Category Archives: Stories

Why Canada Is Making It Cheaper to Leave Your Bank

November 11, 2026 | NCFA Story Intelligence | Competition And Market Structure, Wealthtech Investing And Trading, Regulation And Policy

Digital illustration of Canada bank transfer fee reform showing easier investment account switching, lower fees, open banking, payment infrastructure and stronger financial competition

Canada is cutting bank fees and switching barriers after years of weak competition, high concentration and poor productivity.

On November 7, 2026, the federal government proposed something Canadian investors have complained about for years. Banks would no longer be allowed to charge most investment account transfer fees, which typically cost about $150 per account. Ottawa also wants clearer transfer information and tighter timelines for moving investments to another financial institution.

The fee matters because leaving can already be slow and frustrating. Receiving firms often reimburse the outgoing charge to win the account. That means a fee collected by the institution losing the customer can become part of the acquisition cost for the institution trying to win that customer.

Canada's six largest banks hold roughly 93% of banking assets. The Competition Bureau was warning about barriers facing fintech competitors in 2017. Ottawa began reviewing open banking in 2018. A federal advisory committee later recommended an operating system by January 2023 and warned that government should not delay.

January 2023 came and went.

Real Time Rail also slipped years beyond its first expected launch. Meanwhile, Canada's productivity performance kept falling behind major peers. In 2024, the Bank of Canada called the problem an emergency. By 2025, Senior Deputy Governor Carolyn Rogers was directly connecting productivity, competition and Canada's highly concentrated banking sector. She also said the debate had become more urgent after U.S. trade policy delivered a major economic shock to Canada.

Then more barriers started coming down.

Payment companies came under supervision. Payments Canada opened membership to more firms. Consumer driven banking advanced. NSF fees were capped. Real Time Rail finally launched. Budget 2026 targeted bank entry, ownership and regulatory competition. Now Ottawa wants to make investment accounts cheaper and faster to leave.

The $150 exit fee is the latest part of a much longer story about how difficult Canada has made it for customers to switch and for competitors to win them.

Canada Gets Comfortable With Concentration Before 2018

Canada's banking model earns trust for good reasons. Major institutions survive repeated economic shocks, deposits feel safe and regulators put stability first. For years, those strengths make concentration easier to accept.

But concentration changes what happens around the customer. When a small group of institutions holds most banking assets, controls large financial relationships and already has access to core infrastructure, the cost of entering or leaving matters more. A fee, a delayed transfer or restricted access can help keep a customer in place without giving that customer a better product.

How Concentrated Is Canadian Banking?

In October 2025, Bank of Canada Senior Deputy Governor Carolyn Rogers called Canada's banking system an oligopoly. The six largest banks collectively held about 93% of banking assets.

High concentration doesn't automatically mean poor service or weak banks. Stability and scale carry real value. The concern grows when concentration combines with barriers that make entry, growth or customer switching harder.

Rogers' warning was blunt: limited competition can hold back productivity and innovation.

Canada had already been debating these barriers for years. In 2017, the Competition Bureau called for stronger competition and innovation in financial services. NCFA agreed that regulatory burdens could favour large incumbents and pointed to the UK's more aggressive support for fintech and new competitors.

Customers faced their own friction. Bundled products, recurring payments, transfer charges, branch relationships and the hassle of changing providers all made staying easier than leaving. In a concentrated market, those small frictions can add up to a powerful advantage.

Canada Knows And Still Waits 2018 to 2024

The warnings keep piling up, but change comes slowly. Ottawa starts reviewing open banking in 2018. By 2021, its advisory committee recommends an operating system by January 2023 and says "Government should not delay."

January 2023 passes without one. Real Time Rail also slips years beyond its expected launch. By then, Canada isn't waiting to discover whether customers and new competitors face barriers. It is waiting to remove barriers that have already been identified.

How Long Did Canada Know?

The fight for consumer control of financial data was already well underway during Canada's open banking debate.

Real Time Rail followed another long wait. Payments Canada delayed the system again in 2023 without providing a new launch date.

The delays weren't limited to payments. Parliament approved broader fintech investment powers in 2018, but the operating rules did not reach Canada Gazette Part I until October 2026. That eight year wait for fintech investment reform became another example of how slowly financial modernization could reach the finish line.

Ottawa launched the open banking review in 2018 while Canadians were already connecting outside apps to bank accounts through screen scraping. Privacy, security, liability and technical standards required real work, but the January 2023 target still passed without an operating system.

Interac was selected as the RTR exchange provider in 2021 when launch was expected in 2022. The rail did not reach production until November 2026, leaving Canadian firms to build around older settlement infrastructure for several more years.

The Cost Of Waiting Gets Higher 2024 to 2026

Canada's weak productivity stops looking like a problem that can be pushed down the road. The country has struggled for roughly 25 years. In 2024, the Bank of Canada calls it an emergency. By 2025, it estimates that matching G7 productivity growth since 2000 would have left Canadian GDP about 9% higher, worth almost $7,000 more per person.

Then the pressure starts coming from outside too. Carolyn Rogers says the productivity debate becomes more urgent after new U.S. trade policies deliver a major shock to Canada. A country already struggling with investment, scale and weak competitive pressure now has less room to make firms fight through unnecessary domestic barriers as well.

Why Productivity Changes The Competition Debate

Canada's productivity weakness has been building for decades. Bank of Canada data showed Canadian output per hour falling from about 88% of the U.S. level in 1984 to roughly 71% by 2022.

Stronger competition puts pressure on companies to improve products, cut costs and invest. That connection became harder to ignore as Canada's productivity gap widened.

The country was already trying to break a long productivity trap before the Bank of Canada later warned that Canada had reached a productivity crossroads.

Trade Pressure Raises The Cost Of Slow Reform

U.S. trade pressure didn't cause every financial reform that followed. The timing still matters because the economic environment became less forgiving.

Tariffs made Canada's dependence on the U.S. harder to ignore as the trade fight intensified. Canadian fintechs faced the same pressure to find growth beyond the U.S. market.

Rogers tied the issues together in October 2025 when she said the productivity debate had become more urgent after U.S. trade policies created a major shock for Canada.

In March 2024, Bank of Canada Senior Deputy Governor Carolyn Rogers said Canada's productivity problem had reached emergency status. Canada was producing far less output per hour than the United States and had lost relative ground against major peers over several decades.

By October 2025, Rogers was talking directly about competition. She pointed to Canada's concentrated banking market, said stronger competitive pressure can improve productivity and warned that new U.S. trade policies had made the need to perform better at home more urgent.

Ottawa Starts Removing The Barriers 2025 to 2026

Then more changes arrive in a short period. Payment companies come under supervision. Payments Canada opens membership. Consumer driven banking advances. NSF fees fall. Real Time Rail finally goes live. Budget 2026 targets bank entry, ownership and competition inside financial regulation.

The changes come through different laws and regulators, but they keep hitting the same pressure points: who gets in, who gets access, what customers pay, how quickly money travels and how easily a customer can choose someone else.

Bank of Canada supervision of payment service providers began on September 8, 2025. Expanded Payments Canada eligibility followed later that month. By October 2026, 22 new members had joined after access opened, including fintechs, payment companies and credit unions that couldn't qualify under the old rules.

Consumer driven banking advanced through 2026 while new open banking rules started turning accreditation, consent, security and data access into practical requirements. On November 9, Real Time Rail went live after years of delay.

Federal rules cut NSF fees to a maximum of $10 on March 12, 2026. Typical charges had been about $45 to $48. The rules also block repeat NSF charges within two business days on the same personal deposit account and prohibit the fee when the shortfall is under $10.

By November, Budget 2026 widened the competition push with proposals covering faster bank entry, a secondary competition objective for OSFI, ownership rules, credit union funding and customer switching.

The Exit Fee Becomes A Competition Cost November 2026

The November transfer proposal brings everything back to one customer trying to leave. The incumbent charges the outgoing fee. The receiving institution may reimburse that customer to win the account. In those transfers, the firm trying to win the customer absorbs a cost created by the institution losing the relationship.

Finance Canada's regulatory model assumes that 90% of covered transfers run from established financial institutions to firms it classifies as entrants. It also assumes receiving institutions reimburse about half of transfer fees, which raises the cost of winning customers away from incumbents.

What The November Transfer Proposal Actually Changes

The proposed rules would prohibit most bank charges for closing or transferring investment accounts. An exception would remain for accounts funded for fewer than 90 days. Legitimate redemption or sale charges that would exist without a transfer could still apply.

The typical transfer fee is about $150 per account. Registered account transfers commonly take 2 to 6 weeks. Some can exceed 25 business days, while certain GIC transfers can take 6 to 8 weeks.

Delivering banks would generally have two clearing days to provide required asset and cash information. CIRO is separately developing rules that target settlement within 10 clearing days once impediments have been resolved and final instructions are available.

Finance Canada estimates banks would forgo about $16.3 million in net transfer fee revenue over 10 years. Firms it classifies as entrants are estimated to save about $7.7 million in reimbursements, while consumers would save about $8.6 million.

The regulations remain proposed. The fee prohibition would start 60 days after final regulations are registered, while other disclosure and timing rules would come later.

Finance Canada estimates about 17,000 transfers would be covered in the first year of its model. It assumes no increase in transfer volumes because there isn't enough evidence yet to know how customers or institutions will respond once the barrier is removed.

Banks could also respond by improving offers to keep customers. Easier switching doesn't require everyone to leave to create pressure. The possibility of leaving more easily can give the customer more leverage before the account ever goes anywhere.

Keeping The Customer Has To Be Earned Now

None of these reforms guarantees that a challenger wins. A large bank can still keep customers through trusted advice, better service, stronger products, competitive pricing, useful bundles and the convenience of a broad relationship.

What changes is how much of that relationship can be protected by friction. More firms can enter. More firms can reach infrastructure. Financial data is becoming easier to share. Payments settle faster. Some fees are lower. Leaving is becoming cheaper. More of the contest can come down to who serves the customer better.

Canada's Recent Financial Competition Reset

The recent changes reach almost every part of the customer relationship. Some open the system to more competitors. Others lower fees, make switching easier or give customers more control over their money and data.

  • Payment companies entered formal supervision. Bank of Canada oversight under the RPAA began in September 2025, giving regulated PSPs a clearer place inside Canada's payment system.
  • Payments Canada membership opened. Federal reform made more PSPs, credit unions and other qualifying firms eligible to join. Twenty two new members joined in the first year.
  • Consumer driven banking advanced. Canada's open banking rules are turning data access, consent, security and accreditation into operating requirements.
  • NSF fees fell to a maximum of $10. The March 2026 cap cut a charge that had commonly been about $45 to $48 and added restrictions on repeat fees.
  • Real Time Rail finally launched. After years of delay, RTR went live on November 9, bringing 24/7 clearing and settlement to participating institutions.
  • Fintech investment powers are finally being activated. Parliament approved broader technology investment powers in 2018, but operating rules took another eight years to arrive. The long wait for fintech investment reform shows how slowly even approved changes can reach the market.
  • Bank entry could get faster. Budget 2026 proposes a maximum one year decision timeline for new banks, trust companies and insurers.
  • OSFI could get a competition objective. The same Budget 2026 package proposes adding competition as a secondary statutory objective alongside prudential stability.
  • Growing banks could face fewer ownership limits. Ottawa proposes raising the bank equity threshold that triggers widely held ownership requirements from $12 billion to $25 billion and giving some foreign bank subsidiaries more flexibility.
  • Federal credit unions could get more room to raise capital. Proposed changes would widen who can invest and make growth easier.
  • Deposit insurance could rise to $250,000. A higher limit could make it easier for customers and businesses to keep larger deposits with smaller federally insured institutions.
  • Bank fees could become easier to see. Budget 2026 proposes an annual statement showing total chequing and savings account fees after FCAC found that banking costs can be difficult to see and compare.
  • Branch closures could make switching cheaper. Budget 2026 proposes waiving certain closing or transfer fees during prescribed branch closure periods.
  • Mortgage competition is also getting attention. Budget 2026 proposes stronger rate disclosure and other measures aimed at giving borrowers more choice.
  • Investment account exit fees are now directly in Ottawa's sights. The November 7 proposal would prohibit most bank transfer fees, improve disclosure and put clearer timelines around account transfers.

Canada is now changing who can enter, who can reach payment infrastructure, who can use customer data, what institutions can charge, how quickly money can travel and how easily a customer can leave.

For years, these problems could be treated as separate files. Open banking sat in one department. Payments modernization sat somewhere else. Banking fees were a consumer issue. Productivity was an economic problem. Competition had its own consultations.

They are harder to separate now.

Canada needs firms to invest faster, grow further and compete in a tougher economy. A financial system that makes entry, customer acquisition and switching more expensive than they need to be works against that goal.

The country knew about many of these barriers years ago. What has changed is how many of them are finally coming down at the same time.

Talking Point

Canada's recent competition reforms aren't about handing fintechs or challenger banks an advantage. They're about removing advantages that can protect an incumbent relationship before price, service, product quality or trust gets a chance to decide who wins the customer.

The results should become visible. Transfers should get faster if the rules work. Receiving firms should spend less reimbursing exit fees. New payment participants should be able to offer services they couldn't offer before. Incumbents may respond with better prices, products and service.

The bigger question is whether all of that produces the competitive pressure Canada has been missing.

What Happens Next?

  • Will the investment transfer proposal survive consultation without major changes?
  • Will account transfers become measurably faster once the timing rules take effect?
  • Will receiving institutions spend less reimbursing outgoing transfer fees?
  • Will consumer driven banking lead to more switching, not just easier comparison?
  • Will new Payments Canada members turn access into lower costs, better products or new services?
  • Will RTR adoption spread beyond the first launch participants?
  • Will the proposed OSFI competition objective and one year entry timeline bring more viable financial institutions into the market?
  • Will incumbents respond to easier switching with better prices, products and service?

What Did You Think?

Canada knew about many of these competition and productivity problems years ago. Why did it take this long for so many financial barriers to come under pressure at once?

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NCFA Canada logoThe 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, artificial intelligence, 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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How Wall Street Is Building Tokenized Stock Markets

November 9, 2026 | Story Intelligence | Capital Markets Infrastructure And Funding, Digital Assets Blockchain And Tokenization

AI illustration of Wall Street tokenized stock markets showing regulated trading, ownership, settlement, DTC tokenization, issuer sponsored shares and blockchain routes

How Blockchain Trading Is Meeting Regulated Ownership, Liquidity And Settlement

On November 9, 2026, Ava Labs announced Avalanche as the core clearing ledger for NYSE's planned tokenized securities venue.

NYSE isn't putting its stock exchange on Avalanche.

NYSE Pillar remains the planned trading engine. Regulated transfer agents will connect digital shares with shareholder records. Avalanche will sit inside the clearing process after a trade is matched. Stablecoin funding is part of the design.

Blockchain companies have spent years building ways to issue, trade and settle assets directly on digital networks.

Wall Street already has a system that performs those jobs at enormous scale.

Now the two have to connect.

Blockchain can make securities programmable and allow the asset and cash to settle together. Public markets depend on deep liquidity, clear ownership records, custody, corporate actions and regulated firms that remain accountable when something goes wrong.

The question isn't whether stocks can be tokenized anymore.

It's whether tokenized stocks can gain the speed and flexibility of blockchain without splitting ownership, liquidity and investor protection across too many systems.

Canada put a real security through this process in March 2026. Export Development Canada issued a C$100 million bond through Project Samara, with RBC Capital Markets and TD Securities as joint lead managers.

The system supported issuance, bidding, secondary trading, coupon payments and redemption. The security and wholesale central bank money could settle together on distributed ledger technology.

The Bank of Canada also found costs around the transaction. These included system complexity, liquidity costs, governance requirements, coordination work and additional reporting and oversight.

Samara involved one short term security and a closed investor group. A public stock market has to handle the same issues across many securities, firms and investors.

A Faster Trade Still Needs A Market March 2026

Project Samara showed that a regulated security and regulated money can settle together on a distributed ledger.

But faster settlement only helps if buyers, sellers, custodians and other market participants can work around it without creating new costs or delays.

One trade can be compressed. The rest of the market still has to function around it.

What Canada Actually Tested

The Bank of Canada described Project Samara as a real world experiment using a C$100 million EDC bond, wholesale central bank money and a purpose built distributed ledger platform.

The platform connected securities and cash ledgers and supported atomic settlement, secondary trading and the bond's life cycle.

The Bank reported potential efficiency and data benefits alongside complexity, liquidity costs and governance demands.

On September 17, the SEC opened a five year path for tokenized U.S. stock trading, allowing qualifying Tokenized Securities Venues to use permissioned automated market makers and liquidity pools.

The tokenized stock must provide holders the same rights and privileges as the equivalent conventional shares.

An unaffiliated company can't simply tokenize another issuer's shares and assume the result is equivalent. The venue must notify the issuer before trading begins and give it 30 calendar days to object.

The rules around which U.S. stocks can qualify for tokenized trading also limit eligible securities, trading volumes and the circumstances in which an issuer can object.

