Karsten Wenzlaff, Advisor
August 26th, 2025
Nov 12, 2026

Buying a Canadian money services business starts with identifying what the buyer will acquire: a legal entity, a registration history, contracts, records and possibly an active operation. The value of that package depends on whether it supports the services the new owner intends to provide.
A FINTRAC registration entry is an important starting point. It does not establish the company’s financial condition, the quality of its compliance programme or the availability of banking relationships after an acquisition. A payment business may also need a separate assessment under the Retail Payment Activities Act, or RPAA.
For investors evaluating a Canadian MSB company for sale, due diligence should connect registration status, actual activities, transaction structure and financial evidence before the parties agree a completion timetable.
Begin with the target’s exact legal name, incorporation details, registration number and current status. Match the entity in the corporate documents to the entity in FINTRAC’s Money Services Business Registry.
FINTRAC explicitly states that registration does not mean it endorses or licenses a business. It also states that it does not issue licences or certificates of registration. A sales presentation using the phrase “FINTRAC licence” should therefore be clarified against the actual registration record.
The registry distinguishes registered, expired, ceased and revoked statuses. FINTRAC says it updates the registry monthly, so record the date of the check and obtain relevant recent correspondence from the target as well. Where a renewal is being processed, review the submission evidence and the applicable status treatment.
Registration is not a complete acquisition report. The next step is to establish what the company has actually done and what the buyer intends to change.
A buyer researching a Money Service Business in Canada should define the intended services before treating an existing company as a suitable launch vehicle.
Describe the customer groups, countries, currencies, delivery channels and movement of funds. For a crypto-related product, specify where conversion, custody, fiat collection and payouts occur, and which entity provides each service.
Compare that description with the target’s registration information, existing contracts and operating records. A business registered for certain activities may have little or no transaction history, while an active operator may have obligations and unresolved cases that require a detailed handover.
FINTRAC’s guidance requires registration information to be kept up to date and changes to be notified within 30 days. It also states that registration is valid for two years and must be renewed before expiry. Identify the updates and renewal work relevant to the proposed transaction.
The deal’s structure needs its own assessment. Ask Canadian counsel to determine the consequences of buying shares, purchasing assets or changing the entity through which services will be provided.
FINTRAC registration and Bank of Canada payment-service-provider registration address different requirements. Determine the target’s position under each framework.
The Bank of Canada’s registration guidance sets out four elements: performing a payment function as a service that is not incidental to another business; undertaking the relevant retail payment activity; meeting the geographical scope; and falling outside applicable exclusions.
Its identified payment functions include maintaining an end-user account, holding end-user funds, initiating electronic funds transfers, handling payment instructions and providing clearing or settlement services. The assessment concerns the actual functions and circumstances.
Ask advisers to map who performs each function in the target’s payment chain. The presence of a bank or another registered provider does not, by itself, settle the target’s own position.
For a product marketed as crypto-focused, examine its fiat payment activities as part of that assessment. Keep the conclusion and its reasoning in the transaction file, alongside any Bank of Canada application, registration or correspondence.
For a target that is a registered PSP, the transaction timetable may depend on RPAA acquisition-of-control requirements.
The Bank of Canada’s supervisory policy explains that, where the section 24 requirement applies, the target PSP must submit a new registration application reflecting the planned acquisition and become re-registered before completion. Simply filing an application does not satisfy the requirement to be re-registered.
The acquisition-of-control assessment depends on the transaction and legal structure. Counsel should also assess the applicable exclusions and any prescribed-change rules rather than treating every purchase as identical.
Build the required process into the agreement and completion plan. Identify who prepares the application, which information the buyer must supply and what evidence will permit the parties to close.
The Bank cautions that review timing varies and should not be expected to accelerate because an application was submitted too late. Commercial deadlines should allow for that dependency.
This is a distinct process from updating FINTRAC information. Keep the two workstreams visible, with separate owners and completion evidence.
A compliance manual shows intended procedures. An acquisition review also needs evidence of how the programme has operated.
FINTRAC’s compliance-programme guidance requires an effectiveness review at least every two years. The review tests the relevant programme elements, including policies and procedures, risk assessment and training. Request the review plan, results, findings and documented follow-up.
Then assess the records behind the programme through an appropriately controlled diligence process. Relevant requests may include:
Sensitive reports and investigations need legally appropriate disclosure arrangements. Do not assume that every record can be freely copied into a buyer’s data room.
For a dormant company, establish which processes must be activated or updated before customers can be served. For an active business, identify the cases and responsibilities that will remain open at completion.
Translate the findings into resources: staff time, external assistance, system work and the effect on launch readiness.
Financial due diligence should explain what the business earns, what it owes and which cash is available to support operations.
Separate the value of customer transactions from earned revenue. Reconcile fees and conversion income to accounting records and provider statements, with clear treatment of refunds, reversals and other adjustments.
For an active target, examine customer balances and pending transactions alongside the corresponding assets and provider records. Investigate differences before agreeing the completion position.
Useful questions include:
An illustrative target could report growing payment volume while retaining little contribution after provider charges and staff handling. The buyer needs the supporting records to understand the economics.
Customer funds should not be counted as unrestricted acquisition funding. Establish the applicable treatment of balances and liabilities with the transaction’s financial and legal advisers.
Bank accounts and integrations are valuable only within the conditions under which they can be used.
Review material bank, payment, custody, software and outsourced-service contracts. Identify notification, consent, due-diligence and termination provisions relevant to ownership, management or business-model changes.
Obtain the necessary partner assessment for the intended customer groups and flows. Keep a technical integration, an active contract and acceptance of the new business model as separate items in the diligence record.
Technology handover should cover:
Ask the future operating team to demonstrate a representative transaction and an exception. Their ability to locate the relevant records can reveal whether the buyer will inherit a usable process or significant reconstruction work.
The diligence outcome should be a decision supported by evidence and a plan for unresolved dependencies.
Before signing, establish the target’s identity, registration position, service scope, financial condition and material partner dependencies. Identify the regulatory and contractual processes that affect completion.
Before closing, refresh evidence that could have changed. Confirm required registration outcomes, agreed partner actions, access deliverables, financial adjustments and ownership of open work.
Ask transaction counsel to address material findings through suitable agreement terms. Depending on the issue, this may involve pre-completion actions, warranties, indemnities, transition assistance or another negotiated mechanism.
Keep the operating budget connected to the timetable. A delay in a required registration process or partner decision can extend fixed costs while postponing revenue. Model that scenario before committing the full acquisition budget.
