Karsten Wenzlaff, Advisor
August 26th, 2025
Consultation | Sep 30, 2025

Image: Freepik/prostooleh
On September 25, 2025 the Canadian Securities Administrators (CSA) released for comment a proposal to harmonized Self-Certified Investor Prospectus Exemption (See: Notice and Request for Comment on Multilateral Instrument 45-111) that aims to replace a patchwork of provincial exemptions with a framework that makes it easier for more Canadians to participate in private markets and businesses to raise capital.
The comment period runs until January 5, 2026, giving NCFA members and stakeholders the opportunity contribute to one of the most important reforms for retail investor access in years.
The new rule would harmonize exemptions across multiple provinces and territories, replacing existing orders that had created pilot programs in each province. It sets an across the board investment cap of $50,000 per calendar year that can be spread across multiple issuers.
By consolidating exemptions into a single instrument, the CSA hopes to reduce legal and compliance duplication that has added cost and complexity for issuers.
This proposal builds on a broader modernization trend in Canada’s markets, including reforms such as the expansion of the Listed Issuer Financing Exemption (LIFE), which NCFA has reported as a material change for retail access to public capital raising.
Ontario has been one of the provinces piloting the model through Ontario Instrument 45-507 Self-Certified Investor Prospectus Exemption. The criteria in that order provide a clear picture of who could qualify:
To participate, an investor must complete both a Confirmation of Qualifying Criteria and an Acknowledgement of Risks form, certifying they understand the nature of exempt market securities and the absence of prospectus protections.
Notably, the Ontario pilot set the limit at $30,000 annually across issuers, while the new CSA proposal raises this cap to $50,000 across multiple jurisdictions. For the full consultation record, see the CSA Multilateral Notice for MI 45-111.
The combined effect of the newly harmonized rule would open up private markets to knowledgeable professionals who may not meet accredited investor wealth thresholds.
This includes financial analysts, accountants, valuators, and lawyers with corporate finance experience, as well as entrepreneurs and senior executives who have led companies in sectors where their industry knowledge helps them evaluate business risk. By broadening access, the exemption is intended to channel new pools of informed capital into early stage and growth businesses.
The CSA consultation does not provide any projections on the number of new investors or volume of new capital inflows that may result from these changes, and Ontario’s pilot program didn't publish any participation data. However, harmonization is expected to expand the eligible investor base and reduce administrative burdens on issuers.
For startups and small businesses, this can lower the cost of fundraising and increase the number of investors able to participate.
For investors, the proposed exemption enables participation based on knowledge and experience rather than wealth, while maintaining safeguards such as certification requirements and annual limits.
The proposed change is part of a wider trend of policy changes aimed at growing early stage financing in Canada, including Ontario's interim class orders that support early stage capital formation. More transparent reporting on participation and capital raised will be important for assessing outcomes and balancing investor protections over time.
Canada has long faced criticism for fragmented securities rules that make capital raising inefficient. By harmonizing exemptions across multiple provinces and territories, the CSA is addressing structural barriers that have limited access to early stage funding. If adopted, Multilateral Instrument 45-111 would give more Canadians the ability to participate in investment growth opportunities while providing businesses with a clearer path to attract more capital.
The comment period deadline is January 5, 2025. NCFA encourages its community to participate in this consultation by reviewing the CSA consultation materials, consider operational and investor protection details that should be refined, and submit data-driven and/or evidence-based feedback to regulators.
For background on Ontario’s pilot approach, see NCFA’s coverage of the OSC pilot self-certified investor exemption which provides additional context on the origins and mechanics of the model in Ontario. Also for further context, see the CSA consultation news release.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create aa 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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AI | Sep 29, 2025

Image: Freepik AI
On September 24, 2025, Canada's AI darling Cohere announced a second close to their latest round with an additional $100M added to their coffers, valuing the company at approx $7B, positioning the company at the center of secure enterprise deployments while Ottawa launched a 30 day consultation to reset the national AI strategy.
Cohere’s new funding builds on traction with its Command A models and the North platform, both designed for private solutions across finance, healthcare, and government.