A Token Isn't Always The Share September 17, 2026

A token can trade onchain and still leave an important question unanswered: what does the investor legally own?

It may be the company's share. It may be a claim backed by shares held somewhere else. It may only track the price.

The technology can make the asset easier to transfer. It doesn't decide the investor's legal rights.

Not Every Tokenized Stock Is The Same Stock

SEC staff separates tokenized securities into different structures.

Issuer sponsored securities can use a blockchain as part or all of the official shareholder record. Third party custodial products can represent an interest in shares held elsewhere. Synthetic products can track a stock without giving the holder ownership of the company.

Those products may look similar in a wallet. Their legal rights can be very different.

DTC answered from inside the existing market on October 28. Its Tokenization Service allows eligible participants to create tokenized representations of securities already held at DTC and deliver them to registered wallets.

DTC has more than $114 trillion in assets under custody. Twenty participants had signed agreements when the service launched, including Bank of America, Barclays, Citi, Fidelity, J.P. Morgan, Morgan Stanley, State Street and UBS.

The securities don't have to leave DTC for participants to use a tokenized version. Canton and DTCC's private Besu network were the first supported networks, with more expected to follow.

The existing depository remains connected to the asset while blockchain adds another way to hold and transfer it.

DTC Brings The Existing Market Onchain October 28, 2026

DTC takes a different route from building a new market beside the old one.

It adds tokenization to securities already inside the existing system.

That keeps common custody and established market connections in place. It also means new blockchain markets have to offer more than a digital version of the same asset.

Why DTC's Model Is Different

DTCC says tokenized positions retain the rights, investor protections and economic entitlements of their traditional counterparts.

The service was developed with input from more than 150 firms. More than 30 firms also participated in limited production transactions before launch.

The model connects blockchain networks to a common regulated depository rather than creating a separate ownership system for each network.

On November 2, NYSE named Securitize, tZERO, Broadridge, Computershare, Equiniti and Superstate as transfer agent partners for tokenized securities.

Computershare, Equiniti and Broadridge together serve close to 5,000 publicly listed companies, including nearly 99% of the S&P 500.

The group combines digital asset firms with established shareholder recordkeepers. Securitize, Superstate and tZERO bring onchain issuance and recordkeeping experience. Computershare and Equiniti bring long standing issuer relationships.

Broadridge also connects shareholders with proxy materials, meetings and voting.

Someone Still Has To Know Who Owns It November 2, 2026

A stock doesn't stop working after someone buys it.

Companies pay dividends. Investors vote. Shares split. Mergers close. Ownership changes.

The transfer agent role in NYSE's tokenized share model connects those obligations with the new digital ownership layer.

The share can live onchain. Someone still has to maintain the record everyone agrees is official.

Why The Shareholder Record Matters

Under the SEC's issuer sponsored model, an issuer or transfer agent can use a blockchain as part or all of the official shareholder record.

That changes how ownership is recorded, but it doesn't remove responsibility for transfer controls, corporate actions and determining who legally owns the security.

On November 4, Canton Strategic Holdings put the SEC exemption into a live transaction. Existing shareholder Five North moved CNTN shares from a broker account onto the company's onchain shareholder register.

The shares traded through a permissioned Tradecraft liquidity pool. DRW Cumberland bought stock, Flowdesk supplied liquidity and settlement completed atomically on Canton.

Fairmint remained the SEC registered transfer agent. It recorded the tokenized shares, maintained the official onchain ownership record and controlled which verified holders and wallets could participate.

Identity checks, sanctions screening and transfer controls remained part of the transaction.

The First Live Trade Connects Both Worlds November 4, 2026

The November 4 transaction wasn't another demonstration.

A Nasdaq listed stock traded through an onchain liquidity pool and settled atomically, while a regulated transfer agent kept the official ownership record.

Fairmint CEO Joris Delanoue put it plainly: "A blockchain can settle a trade, but it takes an accountable transfer agent to say who legally owns the share."

Blockchain handled parts of the transaction differently. Regulation didn't disappear. It came into the transaction with it.

What The Canton Trade Connected

Five North began as an existing CNTN shareholder. Fairmint registered the shares in tokenized form and placed the position on the company's onchain shareholder register.

Tradecraft provided the market. Flowdesk supplied liquidity. DRW Cumberland bought the shares. Canton handled atomic settlement.

NYSE keeps conventional exchange technology at the front of its planned digital ATS. NYSE Pillar remains the matching engine, using technology already familiar across NYSE equity and options markets.

The venue can support issuer sponsored tokenized securities as well as qualifying third party custodial products.

Avalanche gets a different job after execution. Its technology will provide the core ledger for the clearing firm supporting the venue.

NYSE says the platform is designed for 24/7 trading, clearing and settlement. Stablecoin funding is contemplated, while regulated transfer agents connect tokenized securities with shareholder records.

NYSE Keeps The Exchange And Adds Blockchain November 9, 2026

NYSE isn't replacing everything at once.

Pillar can match the trade. Transfer agents can keep the ownership record. Avalanche can support clearing. Stablecoins can provide digital cash.

NYSE Head of Digital Issuance Dennis Lee describes the approach as "picking the right technology for each job."

The NYSE Avalanche clearing design gives Avalanche a post trade role rather than making it the only network on which shares can exist.

The result could combine familiar market access with faster digital settlement. It could also leave one stock working across more systems than before.

What Avalanche Does And Does Not Do

Avalanche is providing core ledger technology to the clearing firm supporting NYSE's planned digital ATS. NYSE has not publicly identified that clearing firm.

Avalanche is not replacing NYSE Pillar, the transfer agents or the brokers connecting investors to the venue.

The proposed venue remains subject to regulatory approval.

DTC can tokenize securities already inside the depository. Conventional exchanges can continue using familiar order books and settlement rules while adding tokenized representations after the trade.

This keeps the security tied closely to existing market systems.

Other venues can put more of the process onchain. Ownership, trading and settlement can run through digital networks with verified wallets and programmable controls.

Securitize's tokenized U.S. stocks and OKXICE's proposed venue show how different regulated models are moving from exemptions and filings into actual products and market designs.

One Stock Can Now Exist In Several Places Late 2026

A public company's stock can remain inside DTC, appear in issuer sponsored form onchain and also be represented through third party products.

Those versions can trade through different venues and settle through different systems.

That creates more choice, but liquidity can spread across markets and investors may not receive the same rights from every product carrying the same company name.

Tokenization works best if those routes remain connected closely enough that the stock still behaves like one market.

Where The Markets Can Separate

Buyers and sellers can split across venues. Ownership can be recorded differently. Settlement timing can vary. Custody can sit with different firms.

Dividends, shareholder votes and other corporate actions still have to reach every legitimate holder.

Third party tokenized products can also give investors different rights from issuer sponsored shares.

Can One Stock Still Trade As One Market?

Tokenized stocks can now reach investors through several routes.

AI illustration showing how one public stock can reach investors through multiple regulated routes, including the existing market, DTC tokenized route, issuer sponsored onchain route, NYSE hybrid route and third party token route, with differences in ownership records, trading venues, settlement paths and investor rights.

DTC can tokenize securities already held in the traditional market. The SEC has opened a regulated route for permissioned onchain stock trading. Transfer agents can maintain official shareholder records on blockchain networks. A Nasdaq listed stock has already traded and settled this way. NYSE is combining its existing trading technology with blockchain clearing and potentially tokenized cash.

Each approach solves part of the problem.

Together they create another one.

A public stock is valuable partly because buyers and sellers can meet in deep markets and because everyone knows what the security represents. If liquidity spreads across too many venues or different tokenized versions carry different rights, the investor may see the same company name without actually holding the same product.

That doesn't mean tokenized stocks need one blockchain or one trading venue.

It means the different routes have to remain connected closely enough that investors, issuers and intermediaries can treat them as parts of the same market.

For founders, some of the best opportunities may sit in those connections: custody, compliance, identity, shareholder records, corporate actions, market data, liquidity and settlement.

For investors, the basic questions become more important, not less. Who issued the token? What does it represent? Where is ownership recorded? Where does it trade? Who holds the underlying security? What rights come with it?

Canada has already tested part of this problem through Project Samara. Canadian institutions showed that a real security and central bank money can settle together on distributed ledger technology. They also found that faster settlement brings governance, liquidity and operating questions with it.

If U.S. tokenized stocks build meaningful liquidity, Canadian dealers and custodians will have to decide which products and venues they can connect to and how those holdings fit Canadian custody, securities and investor protection requirements.

Blockchain markets don't have to replace regulated public markets to matter. Regulated markets don't have to abandon their existing systems to use blockchain.

A stock can gain new ways to trade and settle without losing the liquidity, ownership clarity and investor rights that make it one market.

Talking Point

Tokenized stocks can now trade through several regulated routes. The opportunity is faster, more programmable markets. The risk is that liquidity, ownership and investor rights become spread across products and venues that all appear to represent the same stock.

What Happens Next?
  • Can tokenized versions of the same public stock share liquidity across conventional and blockchain venues?
  • Will issuer sponsored onchain ownership grow beyond early transactions?
  • How will shareholder records and corporate actions remain accurate when securities operate across several systems?
  • Will NYSE's model preserve existing liquidity while adding faster blockchain settlement?
  • Which third party tokenized products will issuers support or reject?
  • How will Canadian dealers and custodians connect if U.S. tokenized stock markets gain meaningful activity?
What Did You Think?

If the same public stock can trade through several regulated systems, how different can those systems become before investors are no longer trading the same market?

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NCFA Canada logoThe 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, artificial intelligence, 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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EP67: Can AI Replace Debt Collectors?

About NCFA Canada | Craig Asano | November 6, 2026

Fintech Fridays S4EP67 Chris Maranis, Deputy CEO EXUS_1000

Featured Guest: CHRIS MARANIS, Deputy CEO, EXUS (LinkedIn)

Chris Maranis is Deputy CEO at EXUS and a long-standing leader in the global debt collection technology space. Since joining EXUS in 2004, he has worked with financial institutions across more than 30 countries, helping them transform collections operations across the full lifecycle from pre-collection to recoveries. His experience spans diverse markets and operating models, including in-house teams, outsourced networks, and highly regulated environments, with a strong focus on improving performance while strengthening customer relationships. Today, he helps shape EXUS’ strategic direction by connecting market needs with product vision, commercial growth, and operating execution. His current mandate combines internal leadership with a strong external market role, working closely with customers, partners, and industry stakeholders to advance a more intelligent, ethical, and customer-centric approach to collections. Drawing on two decades of international experience, he now focuses on how AI data-driven decisioning and modern engagement strategies can help organizations build future-ready collections models that deliver better outcomes for both lenders and customers.

About EXUS

EXUS is a global technology company specialising in debt collection and credit risk software. Founded in 1989, its EXUS Financial Suite (EFS) platform is trusted in more than 50 countries. EXUS brings together configurable collections strategies, analytics, decision intelligence, digital self-service and recovery workflows to help organisations improve collections performance and support customers throughout the debt lifecycle.

Links

Contact

General enquiries: m.legat@exus.co.uk

Headquarters: 4 Felstead Gardens, Cubitt Town, London E14 3BS, UK.

 

About this episode

EP67: Can AI Replace Debt Collectors?

What happens when AI starts collecting debt? Could a machine make better decisions than a human, and would you trust it with your financial future? In Episode 67 of NCFA Fintech Fridays, host Craig Asano sits down with Chris Maranis, Deputy CEO of EXUS, a global leader in debt collection and credit risk software, to explore how AI is changing the way banks recover debt, engage with customers and manage financial hardship. With over 20 years of international experience, Chris explains what's actually changing in debt collection as banks introduce predictive analytics, generative AI and autonomous agents. From AI negotiating repayments to detecting customers in financial difficulty, there's plenty happening already. But where should banks draw the line between automation and human judgment? Through practical scenarios, Chris tackles some tough questions about AI, fairness and accountability. He also shares EXUS's expansion into Canada, its work with a major Canadian bank and what's coming next from the company's AI innovation team. It's a fascinating look at how far AI can go in banking, what lenders are willing to automate, and why the toughest decisions may be the ones they can't hand over to a machine. Tune in!

Duration:  66 mins

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Fintech Friday Transcript of Episode 67:

CHRIS MARANIS, Deputy CEO, EXUS (LinkedIn)

Intro: Welcome to fintech Friday's a weekly podcast brought to you by the National Crowdfunding and Fintech Association of Canada and partners. Covering all things fintech, blockchain, AI and alternative finance.

[00:00:29] Craig Asano: Hello, everyone. Craig Asano here, the founder and CEO of NCFA Canada, welcoming you to season four, episode 67. Cannot believe we're already at episode 67 of Fintech Fridays. It's a weekly podcast brought to you by NCFA and partners where we feature conversations with leading voices across fintech, funding, and financial innovation around the globe. We talk with founders about their journeys, executives, companies. We talk about emerging trends, financial innovation, and what those experts are seeing in the market right now. So today we have another fantastic guest with us today. I'd like to introduce Chris Maranis. He's the deputy CEO at EXUS, a long-standing leader in the global debt collection tech space. Since joining EXUS in 2004, he's worked with financial institutions across more than 30 countries, helping to modernize collections, operations, all the way from pre-collection, pre-collection to recoveries. As part of EXUS' executive leadership team, Chris helped shape the company's strategic direction by connecting market needs with product vision, commercial growth, and operating execution.

[00:01:40] Craig Asano: He also works closely with customers, partners, stakeholders on bringing about more intelligent, ethical, and customer-centric approaches to collections. Drawing on more than two decades of international experience, his current focus includes AI, data-driven decisioning, and modern engagement strategies that can improve outcomes for both lenders and customers. Chris, thanks so much for joining the podcast today to share your experience and knowledge.

[00:02:05] Chris Maranis: Welcome to the show. Thank you very much, Craig. I'm very happy and excited to be with you here today. Well,

[00:02:10] Craig Asano: I think we're just gonna kick off with an opening question. I mean, you've spent over 20 years according to your bio, at EXUS working with lenders all around the world. What first drew you into the business, and what has kept you interested for so long? Yeah. That, takes me back, but to be honest from the start, it was not collections back then.

[00:02:32] Chris Maranis: So in 2004, I joined EXUS, the company I still work for. I, I think I just wanted to join a company which since then had a reputation that takes extra good care of its people, and it was growing fast. So that was my aim. And collections was, let's say, a side effect, an accident. So I joined EXUS, and I was assigned as my first assignment to be the project manager for the implementation of the debt collection solutions for a thriving bank back in Greece at that day. And I have to say that what, what really made me... And I think if I look think what has made me stay after, you know, 22 years in collections is that in contrast to what people think, people who are not in collections, collections touches people at a difficult point in their lives. And I saw the struggle a lot of collections teams were going through to, on the same time, achieve their business outcomes but help people in distress get out of it. And it was a shock for me. It, it wasn't what I was expecting collections is like. You know, when you're outside collections, you have this caricature of a collector in your mind, someone who is just, you know, making phone calls and pressing on people to pay.

[00:03:44] Chris Maranis: It's a completely different game. And when I got into it, I saw it's, it's challenging, it's complicated, it needs a lot of skills, and it does involve a lot of wonderful people who I still enjoy working with. So that's the thing that what has kept me all these years. Also, the fact that EXUS, the company I work for, is some kind of unique in, in the way that has a culture of constant change or growth. In these 22 years, I have, I have changed multiple times my role as a person. I have grown, and that's something that I think has kept me all

[00:04:18] Craig Asano: this time. Never had a boring day, Well, it's a remarkable journey since 2004, going from you know, project management really with, with the product on the operational side all the way to a deputy CEO, so congrats to, to that journey. You know, take us back a little bit to the time that you joined EXUS so we could get a sense for what collections were like back then and what EXUS as a company was like. We're gonna sort of provide some background because listeners might not really

[00:04:49] Chris Maranis: know much about Indeed. So back in 2004, collections was quite different than what it was today. To be honest most lenders, most organizations were considering collections as a back office operation. Even worse it was considered by some organizations as let's say, a place where you can exile your bad customers. Far from truth, of course, but that's how it was treated back then. And sometimes collection departments were located in some obscure locations or offices, so people would not know what was happening inside. Operationally collections was mostly a team of people in a call center handling large calling lists and a dialer and making, just trying to maximize the number of calls they make each day. There was some queuing, some filtering or prioritization, but very basic. And technology-wise since, you know, we are technology company the number one system I think that was used was the almighty Excel. Probably the best debt collection system of all times.