A Canadian MSB acquisition becomes easier to assess when its legal status, operating evidence and financial position are reviewed together. The objective is to know what the buyer can continue, what must change and what needs to be resolved before capital and control pass.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, 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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November 11, 2026 | NCFA Fintech Market Insight | Artificial Intelligence And Data, Capital Markets Infrastructure And Funding, Risk Compliance And Regtech

On November 11, 2026, Bank of England Financial Policy Committee external member Jonathan Hall used his final FPC speech to examine what happens when AI agents get more authority inside financial firms. A Bank of England and FCA survey of 196 firms found that 80% already deploy AI agents and another 14% plan to within 12 months. Only 2% reported agents with broad autonomy, and none of those were in trading and payments. Finance is adopting agents quickly, but firms are still keeping people and hard limits around the decisions that can change money, positions or customer outcomes.
The 2026 Bank of England and FCA survey separates four levels of authority:
Among respondents, 80% reported decision support agents, 46% constrained execution and 22% conditional autonomy. Broad autonomy was just 2%. Trade and execution was much lower at 7%, 5%, 1% and 0%.
Payments came in at 7%, 5%, 2% and 0%. Even after planned deployments are included, no more than 9% expect agents within the next year to execute trades, approve customer outcomes, initiate or block payments, or change financial limits and controls.
Canadian firms are already testing that boundary. Questrade MCP lets selected customers give an AI agent access to approved brokerage and market data and prepare an order. The customer still has to approve the trade before it is submitted, so it's not autonomous trading. It's a live example of a financial company giving an agent useful access without handing over final authority.
Thousands of agents using similar technology can become a market risk. The survey found that the three largest cloud and compute providers account for 79% of reported provider relationships. The three largest model API and hosting providers account for 54%.
Several banks, funds or trading firms could use different applications while relying on the same models, cloud providers or data. If those agents read the same market conditions and respond by selling assets, reducing exposure or pulling back liquidity at roughly the same time, many individually reasonable decisions could hit the market together.
Hall focuses on three things. How concentrated are the firms providing financial services? How similar is their behaviour in normal markets? How similar does it become when markets are under pressure? On whether AI will increase that concentration or correlation, he says “at this point we don’t know, but there is a risk that it will.”
Currently, AI agents are not currently causing market wide instability at scale. The concern comes from growing adoption, common technology providers and the possibility that greater autonomy could make reactions faster and more alike. The Bank of Canada’s 2026 Financial System Survey found that nearly all respondents use AI, mostly at limited or moderate levels, and continue to rely on human judgment for decisions carrying significant financial, legal or reputational consequences.
Project Logos is testing the behaviour regulators cannot yet observe at scale in live markets. The BIS Innovation Hub, Bank of England and Deutsche Bundesbank are building a simulated financial market where traditional rules based portfolio managers operate beside LLM based agents. Investor agents allocate capital while both groups make portfolio decisions over time.
Researchers can then quantify whether AI portfolio managers respond differently from traditional automated strategies, whether small changes in models or prompts alter their decisions, and whether their behaviour becomes more correlated when markets deteriorate. Project Logos remains ongoing.
Hall also mentions laboratory research where agents developed unexpected group behaviour, including collusion, and a separate experiment where agents communicated after encountering blocked tasks. Those results show that multi agent behaviour can produce outcomes that were not explicitly planned. They don't however show AI agents colluding in live financial markets.
Further, financial market rules already prohibit manipulation, which can make detection harder if agents learn to coordinate indirectly through price, volume, timing or rapid trading. Hall specifically raises tacit collusion and momentum ignition as behaviours that may be difficult to control through permissions alone.
Companies don't need to wait for autonomous trading to become common before tightening controls. The practical starting point is to separate an agent’s capability from its authority. A model may be able to initiate a payment, change an account or place an order. That doesn't mean the company should give it permission to do so.
Hall calls for unique agent identities, narrow access, secure credentials, transaction limits, sandboxing and monitoring. Those controls let a firm identify which agent acted, restrict the systems it can reach, cap what it can do and revoke access when something goes wrong. Firms remain responsible for the agent’s actions.
OSFI’s July 2026 agentic AI guidance tells Canadian financial institutions to give agents unique identities, limit what they can access, require approval for higher risk actions and keep records of what each agent does. OSFI also wants firms to test failures and outages, understand which outside services support critical work and keep manual backups when those services fail.
AI Agents Expose Weak Links in Financial Authorization shows how the same problem plays out across financial systems. One task can pass through an AI model, cloud service, API, bank, custodian or payment system. Each system that can change money, ownership or customer instructions needs to know what the agent is allowed to do and who approved it.
Companies also need to know whether their AI suppliers are really independent. Two vendors can look separate while relying on the same model or cloud provider. A firm may have strong controls inside its own business and still depend on the same outside infrastructure as competitors and counterparties.
Financial firms should treat AI autonomy as an authorization decision, not a software feature. Start with the job the agent needs to perform, give it only the data and tools required, cap financial actions and require another approval before higher impact decisions change money, ownership or customer outcomes. Record what the agent does, test how it behaves when systems fail and keep a manual way to stop or complete critical work.
The same review should cover outside dependencies. Know which models, clouds and APIs support important workflows and where several suppliers depend on the same infrastructure. An agent can work exactly as designed inside one company and still add to market stress if many firms use similar technology and react the same way at once.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, 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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November 9, 2026 | Story Intelligence | Capital Markets Infrastructure And Funding, Digital Assets Blockchain And Tokenization

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.
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.
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 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.
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 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.
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.
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.
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 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.
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 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.
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.
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.
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.
Tokenized stocks can now reach investors through several routes.

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.
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.
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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The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, 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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November 9, 2026 | NCFA Story Intelligence | Risk Compliance And Regtech, Cross Border Payments And FX, Digital Assets Blockchain And Tokenization

On November 6, 2026, eight Canadian money services businesses appeared on a U.S. sanctions list. Every one of them had a Canadian MSB registration number.
That number meant the business had entered Canada's federal registration system. It didn't mean FINTRAC had approved the firm, cleared its customers or vouched for every transaction passing through it. Until November 6, that distinction could sound technical.
Then the U.S. Treasury allegations arrived. Treasury says several of the eight firms converted cash or conventional currency into digital assets that reached sanctioned Iranian exchanges, addresses associated with the Islamic Revolutionary Guard Corps and, in some cases, wallets tied by U.S. authorities to Canadian drug trafficker Ryan Wedding.
The firms had Canadian addresses, Canadian corporations and Canadian registration numbers. Now they also had OFAC designations.
The same day, FINTRAC coordination with OFAC and FinCEN became public. Then Canada's financial intelligence agency disclosed what had been happening inside its own MSB regime during 2026: 161 registrations revoked, more than $198 million in penalties against nine MSBs, and 28 MSB non compliance matters sent to law enforcement.
