adage says: “If it’s not here, where; if it's not me, who; if it’s not now, when.”
Betty DeVita, CBO, FinConecta
Betty is a global digital transformation executive with expertise in consumer financial services/payments. Her focus is on early-stage and emerging companies driving value creation, partnerships and the path to global scaling. She most recently served as Chief Commercial Officer of Digital Payments & Labs at MasterCard. She also served as President at MasterCard Canada. Prior to that she was with Citi in Latam, the US and Asia in their consumer franchise and left Citi as Chair/CEO for Citibank Canada Inc.Betty sits on the board of Molson Coors Brewing Company (NYSE: TAP), where she sits on the audit committee. She holds a Bachelor of Science from St John’s University, a CEO Certificate from the WhartonKMA in South Korea and is a certified director from the Institute of Corporate Directors, University of Toronto
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Yahoo | | Dec 1, 2021
UK equity crowdfunding business Seedrs - who’s merger with rival Crowdcube was earlier blocked by competition regulators - has been acquired by start-up investing platform Republic in a $100m deal.The move comes after Seedrs criticised the the UK’s Competition and Markets Authority earlier this year as stifling the UK’s potential to boost startups.
Seedrs was the first ever regulated equity crowdfunding business in the world and has pushed £1.5bn of investment through the platform during its history, even acting as retail investment platform for digital bank Revolut, now a unicorn. The platform was also the first to introduce a secondary marketplace.
Republic is a leading US fintech company that allows people to invest in private market equity, debt or crypto offerings and has almost one ($1) billion dollars under management through its private asset management practice.
Prior to this deal, Republic and Seedrs had a longstanding partnership where Seedrs advised Republic’s leadership team.
The acquisition of Seedrs follows Republic's recent $150M Series B financing announcement, led by Valor Equity Partners.
Seedrs Cofounder and now chairman Jeff Lynn will continue in his role at Seedrs, and will shepherd Republic’s European expansion, which will now be in a position to take advantage of new EU legislation that has harmonised crowdfunding rules in the bloc.
Speaking to the FT, Lynn said
the new rules “created a true European harmonised regulatory regime, where none existed before,” adding that “the regulatory fragmentation has made it nearly impossible to build platforms of scale — this [reform] gives platforms access to 27 different countries, all under a single regulatory regime.”
US investment firm Davidson Kempner will buy now take the stakes previously owned Seedrs shareholders, mostly for cash. Seedrs also has almost 5,000 smaller investors, including tennis player Andy Murray.
Republic said it will commit additional capital toward expanding Seedrs in Europe “to help deliver new innovations and products for European investors and private businesses.”
Kendrick Nguyen, Republic’s founder, said:
“We knew international expansion was necessary to achieve cross-bordered participation. In working with Seedrs, we have admired their technological capabilities, the strength of their team and their strong presence in the UK and soon Europe. We anticipate further developing the strengths of both companies from retail, secondaries, crypto, and communities to create a clear industry leader.”
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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