[00:05:59] Chris Maranis: Big organizations, huge organizations were... have had, you know, had tens of Excels and a lot of emails around no system a big high, a high turnover in the call center, so not an ideal situation. Back then in 2004 EXUS had already introduced its first version of the collection system, the ancestor of the system we currently have, and I remember the name was eCollect back then, and it kind of was rather, let's say, advanced for, for that age. But, you know, comparing with to what we are doing right now, you know, the multi-channels, the artificial intelligence, all the thing we have now, it was, rather old, cumbersome, and not as intelligent for sure as systems are today. So yeah, going from Excel to, you know, the,

[00:06:53] Craig Asano: the first iteration of eCollection software, the platform that naturally has evolved more than once or twice, you're probably talking numerous of, of times to commit to production new, new code and updates. But, you know, you had said that EXUS is dealing with company... countries all around the world. During the... Since 2004, during that growth phase, I mean, what... You must have been one of the very first employees. How, how many, how large is EXUS today? Okay. EXUS is not a large company. EXUS is a company employing

[00:07:25] Chris Maranis: around 170 Okay worldwide. What we do and what we feel distinguishes is the hyper-focus we have decided to put on one skill. Actually, it was 20 years ago, we decided that to be the best in the world and do something, you need to specialize. So we, we take a hard look in what we were doing. EXUS was doing other stuff back then, other enterprise business applications, having also some major customers, including Vodafone and other enterprises. But that when we decided that we actually want to be the best in the world and do something, we had to select what that would be, and that should combine three things. One is something you are really good at, and we saw that we were already really good at collections. Our first system was really bringing results. Then something you are good at, something you love doing, and that would sound weird, and we... But all at EXUS, we all love collections. We are so into collections. We have really love what we are doing. And the third is something that makes economic sense or fuels your engine. And combining all that, we came up that we decided we want to be the best in the world in debt collection software.

[00:08:37] Chris Maranis: That's how we decided to actually stop other activities, even some profitable activities we had,

[00:08:44] Craig Asano: to focus on collections. And of course, since then and for these 20 years, there have been, you know, very big changes and many, know, turning points in history. Well, do you wanna touch on some of the maybe the business turning points as well as the technology turning points over... 20-plus years. A lot has changed, it sounds. 20 years, and actually,

[00:09:04] Chris Maranis: if thinking back of that, actually is a chronography of how the financial industry has changed these years. First of all, I remember 2006, more or less, we had our first implementation for a banking group, a group of companies implementing what we call a blueprint. A blueprint is, actually when you designed a, a master, let's say, implementation designed on the centralized level, and then you deploy in multiple entities of the group in different countries where you adjust, you configure it to adjust to the local regulation or cultural peculiarities. But in that sense you achieve through this blueprint approach economies of scale because they share a lot of stuff between them. And Also the transfer of know-how between different entities of the group, and you achieve what they call control autonomy. So that was our first installation for a banking group, setting the same collection system in seven or eight countries, Southeast Europe and North Africa. But I think what was the biggest change happened in the aftermath of the US subprime mortgage crisis and the Lehman bankruptcy back in 2008.

[00:10:15] Chris Maranis: You know, the crisis reached Europe after that, and then it also hit Greece when we were... back where we were located between 2011 and '13, and we experienced an unprecedented crisis. The GDP fell by 25%, unemployment rose to almost 30%. That was a natural stuff happening. Collection managers, the collection managers I was working with at that day, they almost overnight witnessed their NPL rate, the non-performing loans rates, going from something like 3% or 4% or 5%, which is, you know, an industry average, to 30% or 40%. Wow. Lending just froze, and in this environment, in this unprecedented conditions, together with some collection managers back then, we implemented the first collection self-service portal. This is what we practically say these last years as digital. This is the digital channels. It was back then in 2013, having to support this environment which we, we had never met before, we implementing, along with our customers, self-service portal to help customers in distress to find a solution out of the distress and the problem they were at.

[00:11:32] Chris Maranis: So that was a big change and a big experience for all of us this crisis. Then I think one of, one of another important milestone was a thousand... 2016. It was when the first report by an individual technology analyst, it was CEB Tower Group, North US company. They were then acquired by Gartner. They created the first report, independent report analyzing debt collection systems. Until then, and until recently, there was no technology report, there was no magic quadrant, no report from Gartner or anyone else about collection systems. It was the first in 2016, and we were included. It was a global report, so it was covering the whole world. And EXUS and another I think it was 14 companies in total, were included as the top system in this report. And more amazingly, we were already thrilled we were part of this report. We were still, you know, small and growing back then. But when the report actually came into the market, we were ranked as the top debt collections software vendor in the world with all the big guys there participating, which was for us, you know, a big surprise and I think a turning point for us, made, you know, a proof of concept that we can really working...

[00:12:53] Chris Maranis: we were really working on the path towards becoming the best debt collection software vendor in the world. So think that was another important milestone. Other than that, I can think our first attempts in machine learning in 2018, before AI became so popular as it is now due to the gen AI, mostly the LLMs. Machine learning is here for many years, so we got our first attempt in what we were calling self-adaptive strategies. That was 2018. 2018. Didn't work well. It didn't take off, to be honest, back then, and I think it was a combination of the technology not being very mature yet, and also more importantly, the unwillingness of the banking industry and the people to adapt to such a new, untested methodology. this is rapidly changing now, as we know. And I would, I would set as the last, let's say, important critical point around the pandemic because even before the pandemic hit EXUS was already working on a hybrid model, mostly remote.

[00:14:02] Chris Maranis: So we still had an office, but we were mostly working remote. We were traveling on our customer premises, and then we allowed our people to work from anywhere. But still the world was not let's say, accepting working remote in all situations. There was not a lot of trust that this would work. The pandemic helped helped us a lot to migrate to a fully remote model. People actually accepted that you can have a quality meeting remotely. That if you, of course, follow some ground rules, you can still have a productive meeting. So I think that was a turning point. We are completely remote company. We employ people from 16 countries around the world, think last time I checked, which that means it allows us to recruit the top talent from all over the world. We're not restricted in any geography, and we allow these people to work remotely, apart from the times where we actually travel for our, to our customer location for some specific sessions, which we still prefer happen on site. I think that's some major turning points in our history.

[00:15:12] Chris Maranis: Well, that's a lot. You touched upon some significant I would say

[00:15:17] Craig Asano: pivotal turning points just working with that early group of banks which helped you go global early on, and then being resilient to all these crises that we've experienced. And, you know, the comment about being truly a, a remote business definitely has advantages. But for, for listeners who don't know where the head office is

[00:15:39] Chris Maranis: and, and that... is, is it, is it in Greece or is it in the UK or...? It's in London. It's in London. Yes. Yeah,

[00:15:47] Craig Asano: that It's in London Okay. But you're, you're... We're, we're having this remote video interview, and you're based in Greece, though?

[00:15:55] Chris Maranis: I'm based in Greece. Yeah I recently moved to Greece. I used to live in London several years, but I've, have moved now back to Greece, which is my origin, where I was born and raised.

[00:16:07] Craig Asano: And the food and weather is better there, too, right?

[00:16:10] Chris Maranis: Food is great. Food is great. Okay. Well, no, that, that's covered quite,

[00:16:14] Craig Asano: quite a range, so, so thanks for, for that. So let's fast-forward then a little bit into sort of the modern version of, of EXUS and with, with AI and its impact on collections. You know, talk a little bit about, from your perspective and EXUS's perspective, what the technology is allowing you to do today that you couldn't really do, you know, a few years ago,

[00:16:39] Chris Maranis: even a couple of years ago. It's changing so rapidly. Indeed. answering that, I would by repeating something I said earlier, distinguishing the advancements we all witness now in AI, in AI in regards to gen AI, the LLM, which is something rather new. I mean, say it's new. It's already a couple of years now we're all using them, but still, you know, in the fintech environment it's something new. In contrast to machine learning and the predictions based on machine learning, which are here for several for many many years. So machine learning has existed for many years. Before that most of organizations were using behavioral scorecards which is, let's say, a different technology, working towards the same end which is predictions. Now with the advancement of machine learning, of course, you get more accurate predictions. The accuracy you get with predictions is amazing. You get most fast predictions and more adapting predictions. You know, when the pandemic hit a lot of organizations were already using some behavioral scorecards models that helped them predict the behavior of people in order to adjust their strategies accordingly. But these models, let's say this previous era, let's call them models they were designed and put to practice and they would be recalibrated every, I don't know, six months or a year.

[00:18:10] Chris Maranis: The moment the pandemic people started to behave differently because of the pandemic. This change of the behavior that people started demonstrating actually made these previous models completely obsolete. They did not, they did not have the capacity to predict behavior of people because the behavior of people had completely changed of... due to this, you know, life-changing event global event we all witnessed. In contrast now with our machine learning models, we have the ability to retrain them in... and have them adapt to new behaviors, if not instantly, in a much more automatic and quick way. So they are much more adaptive to the models we used to have previously. And I use this, you know, pandemic event as just to make the point and explain how that affects. Other than that, we have to say that the gen AI and the LLMs are a true disrupter. They have brought now capabilities That were not here five years ago, we were not even thinking about them. Of course, we all know now that you need to have guardrails, you need to have governance, you need to have regulations, and I'm sure we're gonna talk about them.

[00:19:25] Chris Maranis: But still, these agentic AI concept and the LLMs are truly making, you know, a difference in how collections and other businesses, I can only talk about collections,

[00:19:39] Craig Asano: are changing right now. I think it's fascinating that the, because of these global crises, that the behavioral it makes total sense, but if you're not actually thinking about that and how it impacts your, your business. And so when, when AI is helping lenders make those key decisions today in, in 2026, maybe, you know, you can talk a little bit about, you know, how... Like, is it... You know, we, we definitely wanna talk about how AI is helping lenders but, you know, clearly there's a discussion around the, how autonomous those decisions will be. And, you know, maybe you can talk about the industry, what you've seen a little bit in terms of how other companies are employing AI and, you know, how it's used by lenders today in 2026. Or, or just Axis. it's really, you know, up to you to provide some information on AI and its impact on lending.

[00:20:36] Chris Maranis: Okay. The impact of AI on lending, and of course, again, I'm gonna focus mostly on the collections part. Yes, course. Yeah. There's a large part on on boarding approving new loans, servicing the loans. But in the collections part, we have already seen a lot of changes. Mind you, I think the, the, the aspiration and the ambition of the usage of AI versus what is actually right now, today, put in production operation, the gap between the two is big. So there's a lot of discussion, there's a lot of new things being piloted. Still there is a way before we see that deployed in actual operations. And I was just reading just the other day about a survey. It was a survey on 1,000, almost 1,000 tech leaders or risk leaders and only 2.5% of them actually confirmed that they have a customer-facing agentic AI tool in production operation. 2.5 of them.

[00:21:44] Chris Maranis: The same percentage regarding, you know, running pilots around it. That will, will be huge, very big. A lot of things are happening, still there is a way to go to actually embed that in the routine and to the operations. Now, having said that there are multiple areas where AI now comes to help, and the first one is about helping lenders decide who needs attention and what kind of attention and what to do next. So to combine the payment behavior that the customer had before, the contact history you have with this customer, and also the current context in order to decide what to do. I'll give an example. We have a prediction model which we call lazy payer. What is that? There are some people who are perfectly willing to, able and willing to pay, they just pay late. eventually they pay. So if you can identify people in your portfolio, you would probably do a very soft outreach. You don't need to go hard on them.

[00:22:53] Chris Maranis: You don't need to spend resource on them. The guys will eventually pay, so probably a very kind reminder through, you know, an SMS or a WhatsApp, depending on their preferred channel would work. There's also some prediction models that help identify the people that we call them self-cure. So there are some people who will eventually self-cure, as the word says. They will pay the debt without needing any, you know, more resource allocated to them, without needing to even irritate because they will eventually pay. But there's also some other prediction models that can predict if you call someone, whether this person is going to give a promise to pay. In the collections world, this PTP, the promise to pay, is one of the important concepts, is actually calling someone, and this someone, first of all identifies as the person you want to talk with, and this is very important, you have to do the authentication, and then acknowledges the debt, an important step there also. And then stating that they're willing to pay, but just want to let's say given some grace period or just get some help and gives a promise to pay in a week or two.

[00:24:06] Chris Maranis: That's what we call a PTP, a promise to pay. Mm-hmm. And based on the models we have created right now, lenders, when they have a list, I don't know, 100,000 or 200 debtors to call, these prediction models could, with very high accuracy, identify the people who are more probably to give a promise to pay. And therefore, you would prioritize your calling list, calling these people first until going to the next. So this is some areas where prediction help. But let's not forget that prediction doesn't actually recover the money. This is halfway there. This is the prediction. Then you need to engage. And when engaging, then we have other AI tools, and this is also where the gen AI and the agentic AI comes into play with either taking control of the communication, so the AI directly talking with the debtor, or in other cases, assisting the human agent to make an efficient and thoughtful communication with the customer. So these are, let's say, very broad categories where AI has started to be applied with, of course,

[00:25:19] Craig Asano: other areas also come into play if we get into more detail. I mean, it seems that, you know, as these pilots mature and in theory become more successful, they're saving time, they're saving money they're becoming more accurate in their predictions of, of behaviors, it, it's quicker. You know, is there an emerging sort of line that you see with the lenders on, on, and debt collections, that side of the lender's business that, you know, you could see, well, we think AI or, or you think AI is gonna be beneficial for all of these tasks, all of these decisions, but we're gonna draw the line here. Or do you believe that, you know, in the very near future, you know, AI will be having that call with that potential customer trying to solicit that, you know, promise to pay? You know, how far will AI go or, you know, how far is it today in making those decisions? It sounds like it, it's, it's a... I, I'm not sure. I guess I need the answer. It, it's, it sounds, it sounds like there's a lot of activity but are there any fully autonomous AI debt collectors, or is that a, a, a space that you don't think it, it's, it's going to come to fruition?

[00:26:37] Craig Asano: Okay. First of all, I will start with a quote I heard from someone,

[00:26:41] Chris Maranis: and I like very much, that it's very difficult to predict, especially the future. So, especially when we talk about AI, and with the rate that things are changing I would not risk any predictions for, for, you know, more than two or three years. Mm-hmm. But I can, I can say what I see already and where I think or feel things are going to move. So one of your questions well, several questions here, but one of them and I think it's a very important one, is whether lenders draw a line between what autonomous AI could do and where a human intervention should take place. And I would, in a very high level of course, draw the line here where the impact of the decision is or becomes bigger or critical or more important for the debtor. So, talking with someone, just letting them know that they owe an amount, just kindly reminding them or negotiating some repayment plan, that's perfect. And I, to be honest, I expect that AI autonomous, as you say agents are going to take over this part.

[00:27:51] Chris Maranis: That's what we call mostly in early collections or soft collections where automation is expected, where you can have a call center instead of having people calling and needing to adjust your calling list or schedule to the time that people are actually working at the call center. You can take off these restrictions. You can have your AI agents calling at the preferred time of the customer through the preferred channel of the customer, and having these discussions. However, some point when a customer, and this is often the case, fell into distress when there is some major event, so a person must has lost their job they're facing some major health issue. There's any something happening in their life that has put them in a difficult situation. I don't expect, and I don't hope, and I hope humans are still going to intervene there and handle these situations showing the level of empathy that is required for these situations. also due to the fact that there's going to be, and I'm sure there going to be although they're not there already, regulations around Because if things go wrong, you need to know what who made the decision, where this decision tracks back to, and being able to explain where we found ourselves into this decision.

[00:29:18] Chris Maranis: So I, I, appreciate my answer is not straightforward,

[00:29:22] Craig Asano: it's not black and white, but this is how I think things are going to be evolving. I have an interesting question here on my research notes around, you know, we tend to assume that people, like humans, have are safer for, for judgment, like in the example that you're talking about an emotional crisis, somebody lost their job, they're more empathetic. But is there a situation that a computer, a, a bot, an AI is more consistent or they're, they could be fairer for the kinds of decisions in, in debt collection outcomes because a, a person, as you say, they could be tired, they're, they're working remotely around the globe on different files. Do, do you see that eventually that they could, they could be the preferred choice for debt collections even in the complex cases because they're more consistent and fair, and they have what I've learned this new word, this institutional memory because they don't forget. They can go back and read the entire file instantly. And as long as they're programmed to be, let's say, fair, and these are the outcomes,

[00:30:28] Chris Maranis: that it could be more effective than humans? Okay. Allow me, Craig, to make a distinction here between consistency and fairness. Okay. Because consistency is not debatable. A consistent consistency is much easier secured through the use of automated tools, including the AI agent. So if consistency is what we are discussing not using humans, who by the way, even humans hallucinate as AI does. real. I mean, they're, they're only human. When it comes to consistency automated tool and AI tool far better. However, that doesn't make it fair. If, if there is a process, strategy, a process designed right now, which is, let's say, unsuitable for the specific situation of the customer, it's not fair. AI will not make it more fair. Fairness is a different thing, and it's mostly applied by, first of all, the regulators that need to safeguard that, and by the policy makers, the strategy maker of the organization, of the bank, who designs a fair strategy for the

[00:31:43] Craig Asano: Yeah. That, that, that's fair to to use the word that the, the actual decision logic would be, you know, baked in and, and applied, whether it's, it's a human running or executing that file per those rules or, or an agentic computer or, or bot. So one thing you mentioned about, you know, when something goes wrong you know, who is at fault. Do you have a view on where you think the regulatory and the legals will eventually... You know, they're studying it on every file, particular you know, in financial services. It, it, it's, it's a very serious sector. So what, what are your thoughts on regulations where that's gonna

[00:32:25] Chris Maranis: that's a rather complicated issue you touched Craig. And it's a question that is yet to be answered by not only the lenders, the regulators, the vendors, the whole market. Generally speaking, again, that's generally speaking the lender is the one who always retains accountability for what happens. So just saying that, "It's not me, it's the bot that you know, made this wrongful decision to fast-track this person to a legal office," won't cut it. The lender will retain accountability. However, the technology providers will have their own responsibilities. Now, now that becomes complicated because different parts of the world are in different, let's say, levels of maturity, and eventually they're gonna deal with this differently. In Europe GDPR exists for many years now. And there's this Article 22, if I'm not mistaken, which already provides safeguards against decisions which are based solely on automated processing that eventually produce legal effects on a individual. That's already in place.