FINTRAC didn't say that the eight OFAC firms were among those revocations, penalties or referrals. Canadian disclosure rules generally prevent it from making that connection public unless the law allows it.
But the sequence is hard to miss. Canada had already spent years strengthening Canada's tightening AML rules around MSBs, crypto, ownership and financial reporting. Now eight registered Canadian businesses were inside a U.S. sanctions action, and Canada's financial intelligence agency was confirming that it helped.
This is a story about what a registration number can prove, what it can't prove, and what happens when the transactions behind it reach sanctioned networks abroad.
Canada requires money services businesses to register with FINTRAC so authorities know who's operating, who controls the business and what services it offers. The registry brings firms into view, but it doesn't certify what happens inside every transaction.
That distinction had already surfaced before November. In September, Maple Digital and the TGR network raised questions about how much an active registration can really tell a bank or counterparty. There was no finding that Maple itself laundered money, but corporate and personnel connections showed why a FINTRAC number couldn't settle questions about directors, related companies or sanctions exposure.
FINTRAC MSB registration rules make the boundary clear. Registration is not a licence, endorsement or certification.
A registration number confirms that a business met the legal requirements to enter the MSB registry. It doesn't certify every customer, counterparty, wallet, source of funds or sanctions control used by the firm.
FINTRAC can later revoke registration if a business becomes ineligible or fails to meet registration obligations.
The eight firms designated by OFAC had Canadian registration numbers, corporate identities and physical addresses. Some operated from Vancouver, Toronto, North York, Richmond Hill, Thornhill and Montreal.
Those registrations told counterparties the businesses had entered Canada's MSB system. They didn't establish what customers were doing through the firms or where every transaction ended.
Iran connected transactions don't enter this story as ordinary transfers. Canada already requires reporting firms to treat them as high risk.
By July 2026, Canada's Iran AML controls still required enhanced checks covering identity, source of funds or virtual currency, beneficial ownership, recordkeeping and possible sanctions evasion. The warning was already built into the system before Treasury named the eight Canadian firms.
FINTRAC's Iran directive requires reporting entities to treat transactions originating from or bound for Iran as high risk.
Firms must verify clients, examine the source of funds or virtual currency, establish the purpose of the transaction and obtain beneficial ownership or control information where required. They're also expected to pay particular attention to possible sanctions evasion.
Earlier that summer, sanctions on Iranian crypto exchanges included Nobitex, Wallex, Bitpin and Ramzinex. Aban Tether Exchange and Shelbit later joined the sanctions record.
By November, several of those names appeared again in Treasury's allegations involving Canadian MSBs. The counterparties weren't unknown names at the far end of a payment chain anymore.
OFAC now names eight Canadian businesses under Executive Order 13902. They look different on paper, but they share one uncomfortable fact: each had entered Canada's MSB registry before U.S. authorities placed it inside an Iran sanctions case.
1380079 BC Ltd, also identified as Amin Exchange Vancouver and Sarafi Amin. OFAC lists locations in North Vancouver and Montreal and MSB registration M23258996.
2397639 Ontario Ltd, operating as Farah Exchange in North York. OFAC lists MSB registration M19648033.
B Galaxy Inc, also identified as Cryptoyal and C Exchange, with addresses in North York and Thornhill. OFAC lists MSB registration N300001022.
CCC Inc, also identified through names including Ccurrency Exchange, Sarafi C, Cryptoyal and C Exchange. OFAC lists MSB registration N300000785.
Darvish Exchange, also identified as Kanata MD Inc and Canada Exchange, with Richmond Hill and North York addresses. OFAC lists MSB registration N300000169.
Diverse Trade Inc, operating as Million Exchange, Million Money Exchange and Millionex, with addresses in Richmond Hill, Toronto and Montreal. OFAC lists MSB registration M19315656.
NIA Nations Currency Ltd, also identified as NIA Exchange and NIA Nations Exchange, with Vancouver and North Vancouver addresses. OFAC lists MSB registration M21153461.
Top PC Technician Inc, also identified as 2840711 Ontario Inc, Amin Exchange Toronto and Aminex Toronto, with North York and Thornhill addresses. OFAC lists MSB registration M21487848.
OFAC's published TRON addresses also give exchanges and compliance teams blockchain identifiers associated with several of the designated firms.
Treasury alleged that NIA Nations dealt with addresses associated with the IRGC and with Nobitex, Wallex, Ramzinex and Bitpin. Darvish Exchange allegedly dealt with Nobitex, Wallex, Aban Tether Exchange and Shelbit.
Farah Exchange allegedly dealt with Shelbit and Wallex. Amin Exchange allegedly received hundreds of thousands of dollars from Shelbit. These weren't generic country risk warnings anymore. Treasury was attaching named Canadian firms to named counterparties.
Then another thread appears. Treasury also alleges that some of the same Canadian MSBs handled proceeds connected with Ryan Wedding, the Canadian former Olympic snowboarder accused by U.S. authorities of running a multinational cocaine trafficking organization.
The case isn't only about Iranian exchanges now. It also touches alleged Canadian drug cash, and Treasury says some of the same businesses appear in both trails.
Treasury says addresses associated with Million Exchange sent digital assets to addresses associated with the IRGC or terrorism. It also alleges that the business converted Canadian drug proceeds into digital assets.
Amin Exchange allegedly received funds from sanctioned Iranian exchange Shelbit and converted millions of dollars in Canadian drug cash into digital assets for transfer abroad.
Farah Exchange allegedly dealt with Shelbit and Wallex and sent digital assets to addresses associated with terrorism and to addresses Treasury connects with Wedding.
Treasury also says an address associated with CCC Inc received hundreds of thousands of dollars from terrorism associated addresses.
These are U.S. Treasury allegations. An OFAC designation isn't a criminal conviction.
In the sanctions allegations, investigators followed counterparties. Which exchange received the funds? Which wallet had already been linked to a sanctioned actor?
In the Wedding allegations, they also followed the source. Where did the cash come from? Why was it converted? Treasury says some of the same Canadian businesses appeared in both trails.
The U.S. action could have ended as a foreign sanctions story. It doesn't.
FINTRAC confirms that it coordinated with OFAC and FinCEN, then Canada's financial intelligence agency publishes numbers showing just how active MSB enforcement has become at home.
Since the beginning of 2026, FINTRAC says it has revoked 161 registrations, more than during the previous three years combined. Over the past year, it imposed more than $198 million in penalties against nine MSBs and disclosed 28 MSB non compliance matters to law enforcement.
The November total didn't appear out of nowhere. By May, FINTRAC's MSB revocations were already reaching money transfer, FX, virtual currency and payment service businesses.