Alongside the capital, the technical story is about compute diversity. On September 24, 2025, AMD and Cohere expanded their global AI collaboration for enterprise and sovereign deployments while also adopting North internally. The widens buyer choice and lowers total cost of ownership for organizations handling sensitive data.
Cohere’s Nick Frosst said customers now have ‘significantly greater flexibility’ in how they use Cohere’s AI, while AMD’s Vamsi Boppana noted they benefit from better cost efficiency and energy performance.
On September 26, 2025, the federal government launched an AI Strategy Task Force with a 30 day consultation window from October 1-31 to set priorities around safety, sovereignty, and procurement readiness, with the goal of moving quickly toward digital sovereignty and economic adoption.
Hon. Evan Solomon, Minister of Artificial Intelligence and Digital Innovation and Minister for FedDev Southern Ontario:
“The Government of Canada is moving quickly toward our vision for AI and digital sovereignty. The AI Strategy Task Force and the ideas gathered through our national sprint will generate bold, pragmatic and actionable recommendations to guide Canada’s next AI strategy. This strategy will accelerate the development of nation-building AI and data infrastructure, drive economy-wide adoption and help build the strongest economy in the G7.”
FedNor confirmed $595,400 across three projects in Northern Ontario, spanning powerline mapping, healthcare automation, and First Nations training. One example is a $500,000 repayable contribution to CircuitIQ for a live powerline mapping tool, which will support hospitals and transport infrastructure. The same program provides $67,200 for Waive to automate healthcare forms and $28,200 for Ontario First Nations Technical Services Corporation to prepare training for more than 50 communities.
PwC Canada’s Value in Motion analysis projects that if Canada accelerates AI adoption, the economy could reach $3.65T by 2035 (up from $2.89T in 2023). The study stresses that faster uptake depends on capital investment, access to compute, and clear policy direction the very areas now in motion with Cohere’s new funding, AMD’s infrastructure partnership, and Ottawa’s task force.
The alignment of capital, computing power, and policy confirms that Canada’s AI story is entering an execution phase. Growth and success will depend on measuring real productivity gains in the near term."
For institutions that handle sensitive data, having more choice in computing power and proven enterprise models lowers risk and gives them more leverage. For policymakers, the inclusion of regional funding shows that AI adoption isn't just an urban story.
For fintechs, October is the time to prove that their models are reliable, that data stays in Canada when required, and that costs are clear enough for procurement teams to sign off.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create aa 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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Regulation | Sep 24, 2025

Image: Freepik
On September 13, 2025, Thailand froze approximately 3 million bank accounts in a sweeping anti-scam campaign. Authorities targeted around 177,000 mule accounts linked to fraud. Wisit Wisitsora of Thailand’s Digital Economy and Society Ministry stated:
“We urge the public not to panic. The suspension is only temporary.”
Banks imposed daily transfer caps ranging from 50,000 to 200,000 baht (approx. $2164 CAD - $8657 CAD at today's forex rates) and froze flagged transactions.
Commercial banks could suspend funds for three days, with police empowered to extend freezes up to seven days. While designed to curb online fraud, many individuals and small businesses described being locked out of their only source of funds, leaving households unable to pay for food or bills.
Facing backlash, regulators introduced safeguards. Innocent users can now expect restoration within hours to one day. Banks are required to notify customers of freezes via SMS or mobile banking and to unfreeze wrongly blocked funds proactively. Officials emphasized that disputed amounts are suspended, not entire balances.
Around the world, regulators from the EU to the U.S. and Canada are grappling with similar challenges as regulators expand digital fraud controls. What the Thailand case shows is that the credibility of financial systems depends not only on the strength of anti-scam tools but also on transparent safeguards.
If freezes become a blunt instrument, they risk driving people out of regulated channels and weakening financial inclusion. For fintechs and policymakers, the global lesson learned is that fraud prevention must be paired with due process to preserve trust.
Fraud-related losses in Thailand exceed 6 billion baht annually (approx $200M CAD), but freezing millions of accounts without due process undermines trust in banking.
"The Thai case clearly shows the risk when rapidly scaled enforcement collides with consumer rights. Without transparent criteria, real-time notifications, and clear appeals, innocent users face financial harm."