[00:33:37] Chris Maranis: And right now, EU is formulating its AI Act, which is going to be introduced in the coming period which is going to further add more controls around that. That's Europe On, on the other hand, US is having a different approach. In Canada, as far as I know, OSFI is, is... There's this guideline E23, I'm not mistaken, which says that financial institutions are accountable for the use of the models they use, and that includes also externally sourced models. I think this is under discussion, and it's going to go in effect in 2027. But, you see, there's, there's a lot discussion to be made. And I expect different, as it has been up to now, different parts of the world are going to handle that in a different way. Yeah, I think it's, it... I guess it's early days. The, in, in most countries, unless it's,

[00:34:36] Craig Asano: it's very harmful, it's, it's difficult to put those regulations in market today because they don't wanna restrict on, on the innovation side and, and fall behind That's also important think yeah, we'll have to come back and do this podcast in another three years with you and see what happened. That, that's what we'll have to do. I hope we'll do one sooner than that. Well, I, I think, I mean, it's, it's fascinating, AI's role, and it, it's really, you know... I wanna try something different here for this next segment 'cause we talked about the decisions that AI can help for on the debt collection side versus a human. And so I wanna play a little game, we'll say, that, you Sure I'm gonna have you respond whether, you know, this example is suitable from your perspective or EXUS's perspective to fully automate it, it's okay. Or let AI calculate and, and support a human's decision, but they're recommending. So, you know, the first option is fully autonomous. Second is, we'll make the recommendation. And, and the third is a human, this is best for a human. Got it. Got and, one of those three decisions based on, you know, all your 22 years of experience here.

[00:35:50] Craig Asano: Got you. So for a Ready payment a customer misses a payment. It's, it's a routine payment. They've got no previous problems. The, the debt collection system identifies, you know, here is a suitable repayment plan. Do you allow that scenario to be fully automated,

[00:36:07] Chris Maranis: or just the decision, or it has to be a human? Misses one payment, has a good history, no previous problem. We identify the problem, automate it. Certainly automate the offer. This is, can be structured automation based on the policy by the bank. Offer something to the customer. The customer chooses to accept or not.

[00:36:24] Craig Asano: And then we have a different, you know, have a fork on the road. We have different scenarios, but certainly automated that's based on the bank's policy. That, okay. So it has policies, give it to the robots. So how about a financial hardship example where the customer says, lost my job. I can't make these payments." Mm is that a situation where, again, well, you know the three outcomes. How would you handle it? Yeah. I would certainly pause the standard path,

[00:36:51] Chris Maranis: the standard negotiation path, the automated path when somebody claims, at least states they are in hardship. And I would bring bring a specialist in the picture. Somebody stating there is a problem doesn't necessarily make it a fact. certainly warrants to stop the automated process and bring someone, a specialist, give time and authority to that person to manage that. Of course, I expect AI would support the handover, would give all the information. They might later follow up,

[00:37:25] Craig Asano: but I would bring in a, a specialist case. Specialist in financial hardship How about what I've indicated here as sort of a, a detected vulnerability? So AI detects a, a pattern that they think this customer is vulnerable, but the customer hasn't disclosed they've lost their job or anything. Should the lender or EXUS, you know, act based on what they found and,

[00:37:49] Chris Maranis: and the customer, the borrower has not mentioned anything? One of the reasons we have put these prediction models in place is to provide this kind of inference, this kind of signals. So we should certainly act on that signal, certainly. If it's, again, it's a suspected hardship, I would route it to a human expert. After the signal is generated by the predictive model, I would route it to a, a human expert who would need to do the diagnosis, so we don't still know what it is, establish the facts, do the check-in with the customer, offer voluntarily to help. And depending on the result, we will follow up. if I may say here Craig, it's important when these things happen to close the loop, meaning to feedback to the process the outcome of what happened. Because the AI model needs to improve its prediction capabilities, and this is will only happens if you close the loop. And that's one of the cases where AI fails to be useful. When people take it on the first steps of actually producing something, and they're happy with that, so they're producing some signals, but not closing the loop, feeding back what actually happened to further train the model and improve. That's a very important step.

[00:39:08] Chris Maranis: Absolutely. And then the,

[00:39:09] Craig Asano: the model only gets stronger and, for, for your particular cases. So I have another one here, a debt dispute. So a customer says, "The amount's wrong. I don't, I don't owe that amount of debt." Should AI Is that simple enough for AI to handle or do you think you have to involve a human? Yeah. I would say banks do have specific processes for disputes,

[00:39:29] Chris Maranis: so this is a standard workflow. When when a debt is disputed, it needs to go through a process. Usually, this process involves a person. So a person needs to call up, verify, again, identity of the person talking, verify the balance, and discuss the grounds on which this dispute came, log all the history, and then feedback. So for disputes, again I would go off the automated and use an

[00:39:59] Craig Asano: expert on disputes to handle that. Seems to be a lot of combinations right now with the, the, the complex cases. But so the, the last case or example I have is, is what I'll call legal escalation. It's, you know, customer has just missed payment after payment, and next they wanna, you know, technically move them to what I'll just call legal recover me. So it's, it's a legal decision. Do you think the AI should be escalating those decisions, which has tremendous impact, adverse impact on, on the borrower? Well, as you rightfully say, this is a, a very impactful decision, and I think it's going to be part also of regulatory,

[00:40:38] Chris Maranis: let's say, attention. It is in most of the cases already. So before moving someone to litigation I think again, a human expert needs to intervene. Although all the evidence are gathered by the AI, let's say, agent verifying that, going through affordability reviewing the situation, and taking the final decision, and being accountable for this decision should be a human being because that gives me a good opportunity to, to add something here. Introducing AI agents does not remove accountability from the organization. In contrast and that's something which I heard I, I was, I was in a in a FinTech event in Frankfurt last week about AI. And there was something said, so that's not me, I'm just quoting someone, but I thought it was spot on. So we all talk about human in the loop. So we have someone in the loop, as I'm talking right now.

[00:41:45] Chris Maranis: There's a person to make the ultimate decision. But you need to have someone on the loop, meaning someone monitoring the whole loop, the whole journey, making sure that it works as it should work, being accountable for the decision at the end of the day. So if things go wrong, there's a human accountable, not a bot accountable. There's a human accountable, and also has a kill switch, being able to pause that. So further to the human in the loop, the human on the loop, and especially for this, what we call special workflows, which for bankruptcy, for litigation, for insolvency you need to have this let's say, design in your organization. Yeah, absolutely. The, you know, AI can really perform incredibly,

[00:42:37] Craig Asano: but in terms of governance and accountability the, the humans surely should take precedent and, and priority. No, that's fantastic. So I, I think these cases provide a lot of insight into the decisioning and how AI interacts with humans or what they could potentially automate in the future versus all the way to, to the governance and the legal escalation and the more complex cases. So thanks for sharing those. So moving on here. I wanna You know, when I was researching this conversation, I came across something online that you had spoken to before. I thought it was interesting. You talked about the business case for caring in collections. So what, you know, what do you mean, and, and does Do lenders think like that? Is this, is something that, you know, only EXUS thinks about or, or you? Or what is the business case for caring?

[00:43:30] Chris Maranis: Yeah. Good point. Actually this was what you read, this article was sparked by a personal experience of mine some, I don't know, seven years ago, I think that experience brought forth for me something that was always there but it was made clear. To, to cut a long story short, I was in a management meeting with my management team, my peers, and I was challenged by my coach to set a breakthrough goal. Something that I love to do, but it was very, very difficult to actually do. So I did commit to play guitar electric guitar with my 16-year-old son in, in front of the whole company in the Christmas event, which you might say is not a big deal, but it was for me because I had never touched a guitar in my life. I don't know how to play guitar. And it was what, was June when I said that, and, you know, Christmas was just, you know, a couple of months down the road. Anyhow, the, the interesting thing was that the, my team did disregard or mock me for that. In contrast they supported me. I got a lot of support from my team. They kept me accountable, and I did it. I actually played Sweet Dreams by Marilyn Manson, one of my favorite Okay with my son in the Christmas event.

[00:44:42] Chris Maranis: what that uncovered for me was that being in a great workplace it's means helping people become more than they think they can be. And you know, there's a myth that caring for people is something soft. While in business, what really counts is, you know, KPIs, performance indicators, pressure. What, what I truly believe and strongly believe is that caring for people is not separate from performance. It's actually one of the drivers of performance, and that's what we do at EXUS. We really genuinely care for our people. Caring for people doesn't mean going easy or soft on them. That's not happening. We ask a lot from our people, but we really deeply care for them, and we have made our modus operandi. We call it our flywheel. So we take extra good care of our people, and our people, in return, they do the same with our customers, which are the collection teams, the people working at the collection departments. They take extra good care of our customers. Mind you that our customers, further to being, you know, large enterprises, at the end of the day, they are people, people that have to make decisions under pressures pressure that need to you know, achieve their goals, but at the same time they have to show the same care for their customers who are the debtors.

[00:46:03] Chris Maranis: And this is, this is a flywheel that actually works. We take extra good care of our people. Our people take extra good care of our customers, the collections teams. And these people are in, are capable to provide this extra good service to the debtors, and that actually works. And when I mean it actually works, this is not just, you know, fluffy stuff. EXUS has been consistently growing in an double digits, I may say, for almost a decade now.

[00:46:33] Craig Asano: So this is actually working in business terms, not just having a good time at work. It, it's the it's known as the golden rule. I, I think it's, it's treating people how you want to be treated and, you know, what you're touching upon, you know, the culture, it's, it's, it's a great leadership lesson for small and, and big companies as well. And it's good to hear that. We don't hear that enough, and I, I'm, I'm glad that you, you that article fleshed that out and we, we saw that. I wasn't exactly certain what that was, so I wanted to get your opinion, and I absolutely agree, so that's fantastic. So one of the reasons that, you know, brought you to NCFA's Fintech Fridays podcast here is that you've... EXUS has an expanding presence in Canada,

[00:47:18] Chris Maranis: and it's now Working with a major Canadian bank on its collections side with the technology. Can you tell us a little bit about, you know, your, your, your footprint here in, Okay Canada and, and the relationship and, you know, your views on the Canadian market? So indeed, we have recently expanded our presence in Canada, working with one of the major in the country. And Canada for us is, I would call it a long-term commitment. We strongly feel that we can add value by bringing the expertise we have from another 40 countries in the world we have worked with these two last decades, but also this unique service level approach we have to the local market. We have already established a trusted relationship with our first customer, and plan to, of course, build on it. And as we have done in all other markets, we have, let's say, increased our footprint. We will allow results and word of mouth do the rest because this is actually how EXUS has grown, by word of mouth, to be honest.

[00:48:26] Chris Maranis: You know, the collections industry, the credit industry, let's say, it's not, it's not that big as you can expect. I have connected with collection managers in all these countries, and we have worked with, and I've seen that the market's not that big. And people talk, and people move from organization to organization. And the best marketing we get is actually from successful implementations, and that's why we also plan to expand in the Canadian market, by being successful, by making, making our first installation in the country being a center of excellence, something that other organizations would, let's say, be envy of and would like to also put forth for their own organization. Now, I, I'm assuming here you,

[00:49:13] Craig Asano: you can't say too much about the implementation but maybe, you know, from a any large bank's perspective, when they go through modernizing collections Mm-hmm sort of integrating that technology, what... You know, can you talk to us little bit about those experiences? What, what is the most challenging hurdles in those implementations that any large bank or even a mid-sized bank has Mm deal with, at least when integrating collections platform technology? Greg, if you allow me here, I will, I will draw from the experience I have, not from Canada, but from multiple tens of installations around the world because some patterns are clear.

[00:49:57] Chris Maranis: And it doesn't matter if it's a auto finance company a universal bank, a consumer finance, a multi finance, a leasing. We have all these kind of lenders, and it may be in Indonesia, in the Philippines, in Saudi Arabia, in the UK, Netherlands or Canada. There are some things which I always see are the key challenges in implementing a modern debt collection solution. I would say the first one is, the hardest part, is to getting the data right. Getting on time and on quality the data. Everybody's saying that. I'm not new to that. Garbage in, garbage out. If you don't have the data stored and be able to gather, consolidate, and feed the collection system, then the quality of the output you will get would be low. I've seen organizations, huge organizations, very advanced and well-respected not having the quality of data they needed even to uniquely identify customers with multiple products in their organization. You know, one of the most important things you can do in collections is to work on customer level. So for example, Greg, if you have a mortgage your bank and you have a credit card, and you are paying your mortgage regularly every month, and you just miss one payment, just a small, you know, $50, $100 payment on your credit card, you wouldn't expect them to call you first thing on Monday morning and tell you, "Why are you not paying your credit card when you have been so regularly paying on your mortgage?"

[00:51:34] Chris Maranis: You would expect they would, you know, see the big picture and you know, treat you as the customer you are. Sometimes this is hard for some organizations because they fail to consolidate information that comes from legacy systems, back office systems that haven't been let's say, consolidated. So that's one thing that affects a lot of projects, the quality of the data in the organization. The second one is the coordination between the IT and the business. So the business teams usually have a clear view on what they need. They have the urgency, they have the requirements, they have the vision. On the same time, the IT department has a portfolio of projects, and in those there's tens, if not hundreds of projects that need to run on the same time. And these two, let's say, teams, organizations sometimes fail to sync or find their common ground to make, you know, to move let's say in unison. And we have found that one of the services we have offered, which is not in the core services but this is something required, is to be the glue, let's say, between the IT and the business, to be the API, say, that translates, you know, business world with IT world, and help them, you know, proceed with a, a common milestone, so with the project schedules we have.

[00:53:01] Chris Maranis: That's the second thing. And the third one is when an organization is trying on the same time to change their infrastructure, their technology, when on the same time changing their strategies, their policies. So if you, if you're changing both at the same time, both infrastructure and the strategy, then there is a big challenge on actually testing if what you have generated is according to what your expectations are. You don't have to check against something. So that's why a lot of organizations sometimes do the let's say the lift and shift type, changing their technology without changing the processes, or changing their processes if the technology is sound. Or if the technology is not sound, first doing the technology upgrade, and then building on that technology, doing all the changes that this new technology enables. So I would say these are the common

[00:53:58] Craig Asano: challenges I've seen around the in different lenders. They certainly sound like challenges a large Canadian bank might just have. Why should they be different than the rest of the world? Yeah. Well, you know, you often hear legacy data. We've all experienced if working for a large company the business versus the IT teams, you know, trying to control and, and just having that alignment and the political will from the bottom and the top to, to do it right and, and properly. But it's exciting times for sure. I was just having a look at the time here. We're gonna move to sort of the future of collections discussion a little bit as we move to, to wrapping up here. You know, we talked a little bit about agentic AI. And from your perspective, where do you see in the few years all the innovation happening? And, you know, how And then after that, we wanna talk a little bit about the actual innovation AI or otherwise. You know, what, what's the future for EXUS? But first, let's talk about the agentic AI and, and its impact on collections in Where, where do you see it going from So the,

[00:55:10] Chris Maranis: we already discussed the part of let's say prediction and decisioning, which is already advanced. And I think more and more being more and more accurate a lot of the decisioning is going to shift towards prediction machine learning models. But I think the biggest disruption right now that's happening on the gen AI part, which is what most people relate as replacing the human agent with a bot. Again, it's difficult to predict the future. I don't think we're gonna get to what's called the complete agentless environment. Of course, the role of the agent is going to substantially change. They're going to be less agents, and the work the job description is going to be completely different. It's going to be more challenging, which is good, it's great. But more and more contact is going to happen automatically and through agentic AI as they can select the best time, the best channel, and handle more and more discussions. This, let's not forget, it also reduces the operational costs of the organization, which one of the major thing and the after.