A registration revocation removes a business from Canada's MSB registry. An administrative monetary penalty punishes regulatory violations, while a law enforcement disclosure gives police information that may support an investigation or prosecution.
None of those actions is a criminal conviction.
The $198 million total is also heavily concentrated in a few exceptional cases. The Cryptomus record FINTRAC penalty was about $176.96 million, accounting for most of the total.
FINTRAC says it generally can't identify firm specific compliance action unless public disclosure is legally permitted. The public record therefore does not establish that any of the eight OFAC designated firms are among the 161 revocations, nine penalized MSBs or 28 referrals.
Before November 6, Canada's tougher MSB enforcement could be seen through revoked registrations, individual penalties and new AML powers.
Now FINTRAC is publicly confirming that Canadian financial intelligence also fed an international sanctions action. The coordination is public. The firm by firm Canadian enforcement record isn't.
The same number that placed each firm inside Canada's MSB system now appears on the same record as an OFAC designation.. That doesn't make registration meaningless. It changes what everyone around the firm has to ask next.
A bank can confirm registration and still need to understand the customer. A payment partner can confirm it and still need to know where the funds came from. A crypto exchange can confirm it and still need to screen the wallet. A foreign counterparty still needs to know who's at the other end.
U.S. property and interests in property belonging to designated entities are blocked and must be reported to OFAC. U.S. persons are generally prohibited from dealing with designated entities unless an exemption or authorization applies.
Entities owned 50% or more by blocked persons can also be blocked under OFAC rules. Banks, exchanges and other counterparties can add the newly published names and wallet addresses to their sanctions screening.
That doesn't mean every Canadian bank is automatically required to close every relationship with an OFAC designated Canadian business. Obligations depend on the parties, transaction and applicable law.
For legitimate MSBs, registration still opens the door to operating within Canada's regulated system. Remittance, FX, payments and digital asset firms remain important to customers who need alternatives to the largest banks.
International access depends on more than the registry. Banks, exchanges and settlement partners also need confidence in ownership, source of funds, sanctions controls, wallet screening and transaction monitoring. If that confidence disappears, the registration number won't preserve the relationship.
OFAC has named the firms and FINTRAC has confirmed the coordination. The rest of the Canadian story hasn't been written yet.
Registrations can be revoked. FINTRAC penalties can become public where the law permits. Police can investigate, prosecutors can lay charges where the evidence supports them, and criminal assets can be identified and recovered.
None of those outcomes can be read into the OFAC designation today.
What happens next will show whether the November 6 sanctions action is followed by Canadian registration, regulatory, police or asset recovery measures involving any of the eight firms.
Eight Canadian businesses entered November 6 with MSB registration numbers. They ended the day on a U.S. sanctions list.
That doesn't prove they committed a crime in Canada. It doesn't prove FINTRAC revoked their registrations, penalized them or referred them to police.
For legitimate operators, the demands are becoming harder to ignore. Know the customer, source of funds and beneficial owner. Know the wallet and the exchange. Keep records good enough to revisit a transaction when an address later appears on a sanctions list.
Those checks aren't free, especially for smaller firms. Banks, exchanges and settlement partners also have to decide whom they're willing to keep connected to their own systems.
Canada's MSB sector still serves real needs in remittances, foreign exchange, cross border commerce and financial access. November 6 doesn't change that.
What it does leave unresolved is what comes next for these eight firms.
OFAC has made its allegations public. FINTRAC has confirmed the cross border coordination. The next chapter is whether that intelligence leads to Canadian regulatory, police or asset recovery action involving any of the eight.
An MSB registration tells you that a firm entered Canada's regulated system. It doesn't tell you enough about the customers, funds, wallets and counterparties behind that number.
Does the November 6 action show that Canada's AML system is becoming more effective across borders, or will the stronger proof come only when Canadian investigations and asset recovery follow?
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The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, 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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Nov 9, 2026

By Chris Maranis, Deputy CEO, EXUS
Financial services has spent years making the decision to approve a loan faster and more informed. AI is part of that progress. As NCFA’s coverage of AI loan decisioning shows, lenders are finding new ways to verify information and assess risk at origination.
But approval is one decision on one day. Collections deals with what happens on all the other days. A customer’s circumstances can change many times before the debt is repaid. What happens when income drops, a payment is missed or a customer stops responding? Those decisions belong to debt collections, and they deserve just as much intelligence.
After more than twenty years working in collections, this is where I think AI gets interesting. Not because it can automate more for the sake of it, but because it can help teams choose a better next action while giving collectors the time and context to handle situations that need human judgement.
Collections teams have always had to prioritise. The difficulty is that a delinquency bucket is not a person. Two accounts in the same bucket can belong to people in very different circumstances. One customer may have forgotten a payment. Another may be struggling to meet several obligations. Treating them identically can waste effort and, more importantly, miss the chance to offer useful support.
AI can help teams assess a broader set of signals: payment behaviour, risk, engagement, affordability information where available, and the results of previous contact. But the point is not to produce a cleverer score. It is to decide who needs attention, when to make contact, through which channel and with which treatment.
A prediction without a policy is just a prediction. It cannot tell a lender what is appropriate for a customer. It has to lead to an action the institution can explain, monitor and change when circumstances change.
This matters in Canada, where the Bank of Canada’s 2026 assessment of households describes resilience overall alongside pockets of greater financial pressure. A portfolio average cannot tell a collections team which customer needs a reminder, which needs a different repayment path and which needs a conversation.
One thing technology should do is make the human conversation better. For a collector speaking with a customer, a concise view of account history, previous interactions and available options can turn a difficult conversation into a more informed one. AI’s role does not end when it recommends the next action.
Imagine a customer who has started, but not completed, a digital repayment journey. If they call for help, the collector should be able to see where they stopped and what options they saw. Asking the customer to explain everything again while the collector searches across systems is friction we should be able to design out.
AI can help assemble that context, prioritise work and suggest actions within a lender’s policy. The collector still has to listen. That matters. A customer disputing a balance, describing hardship or explaining a change in circumstances may reveal something the data did not capture. In that moment, the system’s job is to support judgement and make an appropriate handoff possible.
For me, the design question is simple to ask and difficult to answer: where should AI decide, where should it recommend, and when should a person step in? The objective is not to automate the maximum possible amount of the process. It is to automate where appropriate and preserve judgement where it matters.
Those boundaries cannot live only in a policy document. They should be visible in the workflow. Teams need to know what information informed a recommendation, what policy applies, how an exception is handled and whether different groups of customers are receiving appropriate treatment. They also need to test what happens after an action: did the customer engage, was an arrangement maintained, and did the intervention help resolve the difficulty?