Legal experts warn this could expose authorities to civil claims and property rights challenges. What if citizens turn to cash, crypto, or unregulated channels instead?
Canada faced a similar backlash during the 2022 trucker protests, when the government invoked the Emergencies Act and froze over 200 bank accounts containing nearly $8M CAD without court orders. The measures were lifted within days, but the incident triggered several knee jerk reactions and lasting debate about transparency, due process, and the role of financial institutions in enforcing emergency powers.
Similar debates are underway in other regions, such as the United States with proposals like the Fairness in Banking Act, which NCFA has examined for its consumer protection impact. The common challenge is ensuring that stronger enforcement powers don't override due process or weaken trust in financial systems.
Both the Thailand crackdown and the Canadian freeze highlight how well intentioned interventions can spiral into government overreach if consumer safeguards are weak. Independent oversight, transparent criteria, communication protocols, and effective redress mechanisms are essential.
As fintechs use AI to spot fraud, regulators need to keep rules fair and accountable. Protecting consumers while keeping trust in financial services is key to Canada’s future growth and inclusion.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create aa 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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Cybersecurity | Sep 23, 2025

Image: Freepik/DC Studio
On September 18, 2025, researchers at Radware disclosed a zero click indirect prompt injection called ShadowLeak that caused ChatGPT Deep Research to leak Gmail data after it encountered a booby trapped email. It's a new class of risk where hidden instructions can manipulate agents while being invisible to users, so NCFA wants to ensure that fintechs and key stakeholders are aware of how attackers can turn AI helpers into data thieves in a way that users including developer's can't see.
Radware’s analysis shows that the leak originated from OpenAI’s own cloud infrastructure rather than a user’s device. A malicious email carried hidden HTML instructions such as white text on a white background. When the user later asked the agent to summarize emails, the agent followed the invisible prompt and sent private details to an attacker controlled URL.
Because the action happened in the cloud, the victim’s network defenses never saw it.
The researchers warned that the same trick could work on other connectors including Google Drive, Dropbox, Outlook, calendars, and GitHub. That means sensitive business data such as financial contracts, HR records, and meeting notes could also be exposed.
Radware reported the issue on June 18, 2025. OpenAI deployed fixes by early August and closed the case on September 3. An OpenAI spokesperson told Recorded Future News that the company continually improves safeguards against exploits like prompt injections.
ShadowLeak is not the only case of an AI agent being manipulated into acting against its user.
At Black Hat in August 2025, researchers demonstrated an attack called AgentFlayer that used a poisoned Google Drive document to leak secrets through ChatGPT connectors. The document contained hidden instructions that looked harmless to a person but were machine readable. When the agent processed the file, it followed the malicious prompt and attempted to extract sensitive data.
On August 20, 2025, security researchers at Brave (website browser company) disclosed a similar flaw in Perplexity’s Comet browser. They showed how a hidden Reddit prompt could read Gmail one time passcodes and expose them to an attacker.
On September 13, 2025, Tom's Hardware wrote about a malicious Google Calendar invite method could steer ChatGPT agents with connectors enabled to leak sensitive data, again by embedding hidden instructions in content that appears ordinary to the user.
From Radware’s advisory and government sources such as the U.S. National Institute of Standards and Technology, here are some suggested practices.
AI agents are being connected to sensitive systems at a time when fintech firms face increasing scrutiny over privacy and security.
If a connector exploit can quietly leak contracts, loan records, or customer identifiers, the implications are massive, such as regulatory fines, reputational loss, and reduced trust from partners and investors.
In Canada, where regulators are preparing rules on open banking and digital identity, firms cannot afford to treat agent security as an afterthought. Research shows that 57% to 80% of injection attempts succeed when attackers repeat them (i.e. 25 times), which is why layered defenses are essential.
Banks and financial technology firms must implement agent safeguards into compliance frameworks, risk models, and vendor contracts that will protect customer trust and reduce liability. Canadian fintechs should approach agent security not only as a technical concern but part of core competitiveness functionality.
Board oversight is also critical, as regulators and investors will expect firms to demonstrate how they manage AI risks.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create aa 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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