[00:56:20] Chris Maranis: And also the consistency you talked about earlier comes into play here, and gives another point on automating contacts. What remains to be solved, and for the time being, I think it's going to halt a bit, this migration, is the requirement for accountability and for explainability. It's not only regulations. It's, it's regulations, it's ethical, it's business. For many reasons, you need to be able to explain why something happened. Why was this customer contacted or not contacted on that day? Why was this message specifically on that day sent to this customer? So this is something the whole industry is working on, and I think with the regulations that are going to come in play the next years, we're gonna see more and more of this business being automated and getting over to the AI Yeah, absolutely. Well, as you say, it's tough to predict, but we're living through some fantastical times, I, I will say, on, on the innovation front. So from XS's, you know innovation vision,

[00:57:29] Craig Asano: you know, can you share a few projects that you might be excited about? What excites you? What's coming down the pipeline? Okay. So there are, there are tools that have already been developed, have been piloted. Some are already in operation,

[00:57:43] Chris Maranis: some under pilot operation. That includes, let's say, the AI negotiator. This is a tool that actually handles communication with the customer directly, with the debtor. And we also have the AI coach, which is something like, a co-pilot for agent that helps the agents in their communication, but it also helps the supervisors to manage their teams. If I give a quick example when you are a supervisor in a call center, one of the tasks you have to do is to actually make sure, do, you know, the, your QA, your quality assurance. Make sure you that all policies are being followed, and that includes also eavesdropping on some of the communications that your agent have with people to make sure that all regulations are followed, that the bank's ethical and strategic guidelines are followed. Imagine having 200 people in your team, and they make something like 200 calls per day. Can you actually eavesdrop on all these calls? No way. You can just, you know, sample one or two.

[00:58:51] Chris Maranis: With this AI coach we have developed, all communications are audited, and the supervisor gets summary of the insights and the results of all these communications. So they can very quickly do their performance manager on their teams, they know which ones are performing well, and also tune their messaging in all the discussions they're having. So this is something which already happening, and I think it's a big, big change for collections operations. And if I had to choose one of the things that, you know, are in the pipeline to come in the future, I would say something that our innovation lab is currently still, you know, fleshing out. It's the regulatory compliance agent. And, you know, we, we, we operate under a very regulated environment, and these regulations change constantly. And collection operations need to remain compliant at any times. So this is a big task, being aware of all the regulations and making sure that are, at any time, they are followed. So this regulatory compliance agent is a tool who is going to monitor all changes in regulations and make sure that all internal processes abide by these regulations for the bank.

[01:00:06] Chris Maranis: This is still in design. It's something, you know, it's still in a let's say prototyping phase. And hopefully we will have seen it, you know, come to market later next year. Yeah, it's super interesting because,

[01:00:18] Craig Asano: it's, as you said, it's, it's a, it's a massive task, but it cuts across and into or maybe through all the other agent processes. So in a multi-agent platform and, stack. But it, its impact is, is critical to, to all, any operations and, you know, it's gonna have impact on costs and just making sure that these transactions are, are legit and, and legal. So fantastic. I can't believe that the time has come on here. We're, we're going to go to our rapid fire questions. These are, you know, just expecting short you know, short answers just to have some fun.

[01:00:58] Chris Maranis: Rapid fire. Sometimes it's a bit of business, sometimes it's a bit of personal. So we're just Let's go short answers. So the first rapid fire question for you, Chris, is the biggest misconception about collections. That's easy. The biggest misconception is that collection starts

[01:01:12] Craig Asano: after the relationship with the customer ends. Totally after the end. I see. Good answer. Next rapid fire. What's one thing that the collections

[01:01:21] Chris Maranis: industry needs to stop doing? Thinking of applying or thinking of applying AI

[01:01:26] Craig Asano: to do more of something that does not work. Yeah. You can't automate something that's, that's broken. It's broken for a good reason, right? Next question. One lesson that you'd give yourself when you joined XS way back in 2004, 22 years ago.

[01:01:42] Chris Maranis: Oh, to my much younger self. To your much younger self. Yeah, that's, that's I think,

[01:01:47] Craig Asano: I think a good advice is talk less, listen more. Well, you've done a good, good job today. Next rapid fire, what still excites you most about the industry after 22 years?

[01:01:59] Chris Maranis: I think the best moments I experience when we get, me and my team get the thank you notes from our end users mentioning that how we

[01:02:08] Craig Asano: somehow, even through technology, positively affected their lives. That is the business case for caring in full circle right there. So last rapid fire question, what's on your personal bucket list that you haven't done yet, but you will do it? That's personal, so not business. Personal It's a personal bucket list.

[01:02:26] Chris Maranis: If you wanna That's easy. Yeah. That's easy. Yeah. It's been for many years, probably gonna stay for many years. That's to read James Joyce Ulysses. Oh. You, you could just pick that book up, no time? I've tried in my 30s, I've tried in my 40s, now I've just entered my 50s. I'm gonna try again, but this is a bucket

[01:02:44] Craig Asano: Well, you get that in, in your retirement plan the, the golden years to come. Well I just, you know, wanna thank you, Chris for sharing your, your knowledge. It, I, I've actually learned a ton. One thing, you know, as we wrap up this podcast how can people who get in touch with you or, you know, if they have more, they wanna learn more about EXUS or potentially,

[01:03:10] Chris Maranis: you know, discuss the platform or how do they contact you? I would say that's rather easy. You can find EXUS online, E-X-U-S. It's rather simple. And of course, I'm on LinkedIn. And another way to find about EXUS, just search and find about making collection heroes. That's our trademark. So making collections heroes is what we want to do. Search for that and you'll find

[01:03:34] Craig Asano: Sounds like an amazing company to, to work for. Thank you. Chris, at, at this point, we're just gonna, to wrap up, and is there any last message that you wanna say to our listeners here before we wrap? Well, first of all, I would like to thank you, Greg. It's,

[01:03:51] Chris Maranis: I look at the clock now and I see it's one full, one hour we have been talking. That was a very interesting discussion. Thank you for prompting these questions. And what I would like to say is that it's a chance for me to say that collections on a, is much more complicated than what people think, and it's much more impactful than what people would think. And I would like to just say kudos to all the people that are working in collections all these years and have been serving the debtors, helping them, while at the same time getting, you know, some negative spotlight

[01:04:28] Craig Asano: on their job. I just want to say I really appreciate them, and feeling great working with them. It's a very positive, you know, spin or, or perspective, Chris. It's, it's fantastic. So wanna wish you and, you know, the entire 170 plus team at EXUS, you know, all the success in, in the future here in Canada as well as you expand and, and grow your, your footprint. Thank you very much, Greg. you know, welcome for that, and well, thank you for sharing your insights today. And with that, we'll just wrap up here. So to everyone and our listeners, if you're new to Fintech Fridays, please check out some of the incredible past episodes on the site. I think you'll be surprised with what you find. We look forward to seeing you next Friday for another episode of Fintech Fridays. Have a great weekend, everybody. Take care.

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Why Canada Keeps Tightening Its AML Rules

November 5, 2026 | NCFA Story Intelligence | Risk Compliance And Regtech, Regulation And Policy, Digital Assets Blockchain And Tokenization

AI illustration of NCFA Story about Canada AML rules timeline showing FINTRAC, FATF reviews, beneficial ownership, crypto reporting, crowdfunding rules, penalties and Bill S-8.

Canada keeps closing financial crime gaps, but investigations, prosecutions and asset recovery still have to catch up with the much larger system

Canada added another layer to its anti money laundering system on November 3, 2026.

Bill S-8 would tighten registration for money services businesses, give FINTRAC more grounds to refuse or revoke registrations, add controls for crypto ATMs, restrict some large cash transactions and third party cash deposits, and let regulated firms receive more financial crime information from government and law enforcement.

Five days earlier, the Auditor General had delivered a very different AML announcement.

FINTRAC was taking nearly 4 months on average to provide requested financial intelligence. Half of the recipients surveyed said information sometimes arrived too late to help an active investigation.

A month before that, FATF had praised parts of Canada's system while still calling for stronger supervision, more complex money laundering prosecutions and better asset recovery.

Canada isn't short of rules.

It has spent more than 25 years adding them.

This is a story of Canada closing one financial crime gap after another, only to find that more reports and tougher rules don't automatically produce faster investigations, prosecutions or recovered money.

The 2022 truck convoy became one of the most visible turns in that story.

It wasn't the beginning.

FINTRAC Is Born and the Boundary Starts Moving 2000 to 2008

Canada's modern AML system begins in 2000. Parliament creates FINTRAC and requires suspicious transaction reporting and reporting of certain large movements of money. After the September 11 attacks, terrorist financing is added to the mandate. By 2006, Ottawa is already widening the system again with MSB registration, administrative penalties and broader compliance duties. FINTRAC is still young, but money is already finding routes the first rulebook didn't fully cover.

How Canada's AML System Started

FINTRAC's institutional history traces the current system to legislation passed in 2000.

FINTRAC began receiving suspicious transaction reports and voluntary information in 2001. Terrorist financing was added after the Anti Terrorism Act.

Changes passed in 2006 introduced the MSB registration regime and gave FINTRAC authority to impose administrative monetary penalties. Registration came into force in 2008.

Canada starts expanding the system almost as soon as it builds it.

Banks and other reporting firms now have to tell FINTRAC when money looks suspicious. Investigators gain a national source of financial intelligence that didn't exist before, and regulated firms can no longer treat unusual transactions as someone else's problem.

But criminals aren't limited to bank accounts. Money can pass through companies, intermediaries, cash businesses, real estate and foreign accounts. The first rulebook catches more activity, and the routes around it become easier to see.

The First FATF Review Finds the Holes 2008 to 2016

FATF's 2008 review gives Canada's young system its first major international stress test. Ottawa gets credit for substantial reforms, but FATF still finds weaknesses in customer checks, supervision, beneficial ownership and FINTRAC's effectiveness. Canada spends the following years tightening many of those areas. By 2014, FATF removes Canada from regular follow up. Two years later, the next full review finds that some of the hardest problems weren't gone. They had moved deeper into the ownership and professional structures around the transaction.

What FATF Kept Finding

The 2008 FATF evaluation called for stronger customer checks, more consistent supervision and better beneficial ownership information.

The 2016 evaluation found substantial progress but continued exposure through legal professionals and opaque companies and legal arrangements.

Lawyers couldn't simply be folded back into the same FINTRAC model either. A 2015 Supreme Court decision found that applying parts of the federal regime to legal counsel violated constitutional protections.

The financial system was becoming easier to monitor. Some of the people behind the money were still difficult to see.

Customer checks get stronger. MSBs register. FINTRAC gains penalties and more supervisory reach. A regulated firm has fewer excuses for not knowing who opened the account or sent the money.

Then investigators reach the company behind the transaction and can hit another wall. The account holder may be visible while the person controlling the corporation isn't. The search moves from the customer to the owner.

Canada Starts Naming the People Behind the Companies 2017 to 2019

Federal, provincial and territorial governments agree to improve beneficial ownership records and eliminate bearer shares. From June 2019, most federal corporations have to keep information on individuals with significant control. A numbered company can still stand between suspicious money and its owner, but investigators now have another record to pull when they start taking the structure apart.

Ownership Records Get Stronger Again

The first federal requirement kept ownership information at the corporation.

That changes again in 2024. Most federal corporations must file information about individuals with significant control with Corporations Canada, and some of that information becomes publicly searchable.

It still isn't a complete Canadian system. Provincial and territorial corporate law means ownership information remains spread across jurisdictions.

FATF is still calling for progress toward a pan Canadian beneficial ownership system in 2026.

A shell company becomes less useful when investigators can identify the people with significant control. The ownership trail gets shorter, and legitimate companies get clearer record keeping duties.

The trail can still cross provincial registries, trusts and foreign entities. And while Canada is looking deeper into ownership, another way of moving value is growing outside the familiar bank payment path. The next gap starts with the money itself.

Crypto Opens Another Route for Value to Move 2020 to 2021

Virtual currency dealers and foreign MSBs serving Canadians come under FINTRAC requirements in 2020. Large virtual currency transaction reporting follows in 2021. Crypto is no longer treated as a separate financial world. If a business exchanges or transfers virtual currency for Canadians, the same questions about identity, source of funds and suspicious activity follow it there.

Crypto exchanges and payment firms now have to build registration, identity checks, records and reporting into products designed to move value quickly. Legitimate operators gain a clearer path into the Canadian market, but compliance becomes part of the product itself.

Bringing crypto inside FINTRAC doesn't cover every new way Canadians can collect or move money. A year later, crowdfunding and payment platforms show where the boundary still ends. The next expansion arrives in the middle of a national crisis.

The Convoy Turns a Gap Into Permanent Rules February to April 2022

The truck convoy makes another gap visible in real time. Ottawa invokes the Emergencies Act in February and temporarily brings crowdfunding platforms and certain payment providers under AML obligations. The emergency ends. The coverage gap doesn't. Two months later, Canada makes the change part of the ordinary system.

What Became Permanent

On April 27, 2022, new regulations permanently brought crowdfunding platforms and certain payment providers under FINTRAC as MSBs or foreign MSBs.

Registration, compliance programs, identity checks, record keeping and transaction reporting followed.

The federal explanation explicitly linked the change to crowdfunding and payment risks highlighted by the blockades.

The permanent rules also drew an immediate industry challenge over their scope, lack of consultation and compliance costs.

The convoy didn't start Canada's AML expansion. It exposed one channel the existing system hadn't fully captured.

Ottawa closes the gap quickly. Crowdfunding and payment firms that had built businesses outside traditional banking inherit FINTRAC registration, identity checks and reporting. The line around the regulated market moves again.

Legitimate platforms pay for the same controls. Staff, systems, records and audits become part of the cost of staying in business. The government closes one blind spot and pushes compliance deeper into smaller financial firms.

The Net Spreads Across More of Finance 2023 to 2025

The next expansion isn't built around one crisis. Mortgage businesses come under FINTRAC in 2024. Armoured car companies follow. In 2025, cheque cashers, factors, financing and leasing firms, title insurers and businesses serving private ATMs join them. Private information sharing between reporting entities also gets a legal route. By 2025, more than 38,000 businesses are inside FINTRAC's supervisory reach.

Why So Many More Businesses Are Now Inside

Canada's 2025 National Risk Assessment identifies vulnerabilities across payment providers, mortgage businesses, crypto assets, crowdfunding, real estate, MSBs and other sectors.

It also says criminals can exploit information gaps between reporting firms. Since March 2025, regulated entities can voluntarily share some personal information under approved codes of practice to detect money laundering, terrorist financing and sanctions evasion.

The system becomes less dependent on one firm spotting one suspicious transaction in isolation.

More businesses are now expected to recognize the same money from different sides.

A suspicious account at one institution can become more useful when another firm recognizes the same owner, wallet or transfer pattern. Activity that once ended inside separate compliance teams can start connecting across institutions.

That gives firms another job. They need controls around what can be shared, why it can be shared and who gets access. Canada gains more intelligence, while compliance becomes a bigger part of running the business.

FINTRAC Starts Throwing Firms Out 2025 to 2026

Then enforcement gets much harder to ignore. FINTRAC issued 6 notices of violation worth about $1 million in 2022 to 2023. In 2025 to 2026, it issued 35 notices worth more than $247 million. It also revoked 82 MSB registrations in one year, up from 12 the year before. A payments, FX, remittance or crypto firm can no longer treat registration as something it secures once and files away.

The Price of Non Compliance Jumps

By May 2026, revocations were cutting across money transfer, FX, virtual currency and PSP businesses, including firms operating across several categories at once.

FINTRAC's 2025 to 2026 annual report confirms 82 MSB revocations and more than $247 million in notices of violation.

The escalation was already visible in Cryptomus's record penalty. FINTRAC imposed about $176 million after finding failures that included suspicious transaction and large virtual currency reporting.

Weak compliance can now threaten the economics of the company itself.

A strong operator can benefit when firms that ignore reporting duties or regulator requests lose market access. Banks and partners have more reason to trust an MSB that stays registered and responds when FINTRAC calls.

But the price of proving that compliance is uneven. Large institutions spread legal, data and monitoring costs across millions of customers. A startup can't. The regulator starts removing weaker operators just as the cost of being a strong one keeps rising.

Bill C-12 Makes Compliance Failures Much More Expensive March 26, 2026

Parliament gives FINTRAC much stronger enforcement tools. Maximum penalties rise sharply. Compliance orders become public. An entity that doesn't comply with an order can face a penalty of up to the greater of $30 million or 3% of global revenue. Ottawa can now hit weak controls much harder without waiting for police to prove a money laundering offence.

How Much Larger the Penalties Became

Bill C-12 received Royal Assent on March 26, 2026.

For prescribed violations, an entity can face a maximum penalty of $20 million. Aggregate maximums can also be tied to 3% of global revenue.

FINTRAC says the legislation increased some penalty limits by as much as 40 times.

A compliance failure can reach the boardroom long before it reaches a criminal courtroom.

FINTRAC no longer has to wait for a criminal case to hit a company hard. It can order fixes, impose much larger penalties and put compliance failures into public view. For regulated firms, the cost of weak controls can arrive long before police lay a charge.

But the money laundering case still has to be built somewhere else. Police need evidence, prosecutors need a case they can prove and assets have to be found before they disappear. Canada has made it faster to punish weak compliance. Catching and recovering the criminal money is still the slower job.

Ottawa Builds a New Agency for the Part FINTRAC Can't Do April 2026

A month later, Ottawa goes after that slower part. Bill C-29 proposes a Financial Crimes Agency to investigate serious and complex financial crime and help recover criminal proceeds. FINTRAC can find patterns and send intelligence. The new agency is meant to pick up the trail from there.

What the New Agency Is Supposed to Do

Bill C-29 was introduced April 27, 2026 and is now being considered by a House committee. The agency isn't operational yet.