Canadian expectations make this more than a theoretical exercise. For federally regulated financial institutions dealing with mortgage customers at risk in exceptional circumstances, the Financial Consumer Agency of Canada’s guideline addresses early identification, proactive contact and appropriate, individualised relief. Technology can help carry out a lender’s policies, but the lender remains responsible for the treatment customers receive.
At EXUS, we focus on connecting collections decision intelligence to the work teams actually do. As we have also discussed in our guide to governing collections AI, the useful starting point is the customer outcome and the specific decision AI will influence.
Activity is easy to count. Outcomes are harder. They are also the point. Automated messages, completed tasks and contacts made say little on their own about whether collections is working better.
A stronger test asks whether customers reached a suitable option, whether repayment arrangements lasted, whether complex cases reached trained staff promptly, and whether the lender improved recovery without adding avoidable friction or cost. Those are harder measures, but they tell you whether the operating model is actually improving. And they should inform the next round of decisions.
AI can make collections more responsive as a customer’s situation changes. But it cannot rescue a weak operating model. The value comes from the whole system: sound signals, clear policy, useful digital journeys, supported collectors and a willingness to learn from outcomes.
A customer’s circumstances can change overnight. The collections operation has to keep up. Across thousands or millions of accounts, the challenge is turning that change into the right response by connecting data, policy, digital channels and collectors without losing sight of the person behind each case.
That is the standard I would use for any collections technology, including our own at EXUS: when a customer needs a different response, can the organisation recognise it, deliver it in time and show that it worked? AI-driven decisioning can help guide the next action, and people need the context to handle the cases that require judgement. The technology matters. The outcome matters more.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, 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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Oct 31, 2026 | Last Updated: Nov 12, 2026 | NCFA Fintech Whisperer | Artificial Intelligence And Data, Capital Markets Infrastructure And Funding, Cross Border Payments And FX, Cybersecurity Fraud And Financial Crime, Digital Assets Blockchain And Tokenization, Digital Banking And BaaS, Digital Identity And Trust, Insurance And Insurtech, Lending Consumer Credit And BNPL, Open Banking Open Finance And Data Sharing, Payments Infrastructure And Money Movement, Regulation And Policy, Risk Compliance And Regtech, SME Finance And Business Banking, Sustainable Finance ESG And Financial Inclusion, Treasury Liquidity And Cash Management, Wealthtech Investing And Trading

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NCFA Fintech Whisperer tracks weekly fintech market intelligence that changes how financial markets operate. Coverage spans NCFA's full financial innovation taxonomy, with Canada first and global developments included when they materially affect rules, market access, competition, capital, technology adoption, distribution, risk or execution. We focus on changes that founders, investors, financial institutions, regulators and operators may need to act on, not simply what's making headlines. This page is updated throughout the week as material developments emerge, then closed and archived before the next weekly window begins.
Missed a prior week's Fintech Whisperer? Browse December 6 to 12, 2025, December 13 to 19, 2025, January 1 to 9, 2026, January 10 to 16, 2026, January 17 to 23, 2026, January 24 to 30, 2026, January 31 to February 6, 2026, February 7 to 13, 2026, February 14 to 20, 2026, February 21 to 27, 2026, February 28 to March 6, 2026, March 7 to March 13, 2026, March 14 to March 20, 2026, March 21 to March 27, 2026, March 28 to April 3, 2026, April 4 to 10, 2026, April 11 to 17, 2026, April 18 to 24, 2026, April 25 to May 1, 2026, May 2 to 8, 2026, May 9 to 15, 2026, May 16 to 22, 2026, May 23 to 29, 2026, May 30 to June 5, 2026, June 6 to June 12, 2026, June 13 to June 19, 2026, June 20 to June 26, 2026, June 27 to July 3, 2026, July 4 to July 10, 2026, July 11 to July 17, 2026, July 18 to July 24, 2026, July 25 to July 31, 2026, August 1 to August 7, 2026, August 8 to August 14, 2026, August 15 to August 21, 2026, August 22 to August 28, 2026, August 29 to September 4, 2026, September 5 to September 11, 2026, September 12 to September 18, 2026, September 19 to September 25, 2026, September 26 to October 2, 2026, October 3 to October 9, 2026, October 10 to October 16, 2026, October 17 to October 23, 2026, October 24-October 30, 2026.
Penny brings the practical test of financial AI into everyday accounts. Can a client see exactly what an agent plans to do before approving it? Wealthsimple is keeping confirmation in the transaction path, a useful response to AI agent authorization risks. Banks and fintechs competing here will need reliable permissions and clear records, not just a better chat interface.
Singapore wants financial firms to solve common AI deployment problems together instead of rebuilding every control separately. Vendors should watch the tools that emerge from BuildFin.ai and SafeFin.ai. Shared practices can make procurement easier, but they can also raise the minimum standard for selling AI into banks.
Project SAGE moves the agentic finance debate toward the control layer that determines whether financial agents can be trusted to act. Identity alone is not enough. Firms need to prove who delegated authority, what the agent can do and how that authority is revoked. Those questions sit at the centre of AI agent financial authorization and security.
Firms building AI tools for customer decisions will get a direct route to test designs with the regulator. That matters more than another broad statement on responsible AI. Applicants should arrive with specific decision flows, customer safeguards and evidence they can evaluate during the program.
For Canadian founders and early investors, exit taxation affects where companies are built and where proceeds get invested next. The proposed relief could make staying in Canada more attractive when a venture succeeds. But the eligibility rules will decide who actually benefits, especially founders, employees with equity and angels backing smaller deals. Until enacted, founders shouldn't price the proposed exemption into a transaction.
BitGo can now sell custody and financing together rather than leave institutions to connect several providers. That makes collateral eligibility, liquidation terms and counterparty exposure central buying decisions. Clients comparing BitGo's institutional custody services with its new trading desk should press for actual funding costs and settlement performance. The launch alone doesn't establish market share.
US exchanges now have a route to list equity perpetual futures within registered markets. Brokers can assess a product category many traders currently find offshore. But the business case depends on actual contracts, margins, clearing arrangements and liquidity. No exchange volume was announced, so this is a permission milestone rather than evidence of trading demand.
Tokenized public equities need more than trading and settlement. They also need reliable ownership records, corporate actions and voting rights. Broadridge is building those functions into the NYSE model before launch, extending the tokenized securities infrastructure layer already forming around regulated markets. Regulatory approval and issuer participation are the next proof points.
Financial institutions increasingly face a cost for every separate ledger connection. Consensys is selling a way to coordinate transactions while institutions keep control of their own networks. Buyers will need to test settlement finality, exception handling and integration cost before treating interoperability as solved.
The approved connection could let investors reach the digital gilt through two depositories instead of one. That gives banks and custodians a real interoperability problem to solve before issuance. They’ll need to test ownership records, settlement finality and investor access. A successful pilot could establish a useful model for digital government bond distribution, but no gilt has been issued yet.
A shared clearing house could give tokenized instruments access to familiar margin and default processes. That may be cheaper than running separate clearing arrangements. Members should test legal finality, collateral treatment and what happens when a digital transaction fails. Eurex has announced the design; live eligible products and actual clearing volumes remain the proof.
The proposed listing could give tZERO capital and a public market valuation for its regulated tokenization business. But the amount available depends on redemptions, financing and closing conditions. Investors should track cash actually delivered and trading activity across its platforms. **A signed SPAC deal is not a completed funding round.**
For active traders, a small fee change can matter across millions of shares. Dealers should model the cap alongside spreads and rebates, then confirm which provincial relief orders apply before changing routing. The November implementation brings the fee cap into actual execution costs for affected markets.
This expands BMO’s ability to connect Australian mining issuers with global institutional capital and advisory services. For smaller market participants, it raises the competitive standard for research, placement reach and cross border execution. The integration matters more than the acquisition headline.
Banks using Aquila could add currency coverage without building a separate payment connection for every corridor. That's commercially useful only if rates, compliance checks and failed payment handling work inside normal operations. Firms evaluating bank and cross border payment connections should compare actual execution costs and settlement times rather than count currencies on a slide.
A gift card seller has to keep suppliers funded even when customers pay in crypto and its suppliers expect local cash. Bitrefill is using stablecoins behind the scenes, not asking suppliers to change what they accept. That puts live evidence behind the cross border stablecoin supplier payments opportunity. The financial test is conversion cost, available liquidity and reliable delivery across more corridors.
Payment providers often need one bank for currency accounts and another provider for digital assets. RTGS.global is reducing that integration burden for eligible firms, although bank onboarding and market coverage still apply. Its value will depend on account approval, funding speed and costs across the banking and digital asset payment connections customers actually use.
The licence gives Razorpay a regulated route for cross border payment products and a clearer sales pitch to global platforms. Firms evaluating the service should check permitted flows, payout corridors, bank coverage and actual onboarding time rather than treating the licence as proof that every corridor is live.
The higher ceiling moves this rail beyond smaller remittance tickets and gives payment providers more room to serve larger consumer transfers without splitting them across transactions. The competitive question is whether instant card payouts can win volume from bank based cross border flows on cost, reliability and reach as cross border payment infrastructure becomes faster and more programmable.
Cross border QR acceptance could give Hong Kong bank and wallet users more ways to pay abroad without using a separate travel wallet. Providers should watch fees, currency conversion and participating banks. Merchant reach alone does not establish how much of that network a customer can actually use.
Texas adds another state where Navro can offer regulated payment services directly under its own permission. That makes licensing a sales advantage for firms managing payroll and international disbursements. Clients still need to check other state permissions, supported payout routes and bank arrangements. **One API does not mean one licence covers the entire US.**
Canadian MSB registration doesn't establish that a firm's transactions or customers are compliant. Banks, payment providers and crypto platforms need to check counterparties against sanctions lists, assess transaction exposure and keep stronger records of their decisions. The risk now extends beyond Canadian registration into international sanctions enforcement. The Canadian MSB sanctions case shows how these controls intersect.
The FCA is offering firms a route to test whether quantum systems outperform established financial crime tools before committing to expensive infrastructure. Interested compliance vendors need measurable detection questions and credible comparison data. This complements the earlier financial sector quantum readiness work, but the immediate opportunity is experimentation, not a production procurement mandate.
India has pulled payment security, cyber resilience, system audits and third party controls into one binding rulebook. That reduces uncertainty about which requirements govern when older instructions overlap. Payment firms now have a clearer compliance baseline across their own systems and the vendors they rely on. The operating burden reaches beyond internal technology because connected service providers also have to meet the required controls.
This is a bank payment authorization problem with a third party entry point. Payment firms can't judge resilience only by whether customer accounts were compromised. They also need controls over vendor permissions, treasury transactions and emergency transfer suspension. The cost becomes immediate when legitimate customer payments stop while the bank investigates. Arkéa's precise financial loss remains unconfirmed.
The business case for fraud AI is investigator time and better decisions, not simply faster generated explanations. Mashreq’s deployment puts those claims inside a bank control environment. Buyers should ask for measured investigation throughput, detection quality and evidence trails before extending automation.
This is a procurement and migration issue for banks long before quantum attacks become routine. Firms need to identify where vulnerable cryptography protects customer data, transactions and long lived records. Vendor contracts and implementation roadmaps are where the work becomes expensive.
A fraud report is more useful when it leads to a blocked account, disabled number or removed website. Maple Disruption brings the organizations controlling those channels into the same operation. Banks and fintechs should examine how quickly shared fraud intelligence reaches the team that can act. The real test is disruption achieved, not the number of participants.
BVNK gives payment providers a working route from dollars to stablecoin balances and back. It's useful for firms that need treasury and customer payouts without building four blockchain integrations themselves. The buying decision still comes down to liquidity, redemption and compliance costs. Those are the same operating constraints in NCFA's programmable stablecoin payments research.
Banks could still distribute digital money, but issuing it would require a different legal structure. That matters for licensing, reserves and who carries redemption obligations. Canadian wallets and PSPs also need clear treatment of foreign issuers, not just domestic products. NCFA's stablecoin regulatory guide tracks the existing framework while Ottawa works through the proposed amendments.
Institutional traders want exchange liquidity without giving one exchange control of their entire asset pool. Bitget is separating those functions, but clients still need to review collateral rights, liquidation instructions and settlement responsibility. The distinction matters alongside NCFA's crypto custody and exchange trust research. Keeping assets elsewhere is useful only when the legal and operational controls hold under stress.
The important step is that a major bank can send assets into custody and retrieve them through an operating connection. That is more useful than another memorandum of understanding. Institutions assessing regulated digital asset custody infrastructure will still want evidence of withdrawal reliability, segregation and collateral enforceability before expanding lending against these assets.
Restoring the reserve closes one immediate solvency gap, but it does not restore every withdrawal route. Users and trading firms still need to check liquidity, redemption channels and governance controls. The unresolved commercial issue is how a federated bitcoin product earns back confidence after a reserve failure.
Always available tokenized assets need an equally available cash leg. Hong Kong has connected both sides inside a regulated pilot, which makes settlement hours less of a constraint on treasury and tokenized fund activity. The commercial test is volume, participant growth and movement from pilot access toward production use in tokenized collateral and cash settlement.