The 2026 economic update put $352.7 million over five years and $82.1 million annually thereafter behind the proposed agency, alongside additional funding for specialized prosecutors and Finance Canada.

Its planned workforce includes police and civilian investigators, financial intelligence specialists and asset recovery experts.

Collecting more financial intelligence hasn't produced enough complex cases or recovered money on its own.

FINTRAC can connect reports across institutions and point investigators toward suspicious money. It can tell police where accounts connect and which transactions deserve another look.

Police still have to identify the people, gather admissible evidence and find the assets before they move again. Ottawa is creating another institution because financial intelligence doesn't arrest anyone or recover a dollar by itself.

Two Reviews Show Where the Money Is Still Escaping September to October 2026

By fall, Canada gets two report cards within a month. FATF finds a much stronger system with high quality financial intelligence, but still calls for better supervision, more complex money laundering prosecutions, stronger beneficial ownership coverage and more asset recovery. The Auditor General follows with a problem investigators can feel immediately. Useful intelligence isn't useful enough when it arrives months after police ask for it.

Good Intelligence Can Still Arrive Too Late

The 2026 FATF evaluation says Canada has a mature understanding of financial crime risk and produces high quality intelligence valued by law enforcement.

FINTRAC says FATF found its intelligence was used in 94% of the money laundering and criminal possession investigations reviewed by assessors.

The Auditor General's October 29 audit found that FINTRAC took nearly 4 months on average to provide intelligence when law enforcement flagged a concern.

Half of surveyed recipients said the information sometimes arrived too late to help an ongoing investigation.

The information can be valuable and still lose value while the money keeps moving.

Canada now has more reporting entities, ownership data, penalties, registration controls and financial intelligence than at any earlier point in FINTRAC's history. The reporting side of the system is bigger and harder to ignore.

Investigators still need the information before assets move. Prosecutors still need complex cases they can prove. Governments still need to recover more of the money. Canada has become better at spotting suspicious activity than finishing the journey from report to recovered proceeds.

Bill S-8 Tightens the Perimeter Again November 3, 2026

Five days after the Auditor General's report, Bill S-8 arrives with another set of controls. MSB registration would get tougher. Crypto ATM operators would face more checks and reporting. Some large cash activity would be restricted. Law enforcement could send more information back into regulated firms. Canada is still closing entry points while its newest reviews are pressing the system to do more with the information it already has.

What Bill S-8 Would Change

Bill S-8 is proposed legislation. It isn't law.

The bill would require crypto ATM operators to verify every user's identity, keep transaction records and report each ATM transaction to FINTRAC within 15 days. It would cap a person's transactions at a crypto ATM at $1,000 within 24 hours.

It would prohibit certain third party cash deposits and restrict some cash payments, donations or deposits of $10,000 or more, subject to exemptions and regulations.

It would add new grounds for refusing or revoking MSB registrations, including false or misleading information, and give the Minister of Finance new review and direction powers tied to national security and financial system integrity.

Bill S-8 brings crypto ATM laundering risks back into the centre of the debate after FINTRAC had already documented the use of cash, money mules, private wallets and higher risk exchanges around the machines.

Another gap may close. The pressure on investigators, prosecutors and asset recovery doesn't disappear with it.

Stronger registration can remove operators that lie about their business, ignore regulator requests or raise serious integrity concerns. Legitimate MSBs, payment companies and remittance firms may benefit when weak operators lose access.

Every added check still needs people, systems and legal work. Small firms spread those costs across fewer customers than banks do. Canada can shut bad operators out and still make the door heavier for good ones to open.

The Next Gap Won't Be Fixed by Another Form

Bill S-8 may close more holes around MSB registration, crypto ATMs, cash deposits and financial crime information sharing.

But Canada is reaching the point where adding another reporting obligation produces less value if the rest of the chain can't keep up.

FINTRAC can collect more information.

Banks, fintechs and MSBs can build better controls.

Law enforcement can receive more leads.

None of that helps much if investigators get the intelligence too late, prosecutors can't build enough complex cases or criminal assets are gone before authorities can reach them.

That is where Canada's next AML chapter is heading.

The proposed Financial Crimes Agency could give Ottawa more capacity to investigate serious financial crime and recover proceeds. Bill C-12 gives FINTRAC much stronger leverage over regulated firms. Bill S-8 would tighten who gets into parts of the market and how certain transactions are handled.

Those tools now have to work together.

For fintechs, that creates a different kind of pressure.

The firms that survive stricter registration and supervision may become easier for banks, investors and customers to trust. But every new control also costs money, and smaller operators don't have the same compliance scale as the country's largest financial institutions.

Canada can keep tightening the perimeter.

The bigger question now is whether the system inside that perimeter can move fast enough to catch the money, recover it and still leave room for legitimate firms to compete.

That answer won't come from the next amendment.

It will come from the cases Canada is actually able to finish.

Talking Point

Will Canada's next AML gains come from tougher rules, or from finally turning more financial intelligence into completed cases and recovered assets?

What Happens Next?
  • Will Parliament pass Bill S-8, and which MSB, crypto ATM and cash provisions will survive the legislative process?
  • Can FINTRAC shorten intelligence delays while supervising more than 38,000 reporting businesses?
  • Will the Financial Crimes Agency improve complex investigations, prosecutions and asset recovery once Parliament establishes it?
  • Will larger penalties improve compliance without giving the largest firms an even greater cost advantage?
  • Can federal, provincial and territorial governments close the remaining beneficial ownership gaps?
  • Will wider information sharing help investigators without weakening privacy protections?
What Did You Think?

Has Canada reached the point where better enforcement matters more than another layer of AML rules?

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NCFA Canada logoThe 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, artificial intelligence, 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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Canadian ESG Firms Face UK and EU Rules Abroad

November 4, 2026 | NCFA Story Intelligence | Sustainable Finance And ESG, Regulation And Policy, Competition And Market Structure

AI illustration of Canadian ESG firms facing UK and EU rating rules as they expand from Canada into regulated European markets.

Canada keeps lighter rules at home while UK and EU requirements follow Canadian ESG firms into foreign markets

ESG ratings promised investors a shortcut.

Instead of digging through climate data, labour records, governance practices and supply chains themselves, they could buy a score and put it to work.

Then the scores started disagreeing.

The same company could look strong through one provider and much weaker through another. Nobody had to be cheating or doing bad work. One firm might care more about carbon exposure. Another might put more weight on labour practices, board governance or supply chains. Even when they looked at the same issue, they weren't always using the same data.

Investors were left with a problem. They had bought a shortcut and now had to check the shortcut.

In Britain, thousands of financial firms eventually built their own checks around ratings they were already paying for. The FCA estimates that extra work now costs about £495 million every year.

Regulators eventually made a choice that wasn't obvious at the start. They didn't force every provider to use the same formula. They started regulating the firms producing the ratings.

The EU rules have applied since July 2, 2026. On November 3, 2026, the UK Financial Conduct Authority published its final ESG ratings rules. From June 29, 2028, firms caught by the UK regime need FCA authorisation.

Canada hasn't followed them.

That gives a Canadian startup more breathing room at home.

Then it lands a customer in London, Paris or Frankfurt.

The Canadian rules haven't changed. The business suddenly has.

One Company, Two ESG Scores, Two Different Stories 2020 to 2021

The first crack appears when investors compare the ratings side by side. MIT researchers find average correlation of only about 0.54 across major ESG ratings. Major credit ratings from Moody's and Standard & Poor's are around 0.92. An investor can look up one company, buy two ESG scores and still be left wondering which picture is closer to reality.

Why the Scores Split Apart

MIT finds the biggest source of disagreement in the measurements themselves. About 56% of the difference comes from providers choosing different indicators, estimates or datasets for the same issue.

Another 38% comes from scope. One provider includes an issue. Another leaves it out.

Only about 6% comes from weighting.

These ESG ratings comparability problems were already surfacing years before regulators stepped in.

The scores didn't just disagree. Investors often couldn't see enough to understand why.

One provider knocks a company down for carbon exposure. The investor sees the score fall and assumes climate risk is driving the result. But that number also reflects choices about which indicators were used, which data was trusted and how the provider turned those inputs into a score.

Another barely moves on carbon but cuts the same company for governance or labour practices. The company itself hasn't changed between the two ratings. What changed is the lens used to judge it. Same company. Same ESG label. Different story.

The UK Gives the Industry a Chance to Fix Itself 2021 to 2023

Regulators don't reach for licences first. IOSCO publishes recommendations in 2021. The UK follows with a voluntary Code of Conduct in December 2023. Providers are asked to explain their methods, clean up conflicts and show customers more about the data and assumptions behind the score. The industry gets a chance to prove it can clean things up without direct regulation.

Providers sign up, publish more detail and tighten their controls. They still get to build their own methods and scores. That keeps room for different models to compete, but it also leaves customers comparing very different ways of measuring the same company.

Customers keep doing their own checks anyway. Banks, asset managers and other users still have to decide whether the provider's data, methodology and controls are strong enough for their own decisions. More disclosure helps, but the doubt doesn't go away.

The Shortcut Starts Costing Almost as Much as the Rating 2024 to 2025

Then the FCA counts the cost. About 5,400 regulated firms are using outside ESG ratings. They spend roughly £622 million on products containing them in the year to November 2024. Around 3,400 firms also have their own staff checking whether those ratings are good enough to use. That extra work costs an estimated £495 million a year.

What £495 Million of Checking Looks Like

Firms doing the extra work use an average of almost 3 full time employees.

About £104 million of the annual bill comes from fixing problems or chasing information that isn't easy to find.

One firm tells the FCA that adding a new ratings provider can take 9 to 12 months once it reviews the methodology and changes its technology.

55% of users report concerns about provider systems and controls. Another 48% report transparency problems.

The market has reached an awkward place. Firms are paying for ratings, then paying again to work out how much faith to put in them.

A rating only saves time if the buyer trusts the data, methodology and controls used to produce it. By this point, many firms aren't simply reading the score. They're reviewing the provider, checking the method and sometimes changing their own systems before the rating can be used.

By 2025, thousands of firms have built their own second opinion inside the company. Some are spending months onboarding providers and assigning staff just to close information gaps or resolve concerns before a rating can be trusted. The shortcut has created another job.

Britain Decides Voluntary Rules Aren't Enough 2023 to 2025

The UK now has its answer. HM Treasury asks whether ESG ratings should come under financial regulation. 95% of consultation respondents support bringing them in. The government proceeds. By December 2025, the legal order is in place. The industry had its voluntary first chance. The next stage comes with a regulator.

Before, a provider could follow the voluntary code and convince customers that its controls were good enough. The customer could accept that explanation, ask for more or walk away. The regulator wasn't deciding whether the provider could stay in the market.

Under FCA rules, that choice disappears. Firms in scope have to meet requirements around governance, conflicts, systems, data and disclosure, and they need authorisation to keep serving the market. If the firm is caught by the regime, meeting the standard becomes part of staying in business.

Europe Makes Foreign Providers Play by Its Rules July 2, 2026

Europe gets there first. Its ESG Ratings Regulation starts applying on July 2, 2026 and puts ESMA in charge. Then the reach widens. A Canadian provider can be in Toronto, build the rating in Canada and still face European requirements when it sells that rating to European customers. Being outside Europe doesn't put the business outside the rules.

How a Canadian Provider Can Still Get Into Europe

Equivalence can work when the European Commission decides another country's rules are close enough to its own. The provider also has to be authorised or registered and supervised there.

Canada doesn't currently have that kind of ESG ratings regime.

Endorsement lets an authorised EU provider stand behind ratings produced outside Europe when both providers belong to the same corporate group.

Recognition gives qualifying smaller foreign providers another way in. They still have to meet EU requirements, appoint a legal representative and answer to ESMA.

Europe leaves the door open. Canadian firms just don't get to walk through under Canadian rules alone.

A smaller Canadian provider can still reach European customers without waiting for Canada to create its own ratings licence. Recognition can give qualifying foreign firms a way in when equivalence isn't available, so the market isn't closed to an independent Canadian provider.

But it still has to meet European requirements. Depending on the route, that can mean a legal representative, added documentation and direct accountability to ESMA. The company can stay Canadian, but its European business can't simply run on Canadian rules. Getting into the market is possible. Getting in on Canadian terms isn't.

Canada Tightens ESG Claims but Leaves Ratings Providers Alone 2024 to 2026

Canada hasn't ignored ESG. Investors have challenged the claims behind bank sustainability promises. Competition Act changes have pushed companies to think harder about what they say about environmental performance. Securities regulators also keep a close eye on how funds describe ESG strategies.

Then Canada spends years wrestling with another question. If a lender or investor wants to call something green or transition finance, what should those words actually mean?

An answer finally arrives in October 2026 with Canada's green and transition taxonomy. It gives the market common definitions, but using it is voluntary. And it still doesn't regulate ESG ratings providers. Canada is tightening the claims around the score without licensing the company that produces it.

Three ESG Products That Look Similar Until the Rules Arrive

A taxonomy tells a lender or investor whether an activity fits a green or transition definition.

Disclosure rules tell a company or fund what it has to say.

An ESG rating takes information and turns it into a score, assessment or opinion.

They can all draw from the same sustainability data. They still aren't the same product.

Canadian companies are already raising money for ESG reporting tools built around records that can be checked. Better data helps the whole market. It doesn't turn every ESG software company into a ratings provider.

A Canadian startup can build an ESG scoring product, test it and sell it at home without first getting a dedicated ratings licence. That leaves more of its early budget for product, data, hiring and customers instead of a new authorisation process.

Then it signs a foreign customer. New legal work, documentation, controls and regulatory relationships can arrive with the contract even though the product itself is unchanged. The product hasn't changed. The cost of selling it may have.

Digital Trade Gets Easier but ESG Rules Stay Put October 30, 2026

Then Canada and the EU announce something that sounds promising for exporters. Their Digital Trade Agreement is designed to make electronic contracts, data transfers, signatures and online services easier across the Atlantic. Digitally delivered services between the two markets reached about €19.8 billion in 2025. For a Canadian technology company, parts of the sales process should get simpler.

The ESG rating still has to get past ESMA.

The Canada EU digital trade deal can make contracts, permitted data transfers and online delivery easier for smaller Canadian companies. That can remove friction from how a digital service is sold and delivered across the Atlantic.

If the product is an ESG rating, ESMA's rules still apply. A smoother digital sale doesn't replace recognition, endorsement or any other requirement that applies to the provider itself. The sale may get easier. The regulatory work doesn't disappear.

The FCA Leaves the Score Alone and Goes After the Process November 3, 2026

The UK finally answers the question that had been hanging over ESG ratings for years. It doesn't tell providers to agree. It doesn't choose the right climate model or decide how much governance should count. Instead, it makes providers answer for the work behind the score. Data, methods, conflicts, governance and systems all come under FCA oversight. The opinion can still differ. The provider has to show how it got there.

When a Data Product Becomes an ESG Rating

A company can call itself a data firm, software platform or analytics business. That won't decide whether the rules apply.

Pure data can stay outside the regime. Add an assessment, score or opinion based on ESG factors and the answer can change.

That line gets even more interesting as firms add automated scoring, machine learning and AI generated analysis.

For a Canadian founder, one product update can change more than the feature list. The feature customers want may also be the feature that pulls the product into regulation.

Providers still get to disagree and build different models. One can give climate more weight while another puts more emphasis on governance, and the FCA doesn't try to choose the winner.

What changes is how much of the work behind the score has to stand up to scrutiny. Providers have to explain more about the data, methods, conflicts and controls that produced the result. The rating can stay subjective. The process can't stay hidden.

A Canadian Firm Wins the Customer and Inherits the Rules 2027 to 2028

Now Canada's lighter model meets the export market. A Canadian provider can spend years building under domestic rules, hire a sales team and finally win the overseas client it wanted. Then compliance enters the deal. Britain may require FCA authorisation. Europe may require recognition, endorsement or another permitted path. Lawyers get involved. Controls get added. Contracts change. Someone has to own the relationship with the foreign regulator.

Winning the customer can become the moment the company inherits the regulation.

UK applications begin in 2027. Firms expecting at least £500,000 in ESG ratings revenue over the following 12 months apply first. Smaller providers follow. For a Canadian exporter, the size and timing of the sales pipeline can therefore affect when the FCA application work starts.

A firm serving both the UK and EU can reuse some people, controls and documentation. That should keep the second market from starting entirely from zero, but the two regimes remain separate and each still has its own entry requirements. It can reuse the work. It can't reuse the permission.

When Does Regulatory Divergence Start Costing Canada?

Canada gets a real benefit from staying lighter.

A young ratings or analytics company can spend more of its first dollars on product, hiring and customers instead of building a licence around a market that may still be small.

That works well while Canada is the market.

Then the company wants to scale.

A UK customer can bring FCA requirements into the sales process. A European customer can bring ESMA. The Canadian company starts hiring compliance staff, changing contracts, documenting methods and adding controls that Canada never asked it to build.

Copying the UK or EU isn't an obvious answer either.