Ireland is giving tokenization firms a more direct route into regulatory engagement while the supporting settlement and legal framework is still being built. That can surface custody, asset servicing and interoperability issues before firms scale them. The opportunity is shifting from issuance toward the regulated infrastructure around tokenized real world assets.
Tokenization firms need ways to reach regulated bank partners before they can prove demand. tConnect creates another entry point to test that fit. The useful measure will be projects that progress from collaboration into funded deployments, not how many firms attend.
The pause is a direct operating interruption for traders and liquidity providers relying on cross chain swaps. Those users need current chain status, outbound queue visibility and clear incident reports. An unexplained refund error also raises questions about how the protocol handles exceptional transactions under load.
Institutional custody clients now have another federally regulated option to evaluate when choosing where to hold digital assets. For Coinbase, the charter offers more direct control over its custody business and less dependence on separate state level arrangements. The competitive test is whether federal supervision helps Coinbase win more institutional assets and custody mandates. Banks and investment platforms should compare custody terms, segregation and supervisory protections rather than assume every trust charter offers the same services.
Eight sponsor banks give Synctera more capacity to match fintech programs with regulated banking partners rather than depend on one institution's appetite for risk. But the larger network also demands consistent controls across every bank relationship. Compliance quality is becoming a competitive requirement for banking infrastructure. That makes its earlier Cable compliance acquisition commercially important as the platform expands.
Higher deposit protection could make customers more comfortable keeping larger balances at smaller federally insured banks. That affects a bank's funding cost and its ability to compete for savings. The proposed changes could help challengers, but firms must explain the current coverage accurately until Parliament changes the law. Smaller banks may benefit most if stronger insurance coverage helps them compete for deposits.
Getting a banking licence is expensive before the first account opens. A clearer decision period could make financing a challenger bank more realistic, while the ownership changes may let growing banks retain strategic investors longer. The details matter. Canada's Budget 2026 financial competition analysis sets out the wider context, but applicants still need to meet prudential standards.
Revolut can now compete on deposits rather than relying only on its existing account and payment products. For incumbent banks, the pressure is immediate on savings pricing and mobile acquisition. For digital challengers, the licence shows how costly and valuable direct deposit capacity can be.
Thailand’s virtual bank contest is turning into a distribution and core technology test. CLICX brings banking, mobile and physical retail reach together, but readiness alone does not establish account growth. The first customer offers and their economics will tell competitors whether that combination works.
Buying a bank can give a lending platform more direct control of funding and products, but the approval process can disrupt the whole plan. OppFi’s withdrawal puts a price on regulatory uncertainty. Other fintech acquirers need credible alternatives while approval remains unresolved.
Banks now face a larger identity vendor combining onboarding, biometrics and fraud controls. That may reduce integration work, but a bigger provider can also command more pricing power. Buyers should compare approval accuracy, portability and contract terms before consolidating suppliers. The projected 200 million checks are useful scale context, not proof that the merger has improved results.
Amdocs has bought its way into the systems insurers use to administer policies, bill customers and settle claims. For EIS clients, the first questions are service continuity and integration cost. For competing vendors, the threat is a supplier that can combine core software with enterprise AI services. Actual insurer deployments will determine whether that combination pays off.
Data centre builders need insurance that spans power, construction, equipment and cyber exposures rather than isolated policies. Pooling underwriting capacity could make larger projects easier to finance, especially as AI raises infrastructure demand. The test is whether the facility offers useful terms and capacity once it opens.
Motor finance lenders can settle some claims before the wider redress process ends, but an early offer has to stand up to scrutiny. A poorly explained calculation can create another dispute. Firms should keep a clear record of the amount offered, the customer’s options and the effect on any open complaint. Faster resolution only helps when customers can understand the terms.
Accreditation is moving from legislation toward the application work firms must actually complete. Fintech applicants should test the proposed evidence requirements against their operating models now. The deadline is a chance to resolve costly ambiguity before onboarding and compliance processes become fixed.
The date finally gives payment teams a launch milestone they can plan around. For merchants and treasury operators, the value comes when their providers actually enable funds to arrive in seconds. Access still depends on testing, settlement arrangements and participant readiness. NCFA's RTR access rules guide shows why a system launch does not give every provider immediate access.
Pliant is making corporate payment infrastructure accessible to software agents, not just staff clicking through expense screens. That creates demand for clear limits, approvals and records of who authorized each instruction. Canadian firms already face these AI agent payment authority questions. The $80 million round funds expansion, while transaction controls and customer adoption will determine the product's value.
A recipient name that differs slightly from the bank's record can interrupt a legitimate payment or confuse a sender. Consistent matching gives banks a better chance to handle those cases without weakening fraud checks. PSPs should test character handling and near matches against real customer records, then measure false warnings and stopped payments. The rules work only when the customer experience is clear.
Ebury is preparing to sell instant Canadian payments through infrastructure it already uses abroad. That may shorten integration work, but customers cannot use an announcement to settle funds. The next milestones are access and testing under Canada’s RTR rules, followed by actual payment availability. Corporate clients should watch those dates before changing treasury processes.
The shift is from an AI assistant recommending a payment to software executing one under delegated authority. That turns spending limits, identity, revocation and transaction logs into core payment infrastructure. The same control questions are emerging across AI agent financial authorization and security.
Peak demand is where payment infrastructure becomes visible to a merchant. A provider that keeps checkout working during short bursts of traffic can directly influence completed sales, but the useful benchmark is measured performance rather than the integration itself. Transaction success, latency, conversion and processing economics will show whether the deployment strengthens Unlimit's position in India's competitive payments market.
OKX has given eligible US stablecoin holders a spending option without a separate manual cashout. The question is how the product handles conversion costs, availability and rewards once customers use it regularly. For payment firms, this adds another live case to the stablecoin card settlement market. It is not a Canadian card launch.
Bill S-8 would make registration harder for risky money services businesses and change how financial crime intelligence reaches regulated firms. Crypto ATM operators should review the proposed restrictions against their current licences and locations. Payment firms should examine what new information FINTRAC could demand. NCFA’s crypto ATM money laundering guidance offers background, but the bill is not yet law.
Crypto issuers and counsel now have more specific staff language to test against token design and disclosures. The guidance can narrow unanswered questions, but it is not legal immunity. Businesses should track which interpretations affect their product structures without presenting staff FAQs as binding law.
Singapore is attacking two barriers to insurance capital reaching infrastructure deals, expertise and capital cost. Insurers can assess the grant immediately, while asset managers should examine whether the proposed risk criteria fit the deals they can originate. The consultation could alter financing demand across infrastructure and securitized assets.
The implementation date turns the September rulebook into a balance sheet decision for affected banks. Clearing, custody, trading and financing teams can now price eligible activity against the final treatment. The distinction between tokenized deposits and crypto exposures remains important under Canada's OSFI 2027 crypto rules.