A Canadian licence would cost money. Plenty of firms may never need one. Large global providers can spread that cost across thousands of customers. A startup can't.

But staying different isn't automatically free.

If every Canadian firm with global ambitions has to build around foreign rules anyway, Canada's lighter model starts saving less than it first appears.

Canada hasn't crossed that line by law. Some Canadian firms may cross it much sooner.

At what point does regulatory divergence stop saving Canadian firms money and start making international expansion more complicated?

Ottawa hasn't answered that question. Canadian firms trying to sell abroad may answer it first.

What Happens Next?
  • Will FCA and ESMA oversight help smaller providers win business, or make the biggest firms even harder to challenge?
  • How many Canadian firms will build around foreign rules without Canada ever creating its own ESG ratings licence?
  • When does an analytics tool become a rating as founders add scores, rankings and AI generated judgments?
  • Will Canadian exporters start treating UK and EU compliance as the real operating standard even while Canada stays lighter?
  • At what point would Canadian rules make foreign expansion easier instead of simply adding another cost at home?
What Did You Think?

Does Canada's lighter approach give ESG ratings firms a useful advantage, or does that advantage fade once the firms start selling into regulated UK and EU markets?

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NCFA Canada logoThe 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, artificial intelligence, 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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Binance $6.3B Hack and Polymarket Breach Expose Weaknesses

October 30, 2026 | NCFA Story Intelligence | Digital Assets Blockchain And Tokenization, Cybersecurity And Fraud, Competition And Market Structure

AI illustration of Binance $6.3B hack and Polymarket breach illustrated with unauthorized withdrawals, frozen assets, trading halt, vendor breach and customer protection controls.

How two separate security failures exposed weak points in authorization, recovery and digital finance infrastructure

On October 29, 2026, Binance suffered unauthorized withdrawals with an estimated US$6.3 billion impact, while Polymarket suffered a separate third party breach that forced its international prediction market to halt trading. Binance says the attack may have started with a compromised DevOps engineer’s laptop. Polymarket says one of its third party providers was compromised. The Binance hack and Polymarket breach aren’t known to be connected, but both exposed a similar weakness. Neither required the underlying blockchain to fail.

At Binance, the attacker reached systems capable of submitting withdrawal transactions. The exchange says it has found “no evidence of any wallet private key leak.” About US$3 billion has been frozen onchain, and Binance says customers won’t absorb the loss. Deposits are operating normally. Withdrawals remain paused while the exchange rebuilds parts of the withdrawal service.

Polymarket faced a different failure. Its international exchange entered cancel only mode at 2:05 p.m. ET, identified the compromised provider at 2:37 p.m., prepared to resume trading at 2:55 p.m. and marked the incident resolved at 3:05 p.m. Polymarket says “Anyone who has been impacted will be made whole.” The platform is operating again, but full reimbursement of every affected user hadn’t been independently confirmed at the latest verification cutoff.

Binance shows what can happen when attackers reach the systems that authorize money movement. Polymarket shows how hostile code can reach customers through software sitting between them and the market. In both cases, the financial rails could keep processing instructions after the instructions themselves had been compromised.

The Binance Hack Starts Before the Money Moves October 28 to 29

The theft looks almost instant in a headline. It wasn’t. TRM Labs says activity tied to the Binance operation began at least 36 hours before the main withdrawals. Its reconstruction found funding, testing and preparation before most of the money left in roughly 20 minutes starting around 20:05 UTC on October 29.1

TRM attributes the Binance hack with high confidence to North Korea’s TraderTraitor operation. Binance hasn’t made that attribution, and no public law enforcement finding had confirmed responsibility for this attack at the latest verification cutoff.

The money moved in minutes. The operation appears to have been prepared much earlier.

What the North Korea Attribution Actually Means

TRM says its assessment draws on onchain and offchain intelligence and similarities with earlier TraderTraitor operations. The firm points to advance preparation and transaction behaviour that it says match previous North Korea linked attacks.

There is history behind that assessment. In February 2025, the FBI formally attributed the US$1.5 billion Bybit theft to North Korea and identified the activity as TraderTraitor.2

That earlier attribution doesn’t prove who attacked Binance. Binance hasn’t identified the perpetrator. Until law enforcement reaches its own conclusion, North Korea remains an attributed assessment rather than a confirmed finding.

TRM estimates approximately US$6.36 billion moved from Binance wallets across ten blockchains. Elliptic independently calculates about US$6.43 billion.

Binance’s official estimate remains approximately US$6.3 billion. Different pricing times produce small differences, but all three calculations land around the same extraordinary number.

US$6.3 Billion Spreads Across Ten Blockchains October 29

Elliptic estimates roughly US$3.80 billion left through Ethereum based assets alone. Another 18,270 BTC worth about US$1.48 billion moved, together with hundreds of millions of dollars across Tron and other networks.3

This wasn’t one token leaving one wallet. Assets moved across different networks and different forms of money before Binance stopped withdrawals.

The recovery options split immediately. Stablecoin issuers could freeze supported tokens. Bitcoin and ether could be watched moving across public ledgers, but no issuer could switch them off.

The asset the attacker held started determining what Binance could get back.

Where Most of the US$6.3 Billion Went

Elliptic calculates US$3.80 billion on Ethereum, including about US$1.9 billion of USDT and US$823 million of USDC. It also identified 18,270 BTC worth about US$1.48 billion and roughly US$612.7 million of USDT on Tron.

Most of the stolen value therefore sat in a small number of large positions, but those positions didn’t carry the same recovery rights. Tether and Circle could intervene in their tokens. No company could impose the same freeze on native bitcoin.

Token prices can change the dollar value. The control rights don’t change with the price.

Binance Says the Private Keys Didn’t Leak October 29 to 30

Binance’s most surprising technical finding so far is what the attacker apparently didn’t steal. The exchange says it has found no evidence that wallet private keys leaked. Its initial investigation points instead to a compromised DevOps engineer’s laptop that may have opened access to a service container used to submit unauthorized withdrawals.

The investigation has since widened beyond one computer. Binance says the incident involved multiple factors and that its security team is tracing the complete attack path through the withdrawal system.4

Independent investigators go further. TRM believes Binance’s signing infrastructure was compromised. Elliptic reached a similar conclusion after examining signed withdrawals across several chains and prepared authorizations on Ethereum.

Binance has promised a full technical postmortem once the investigation is complete.

If the forensic reconstruction holds, the attacker didn’t need the keys. Reaching the machinery deciding what those keys should sign was enough.

NCFA saw a striking variation of the same problem only weeks earlier. How 4,000 BTC Left Liquid Network Without A Stolen Key showed how nearly an entire reported Bitcoin reserve could leave through an apparently valid process even when the obvious authorization key remained intact.

A compromised employee device can sit several steps away from a private key and still reach systems that decide which transactions get signed.

For an exchange, authorization controls become part of custody whether the private key leaks or not.

The Race to Freeze Billions Begins Minutes After the Theft

Once the withdrawals landed, the attacker started changing the asset mix. Stablecoins such as USDT and USDC can be frozen by their issuers under certain conditions. Bitcoin and ether can’t.

Elliptic estimates roughly US$786 million of stablecoins was converted before freezes took effect. Some swaps were completed at prices well below prevailing market value. Getting out appeared to matter more than getting a good price.

TRM separately traced large USDT conversions into ETH. It also found an attacker wallet using USDT as collateral in Aave to borrow ETH before controls tightened.

The attacker was willing to lose money to hold assets that were harder to stop.

The First Hour Became a Stablecoin Freeze Race

Elliptic says the attacker’s main Ethereum wallet received stolen USDT at 20:24 UTC. Tether froze about US$1.18 billion of USDT 37 minutes later and then followed funds into additional attacker addresses.

Circle froze about US$823 million of USDC in the same main wallet soon afterward. Ripple, World Liberty Financial, Paxos, First Digital and other ecosystem participants also acted on supported assets.

By 08:00 UTC on October 30, Elliptic had independently verified about US$2.84 billion frozen. Binance later put the verified total at roughly US$3 billion. Attack speed and issuer response were competing in real time.

Tether, Circle and other issuers could immobilize supported balances while stolen assets were still moving.

Bitcoin and ether stayed visible but movable. Tracing the money and controlling the money were two different powers.

Frozen Crypto Isn’t Recovered Crypto October 30

The US$3 billion frozen figure sounds like half the money came back. It didn’t.

A frozen stablecoin balance may no longer be movable, but Binance doesn’t automatically possess it again. Returning the asset can still depend on issuer action, legal process and cooperation across companies and jurisdictions.

Investigators can also know exactly where bitcoin or ether sits without controlling it. Binance can separately replace assets from its own balance sheet even while stolen funds remain frozen or under attacker control.

Frozen, recovered and reimbursed are three different numbers.

Binance Recovery Snapshot
Estimated impact
US$6.3B
Frozen onchain
~US$3B
Company resources allocated
US$6.34B+
Final recovery
Not yet known

NCFA visualization. Sources include Binance, Elliptic and TRM Labs. Frozen assets aren’t the same as recovered assets or customer reimbursement.

Binance Puts US$6.34 Billion Behind Customer Losses October 30

Binance then changes the financial story.

The exchange says it has allocated more than US$6.34 billion of company resources to cover the incident. About US$5 billion is already held in affected token assets. Binance says it is buying the remaining assets through market and over the counter channels so the replacement portfolio matches what was lost.5

Those figures don’t include the roughly US$3 billion already frozen.

Binance is replacing its asset position while the recovery effort continues separately. SAFU alone is far smaller than the incident, so protecting customers depends heavily on broader company resources.

A US$6.3 billion hack is now testing Binance’s liquidity, reserves and ability to absorb a loss without passing it to customers.

What Binance Still Has to Replace and Prove

Estimated impact is about US$6.3 billion.

Company resources allocated exceed US$6.34 billion.

Matching affected tokens already held total about US$5 billion.

Remaining replacement purchases are roughly US$1.34 billion.

Frozen onchain stands at roughly US$3 billion and is separate from the company allocation.

The technical postmortem and updated Proof of Reserves are still pending. Those releases should show what failed, what changed and whether customer liabilities remain fully backed after remediation.

Binance Update October 30

“Withdrawals remain paused while our team completes a security revamp.”

Binance says deposits are operating normally and expects withdrawals to resume within 48 hours. View the official Binance update.

Polymarket Breach Halts Trading for One Hour October 29

Polymarket’s breach followed a different path.

Its international exchange entered cancel only mode at 2:05 p.m. ET. At 2:37 p.m., Polymarket said a third party provider had been compromised and the issue was fixed. Trading was prepared for restart at 2:55 p.m., and the incident was marked resolved at 3:05 p.m.

Reuters identified the provider, through a source familiar with the matter, as DebugBear, a website performance monitoring company. DebugBear separately acknowledged its own security incident and advised customers using its Real User Monitoring product to remove the embedded code.6

Polymarket hasn’t publicly named the provider. Its international platform is now operational.

The exchange came back in an hour. Customer recovery took a different clock.

Polymarket Incident Record
2:05 ET
Trading enters cancel only mode and relayer actions pause.
2:37 ET
Polymarket says a third party provider was compromised and the issue was fixed.
2:55 ET
Trading restart is announced.
3:05 ET
The incident is marked resolved.

View Polymarket’s official incident record

How the Polymarket Breach Reached Logged In Traders

Security researchers recovered malicious JavaScript distributed through infrastructure linked to the compromised monitoring service. The code checked whether a Polymarket visitor was already logged in, then examined balances and prediction market positions.7

Depending on the account setup, the script could try to sell positions, transfer position tokens or move cryptocurrency. Researchers didn’t identify a routine whose central purpose was stealing a password, seed phrase or private key. The code reused authority already available inside the authenticated application.

One outside analysis traced the attack path through 710 deposit wallets and 731 addresses, while stressing that the address count doesn’t equal the number of victims. A customer could authenticate correctly and still encounter hostile software after login.

Polymarket hasn’t confirmed a final loss figure or victim count. Outside estimates range from about US$2.2 million to US$2.7 million.

Polymarket says affected users will be made whole. Full reimbursement hadn’t been independently verified at the latest cutoff.

Polymarket Is Hit Through a Vendor Again June to October 2026

October isn’t Polymarket’s first recent third party compromise.

In June, Polymarket confirmed that a compromised outside vendor allowed malicious code into its website for some users. The company acknowledged that funds were stolen and said victims would be refunded in full. Outside researchers estimated losses around US$3 million.8

Four months later, another outside service sits inside another loss event.

The company has also been moving deeper into regulated financial markets. Polymarket Earns Approval to Relaunch in the U.S. followed its return path after acquiring a regulated derivatives exchange and rebuilding access to the American market.

The business is becoming more institutional while its customer experience still depends on monitoring tools, browser code, authentication services and outside software.

Polymarket can decentralize parts of the market without decentralizing every dependency needed to reach it.

The Weak Point Moves Outside the Blockchain 2025 to 2026

The Binance hack and Polymarket breach are separate, but both cut through the old idea that crypto security is mainly about protecting a private key.

In February 2025, attackers stole roughly US$1.5 billion from Bybit. The FBI later attributed the theft to TraderTraitor. Investigators said the attack manipulated the approval process around a legitimate transaction rather than breaking Ethereum itself.

Now Binance says its wallet private keys appear intact while investigators examine the systems around transaction approval. Polymarket’s market also kept functioning while malicious web code allegedly reused authority inside logged in customer sessions.

The blockchain can keep doing exactly what it is told after the instruction itself has been compromised.

Founders and institutions building on digital assets can’t treat security as a wallet problem alone. Employee devices, access rights, transaction limits, supplier controls and approval workflows all sit inside the same chain of trust that protects the assets.

What the Binance Hack Means for Canada October 2026

Five days before the Binance and Polymarket incidents, Canada published proposed Stablecoin Regulations for consultation.

The proposed rules require covered issuers to maintain reserves at least equal to outstanding stablecoins at the end of each day, use qualified Canadian custodians and support redemption at par. They also add governance, risk management, data security, incident reporting, recovery and resolution requirements. Consultation closes December 23, 2026, with implementation intended for fall 2027.9

NCFA’s Canada Proposes Stablecoin Market Entry Rules examines the commercial choices created by that framework. The Binance hack makes one of those choices unusually visible. Stablecoin issuers weren’t passive observers after the theft. Their ability to freeze supported assets changed the recovery picture by billions of dollars.

Canada’s proposed rules don’t govern the Binance or Polymarket incidents, and there is no basis to claim they would have prevented either one.

Canadian banks, PSPs, wallets and fintechs still face the same operating questions. Who can authorize the transaction, who can stop it, which suppliers can touch it and who carries the loss when the control chain breaks?

Binance also carries unusual Canadian context. Binance Left Canada but the Fight Reached Supreme Court traced how the exchange’s Canadian exit became a wider fight over regulatory reach and company records. This security incident tests a different side of institutional credibility. Binance now has to show that its own controls can withstand a failure large enough to move billions.

What Binance and Polymarket Still Have to Prove

Binance hasn’t finished proving the recovery works just because deposits are back. Withdrawals still have to resume without reopening the weakness that forced them to stop. The exchange also needs to show that replacement assets fully support customer liabilities after billions moved out. Its promised postmortem needs to explain how unauthorized withdrawals passed internal controls and what changed before the system reopened.

The updated Proof of Reserves will put numbers behind the customer protection promise. Binance says customers won’t absorb the loss. Reserve data can show whether the assets behind customer balances have actually been restored.

Polymarket isn’t finished once trading comes back either. Affected users still need to be fully reimbursed. Two third party compromises in four months also leave a harder question over the business. **How much outside software should be able to touch an authenticated customer session before the market itself becomes exposed?**

The Binance hack showed that a platform can lose billions without evidence that its private keys were stolen. Polymarket showed that a market can remain technically intact while hostile code reaches customers through a supplier. Stablecoin issuers then froze billions of dollars that native bitcoin and ether issuers couldn’t freeze because no such issuer exists. Binance’s own balance sheet became the backstop after those controls ran out.

That is where the competitive line in digital finance is moving.

The strongest platforms won’t be the ones that simply claim secure infrastructure. They’ll be the ones that can **limit what a compromised employee, supplier or software component can do, stop bad instructions before settlement, isolate losses quickly and carry the financial weight when prevention fails**.

Binance and Polymarket are now being measured on exactly that.

The blockchain may settle the transaction. Trust won’t come from the blockchain alone. It will depend on everything that happens before an instruction reaches the chain and everything a company can still do after something goes wrong.

Frequently Asked Questions

Were Binance private keys stolen
Binance says it has found no evidence that wallet private keys leaked. Its investigation points to a compromised employee laptop, service infrastructure and a wider attack path. Independent investigators believe transaction signing infrastructure was compromised, but Binance’s complete technical postmortem is still pending.
Has Binance recovered the US$3 billion
No. Binance says roughly US$3 billion has been frozen onchain. Frozen assets aren’t automatically returned. Actual recovery can still require issuer action, legal process and cooperation across several institutions.
How did the Polymarket breach happen
Polymarket says a third party provider was compromised. Independent researchers found malicious JavaScript that could interact with authenticated user sessions and attempt to sell positions or transfer assets. Polymarket hasn’t yet published a complete technical postmortem.
How much did Polymarket users lose
Polymarket hasn’t published a final loss figure or victim count. Outside estimates currently range from about US$2.2 million to US$2.7 million. Polymarket says anyone affected will be made whole, but full reimbursement hadn’t been independently confirmed at the verification cutoff.

Related NCFA Intelligence

Digital Asset Security

How 4,000 BTC Left Liquid Network Without A Stolen Key

How nearly an entire reported Bitcoin reserve left through an apparently valid process even though the obvious authorization key remained intact.

Binance

Binance Left Canada but the Fight Reached Supreme Court

How Binance’s Canadian exit became a wider test of regulatory reach, company records and access to digital asset markets.

Prediction Markets

Polymarket Earns Approval to Relaunch in the U.S.

How Polymarket moved back toward regulated US market access after acquiring a licensed derivatives exchange.

Stablecoins

Canada Proposes Stablecoin Market Entry Rules

Canada’s proposed rules put reserves, custody, redemption, data security and recovery directly into the stablecoin operating model.


NCFA Canada logoThe 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, artificial intelligence, 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

NCFA Financial Innovation MapNCFA Innovation Opportunity BriefsNCFA Fintech Insights
NCFA Fintech WhispererNCFA Fintech Fridays PodcastNCFA Weekly Newsletter

 

Cohere Becomes Canada’s Sovereign AI Equity Bet

October 29, 2026 | NCFA Story Intelligence | Capital Markets Infrastructure And Funding, Artificial Intelligence And Data, Competition And Market Structure

NCFA Story – Cohere Becomes Canada’s Sovereign AI Equity Bet

Ottawa Moves From AI Funder to Cohere Shareholder

On October 29, 2026, the Ottawa announced plans to invest up to C$1.6 billion in Toronto based Cohere as part of a Series E financing targeting as much as C$7 billion, putting public money directly into a Toronto company that is trying to build a Canadian and European alternative to the dominant US AI platforms.  The deal would make Ottawa more than a supporter of Canadian AI. It would make the federal government a shareholder in one of the country’s most valuable private technology companies, at a time when Canada is pushing for greater digital sovereignty and Cohere is expanding deeper into Europe and global enterprise markets.

The government says the investment will be made in stages. Cohere must keep its Canadian incorporation and headquarters, create at least 1,000 new Canadian technical jobs by 2030, and commit at least C$1.7 billion to additional computing infrastructure in Canada. Cohere is entering the deal from a much stronger position than it occupied two years ago. Its Series E is targeting up to C$7 billion at a stated C$35.7 billion valuation. Schwarz Group leads the round. NVIDIA, Bell Ventures, Inovia Capital, Prosperity7 Ventures and other investors are participating. Cohere says its annual recurring revenue grew 165% year over year in the third quarter of 2026 and its customer base expanded twentyfold to about 300 customers.1

Ottawa calls this a sovereignty investment. Prime Minister Mark Carney says Canada needs the ability to build, adopt and govern AI on its own terms, while taking equity lets Canadians share in Cohere’s success if the company keeps climbing.

The sovereignty case and the investment case aren’t the same thing. Canada can value domestic AI capacity even if Cohere never becomes a great financial investment. It can also make money if Cohere becomes a much larger global company. Ottawa is now trying to do both.

What follows is a story of a Canadian AI company finding a different lane, moving closer to government, crossing the Atlantic for scale, and returning to a cap table where Canada itself now wants a seat.

Cohere Chooses a Different AI Race 2019 to 2024

Cohere starts in Toronto in 2019 before generative AI becomes a household product. Aidan Gomez brings unusual credibility to the founding team because he helped write the 2017 transformer paper that underpins modern large language models. Yet Cohere doesn’t build its identity around a consumer chatbot. It sells models and developer tools to businesses.

The capital arrives quickly. Cohere says it raises nearly C$1 billion across Series A through D between 2021 and 2024. By July 2024, a US$500 million Series D values the company at about US$5.5 billion. Canuck Startups Cohere and Clio Secure Major Funding Rounds captures the moment when Cohere becomes one of Canada’s most valuable private technology companies.

At the same time, the AI race is getting brutally expensive. OpenAI, Anthropic, Google and Meta are spending heavily on models, compute and distribution. Cohere can keep chasing general purpose scale, or it can make the market smaller and more defensible.

It chooses the second route.

By early 2024, Reuters reports Cohere’s annualized revenue has climbed from about US$13 million to roughly US$35 million by the end of March. The company is growing, but the numbers also show how far it sits from the largest US AI platforms.2

Cohere leans into control instead of reach. Its pitch increasingly centres on private deployment, data security, cloud choice and enterprise customization. The company can compete without needing to win the consumer chatbot popularity contest.

The Enterprise Pivot Starts Paying 2024 to 2025

During the third quarter of 2024, Cohere sharpens the strategy around secure, customized enterprise AI. Reuters later reports that about 85% of its business is coming from private deployments. By May 2025, annualized revenue has passed US$100 million, more than double the level at the start of the year.3

Then Cohere moves higher up the software stack. North turns the company from a model supplier into a workspace and automation platform that can run inside a customer’s own infrastructure. Banks, governments and other regulated organizations can keep more control over where their data sits and how models touch it.

RBC becomes an early Canadian proving ground. RBC and Cohere Partner on ‘North for Banking’ AI Platform follows the effort to build an AI platform around bank data, security and internal workflows.

Cohere has found a market where being smaller can still be useful if customers care more about control than consumer reach.

How Cohere’s Numbers Changed

Reuters reported annualized revenue of about US$35 million by March 2024 and more than US$100 million by May 2025. In September 2026, Reuters reported that Cohere had about US$240 million in recurring revenue for the prior year as it prepared to combine with Aleph Alpha.4

Today Cohere reports 165% year over year ARR growth in Q3 2026 and roughly 300 customers, up twenty times over the prior year. These are strong growth signals, but Cohere still doesn’t publish net income, cash burn or enough financial detail to tell outsiders whether the business is profitable.

The customer list gets heavier. Cohere names RBC, TD Bank, Bell, Fujitsu, PwC and other large organizations among customers. Private deployment gives the company a route into sectors where security, residency and compliance can block consumer oriented tools.

The scale gap hasn’t disappeared. Anthropic reported US$16.29 billion of revenue in the first half of 2026 in its IPO filing, while OpenAI and other US platforms remain far larger in consumer reach and capital commitments.5 Cohere is trying to win a different buying decision.

Ottawa Moves From Watching to Building Around Cohere 2024 to 2025

Ottawa’s relationship with Cohere deepens before it ever buys a share.

In December 2024, the federal government announces up to C$240 million for a Cohere compute project under the Canadian Sovereign AI Compute Strategy. The agreement is finalized in March 2025 as part of a C$725 million project. Cohere becomes an anchor tenant for new compute infrastructure operated by CoreWeave in Cambridge, Ontario.6

Canada Invests $240M in Cohere for AI Data Centre captured the original logic. Canada wanted domestic compute, Canadian data control and enough infrastructure for local AI companies to grow without depending entirely on foreign systems.

Five months later, the relationship moves closer again. Ottawa signs an agreement with Cohere to explore deploying its AI inside the federal public service and to strengthen Canada’s ability to commercialize and export domestic AI.7

Government is becoming funder, infrastructure partner and potential customer before it becomes shareholder.

The C$240 million support is not the same as today’s equity. Federal records describe the earlier deal as a contribution tied to compute expansion. Ottawa gets economic and strategic benefits if the project succeeds, but it does not participate in Cohere’s valuation the way a shareholder does.

Cohere keeps raising privately. In August 2025 it raises US$500 million at a US$6.8 billion valuation. Cohere Raises $500M at $6.8B for Enterprise Agentic AI shows a company still relying on venture, pension and strategic investors while government support sits outside the cap table.

Europe Gives Cohere a Second Home and a Bigger Story 2025 to 2026

Cohere spends 2025 looking beyond Canada for growth. Paris becomes its EMEA base as European governments and companies start talking more openly about dependence on US cloud and AI providers. Cohere Picks Paris as New EMEA Hub For Enterprise AI follows a company that wants Europe to become a real revenue market, not a satellite office.

The strategic leap arrives in 2026. Cohere and Germany’s Aleph Alpha agree to combine and operate globally as Cohere, with leadership, research and headquarters functions rooted in both Canada and Germany. Aleph Alpha brings European public sector relationships and a long running sovereignty pitch. Cohere brings more commercial scale and a broader enterprise platform.8

Schwarz Group commits €500 million in structured financing and plans to run Cohere models through STACKIT, its sovereign cloud business. The owner of Lidl and Kaufland is no longer only a customer or infrastructure partner. It becomes a major financial backer of a Canada Germany AI platform.

Cohere has stopped looking like a Canadian startup expanding abroad. It is starting to look like a transatlantic infrastructure company built around organizations that don’t want one foreign provider controlling their AI stack.

Why Canada and Europe Keep Showing Up in the Same AI Story

Canada became associated with Pillar II of Horizon Europe in 2024, giving Canadian researchers and companies deeper access to collaborative EU research funding. Canada and the EU then signed an AI cooperation agreement following the first Canada EU Digital Partnership Council in December 2025. Canada and Germany also moved ahead with a Digital Alliance focused on AI, digital sovereignty and infrastructure.

Cohere’s European expansion sits inside that wider policy movement. The company’s combination with Aleph Alpha and its STACKIT partnership give the commercial strategy a transatlantic operating base at the same time Canada and Europe are looking for more control over strategic digital infrastructure.

Europe offers customers, public sector relationships and a policy environment that already prizes data control and local infrastructure. Cohere gains another route to market without having to imitate the consumer led strategies of the largest US firms.

Europe also brings competition. France’s Mistral is raising billions around a European AI champion of its own. US platforms are selling aggressively into the same enterprise accounts. Sovereignty creates demand, but it doesn’t hand Cohere the market.

Canada Finally Buys Into the Company It Has Been Building Around October 2026

The latest round changes the relationship again.

Cohere opens a Series E targeting up to C$7 billion at a C$35.7 billion valuation. Schwarz Group leads. Ottawa commits up to C$1.6 billion in equity. The federal investment can therefore represent almost a quarter of the targeted round if it is eventually funded in full.

The company says the round has reached an initial close, but it hasn’t disclosed how much has actually closed or when the round will finish. Ottawa hasn’t disclosed the eventual ownership percentage, share class, voting rights, board representation, liquidation preference, dilution protections or exit terms. Reuters also reports that the size and terms of the government’s stake remain undisclosed beyond the commitment ceiling.9

Carney says the government wants Canadians to have “a share in that success.” Cohere gets capital for models, compute and international growth. Canada gets operating commitments at home and financial exposure to whatever the company becomes next.

Ottawa is no longer only building the market around Cohere. It is buying into Cohere itself.

Something could go very right. If Cohere turns its enterprise and sovereign AI position into a much larger global business, Canada participates in the appreciation instead of collecting only jobs, tax revenue and infrastructure benefits. A future valuation above C$35.7 billion would make equity look very different from another contribution.

The same structure exposes taxpayers to the downside. A private valuation can reset. New rounds can dilute shareholders. Compute spending can consume capital quickly. Cohere may deliver strategic benefits to Canada while still producing a weak investment return. Sovereignty doesn’t erase price.

Ottawa Has Owned Companies Before but This Time Isn’t a Rescue 2009 to 2026

Canada has taken corporate equity before. During the 2009 auto crisis, Canada and Ontario received a combined 11.7% of General Motors plus preferred shares and 2% of Chrysler after providing restructuring support.10 During the pandemic, Ottawa invested C$500 million in Air Canada equity and received warrants as part of a broader financing package. The government later sold the shares and warrants for a combined C$125 million profit.11

Those deals were crisis interventions. Cohere isn’t being rescued from bankruptcy or a pandemic collapse. Ottawa is buying into a private growth company at a rapidly rising valuation because it considers the technology strategically important and wants exposure to the upside.

That happens in the same year Ottawa launches the C$25 billion Canada Strong Fund, its first national sovereign wealth fund. The fund is designed to invest primarily through equity in strategic Canadian companies and projects, alongside private capital, with a mandate to earn market rate returns. Ottawa says it will operate at arm’s length through an independent Crown corporation.12

Two weeks before the Cohere announcement, Industry Minister Mélanie Joly also said Ottawa was considering every option in its dispute with Cleveland Cliffs over Stelco, including possible nationalization. No nationalization decision has been made. The dispute is separate, but ownership has clearly moved back into Canada’s industrial policy vocabulary.13

Canada is experimenting with ownership at the same time it is trying to become more sovereign, more competitive and less dependent on foreign strategic infrastructure.

Where the Horse Picking Risk Enters

Direct equity gives government upside that grants and contributions do not. It also forces someone to choose which companies deserve public capital, at what valuation and on what terms.

The Canada Strong Fund is being designed with an independent board, professional management and an arm’s length mandate partly to separate investment decisions from day to day politics. The Cohere announcement does not yet disclose which federal entity will hold the shares or the governance process used to price and approve the investment.

Private investors can walk away from a deal if the price or terms don’t work. Public capital also carries strategic objectives such as jobs, sovereignty, infrastructure and domestic control. Those goals can strengthen an investment thesis, but they can also make it harder to tell whether a weak financial return was accepted for a broader policy benefit.

Canada’s new Canada Launches $1.75B Venture and Growth Capital Plan mostly uses public money to attract private investors through funds and managers. Cohere is a far more concentrated position in one company.

The price is already much higher than it was last year. Cohere raised at a US$6.8 billion valuation in August 2025. The new round points to C$35.7 billion after a year of product growth, acquisitions, European expansion and the Aleph Alpha combination. Ottawa is buying after the story has already moved.

Canada Now Owns Both Sides of the Bet

Cohere gives Ottawa a rare chance to test two ideas at once.

The first is strategic. Canada wants more control over the AI systems that governments, banks and other critical organizations may eventually depend on. Cohere’s architecture, Canadian roots and Europe strategy fit that ambition better than handing every sensitive workload to a foreign hyperscaler or consumer AI company.

The second is financial. Instead of paying only for infrastructure, research or jobs, Ottawa wants equity. If Cohere becomes one of the few globally important enterprise AI companies outside the United States and China, taxpayers own part of the upside.

The company has earned a stronger hand than it had two years ago. Revenue has grown, the customer list has widened, North has moved into production environments, European expansion is real, and Schwarz Group has put capital and infrastructure behind the transatlantic strategy.

There is still plenty the public can’t see. Cohere doesn’t disclose net profit or cash burn. Ottawa hasn’t published the ownership percentage or shareholder protections. Nobody outside the deal can yet judge whether C$35.7 billion is an attractive entry price for taxpayers.

Canada may be right about the strategic asset and still have to prove it bought the asset well.

The investment becomes more interesting if Cohere keeps compounding from here. It becomes more difficult if the company needs repeated public support, the valuation falls, or strategic goals start masking weak investment performance.

Cohere has spent seven years trying to prove a Canadian AI company can scale without becoming another US platform. Ottawa has now put C$1.6 billion behind the next chapter.

If Canada wants to become an owner of national champions, Cohere will help show whether it can act like one.

Questions Still Sitting on the Cap Table

What does Canada actually own

The government has announced an equity commitment of up to C$1.6 billion, but it hasn’t disclosed the ownership percentage, share class, voting rights, board rights, liquidation preference, dilution protections or exit terms. Those details are needed before the investment economics can be judged properly.

Is Cohere profitable

Cohere reports rapid ARR and customer growth, and Reuters has reported strong margins around its private deployment strategy. The company does not publicly disclose net income, cash burn or complete financial statements, so profitability cannot be confirmed from public information.

What happens if Cohere misses its Canadian commitments

Ottawa says the equity will be invested in stages with regular reporting on jobs and Canadian investment. The public announcement does not disclose the consequences for missed milestones or whether later stages can be withheld.

Is Cohere the start of a wider ownership strategy

Ottawa has not said the Cohere structure will become a standard program. The Canada Strong Fund does point in the same direction by making commercial equity ownership a larger part of federal economic policy. Cohere may become an early test of how those strategic and financial objectives work together.

Related NCFA Intelligence

Capital Markets

Budget 2025 Accelerates Fintech, AI, and Capital Growth

How federal AI infrastructure and growth capital policy started converging before direct Cohere equity arrived.

Competition

Canada Adds Competitiveness to Federal Regulation

A wider look at Ottawa’s push to put competitiveness more directly into federal economic and regulatory decisions.

Security

National Security Is Now Part of Financial Supervision

Why sovereignty, infrastructure control and national security are moving deeper into financial and technology policy.

AI Adoption

Why AI Investment Is Missing What Workers Actually Want

A reminder that capital and technical capability still have to translate into adoption, useful work and measurable outcomes.


NCFA Canada logoThe 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, artificial intelligence, 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

NCFA Financial Innovation MapNCFA Innovation Opportunity BriefsNCFA Fintech Insights
NCFA Fintech WhispererNCFA Fintech Fridays PodcastNCFA Weekly Newsletter