Quantum risk is becoming a technology planning issue long before a cryptographically relevant quantum computer arrives. Banks and payment firms need an inventory of the encryption they use, dependencies on vendors and a realistic replacement schedule. MAS is putting dates around that work rather than leaving quantum preparation as an open ended technology project. The timelines remain proposed while the consultation is open.
Banks don’t have a new AI rule to implement here. They do have a clearer view of the questions examiners may ask about consequential automated decisions. Can staff stop an agent? Who approved its authority? Can the bank explain a failure? Those are practical tests of AI agent authorization controls, even though the OCC guide imposes no new standards.
Moving fraud logic from engineering queues into the risk function can shorten the time between a new attack pattern and a production control. It also makes governance more important because rule changes can affect onboarding, approvals and declines immediately. The product will be more valuable if customers can show faster response without increasing false positives, exceptions or unexplained automated decisions.
The FCA is giving firms failure patterns they can test against now. Data lineage, change testing, AI inventories, conditional approvals and kill switch ownership all become concrete control questions rather than abstract governance principles. Similar issues are emerging across AI, programmable finance and financial crime regulation.
The merger puts regulated bank funding and embedded business lending under one owner. Liberis gains another way to fund offers delivered through its partners. Qred gains wider merchant distribution. Small businesses will judge the combination on approval times, price and repayment flexibility. Reach across 17 countries is valuable only if the lending economics hold up.
ESG ratings providers now have deadlines, not just broad calls for better disclosure. Firms selling ratings in the UK should review their conflicts controls, methodologies and customer explanations ahead of the June 2027 application window. Asset managers have work too. They need to know whether the ratings suppliers embedded in their products can meet the new standards before June 2028.
Tokenized deposits are becoming a treasury product for actual institutional customers, not just a bank demonstration. The commercial value rests on when money can move, how much liquidity must sit idle and what treasury systems can connect. Measured customer flows are the next test.
Clearing members can now use certain RMB bonds as margin instead of tying up as much cash. **More than RMB 400 million posted on day one** gives this a stronger operating basis than a policy proposal. The saving will depend on haircuts, custody charges and funding costs. Banks should measure the cash released, not just the amount of collateral accepted.
Wealthsimple could bring Canadian dollar digital assets to customers who would never open a crypto wallet themselves. CADD already exists, so this is a new distribution and reward announcement, not the launch of the stablecoin itself. NCFA covered CADD's original regulated issuance in May. The next test is how many clients use it for payments or cash management rather than simply collecting rewards.
Zero commission Canadian options put more pressure on trading fees, while faster order entry makes a difference for active clients. Direct indexing adds a tax planning product within accounts investors already use. The bigger competitive test is whether Wealthsimple can serve frequent traders without higher spreads or weaker execution. Its planned perpetual futures also bring suitability and leverage questions that matter as much as headline pricing.
Capital.com has permission to enter Singapore, but it still needs customers. The company plans to begin onboarding in 2027, so local brokers have time to prepare. Investors should compare the instruments, trading costs and safeguards actually offered at launch. Regulatory approval opens the market; it does not establish customer traction.
Canada’s RTR launch, proposed banking reforms and new digital asset rules make this a consequential week for financial innovation. Globally, firms are putting AI, tokenization and new payment infrastructure into practical use. For Canadian fintechs, the opportunity is in execution. Clearer rules, better access and products that solve real customer problems will determine who can compete and grow.
NCFA offers various curated resources to help founders and investors stay current on developments that impact fintech markets. Get the weekly Whisperer and related market intelligence through NCFA's newsletter, view the latest fintech news and insights, industry research, or launch into emerging financial innovation opportunities.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer to peer finance, payments, digital assets and tokens, 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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November 6, 2026 | Insight | Competition And Market Structure, Payments Infrastructure And Money Movement, Capital Markets Infrastructure And Funding

On November 5, 2026, Finance Minister François Philippe Champagne tabled Budget 2026 with a financial sector package aimed at making it easier for credible new competitors to enter, raise capital and grow. The Budget 2026 financial sector measures cover bank approvals, ownership, deposit funding, payments, stablecoins, investment capital and commercialization. Separate measures tighten fraud, financial crime and consumer protection. Many of the digital finance building blocks started in Budget 2025's fintech and capital agenda. A year later, some are reaching implementation while Budget 2026 goes further on bank entry, ownership, funding and competition.
Canada's six largest banks still hold about 93% of banking assets, leaving new entrants to compete against institutions with major advantages in deposits, distribution, capital and customer relationships. Outside banking, Canada also has a large C$14 trillion non bank financial system spanning investment funds, pensions, insurers and other financial firms. Canada has plenty of financial activity, but needs stronger competition in core banking and payments.
Ottawa wants to add competition as a secondary statutory objective for OSFI while keeping financial stability first. Proportionality, compliance burden and market impact would become explicit considerations when OSFI regulates and supervises financial institutions. Smaller institutions often carry many of the same fixed regulatory costs as much larger competitors, so the way those rules are applied can affect whether a new entrant can build a viable business.
Peter Routledge, Superintendent of Financial Institutions
“Our role is to ensure the prudential framework does not create unnecessary barriers to responsible competition.”
OSFI's streamlined approval rules for targeted new entrants already use a 12 month target for formal review after OSFI accepts a complete application. That clock doesn't include all the work required before filing or everything needed before a new institution can begin operating.
Budget 2026 proposes a maximum one year statutory decision timeline for new banks, trust and loan companies and insurers. It would also remove some self dealing restrictions that can limit how a new institution organizes itself while waiting for approval. A ministerial policy statement would give applicants more guidance on entry, transitional relief and proportional regulation. Applicants still need capital, governance, systems, risk controls and a credible business plan, and the legislation still has to define exactly when the statutory clock starts and stops.
Santander first published notice of its Canadian bank application in July 2019. Santander's Canadian banking licence followed years later, with an amended structure involving its Canadian finance businesses receiving an order to commence business in March 2025. The application changed along the way, so that full timeline can't be compared directly with Budget 2026's proposed one year decision period. It does show how long the full path into Canadian banking can take.
A challenger still needs enough capital to grow. Budget 2026 would raise the equity threshold at which a bank must become widely held from $12 billion to $25 billion. Certain foreign bank subsidiaries with less than $8 billion in equity would get more ownership flexibility, while federal credit unions could bring in a wider range of qualifying cooperative shareholders.
Those rules leave successful challengers with more room to raise capital before ownership restrictions tighten. Canada has already added new entrants such as Questbank. New banks still have to attract enough deposits and customers to take meaningful share once they're licensed.
Budget 2026 also proposes raising CDIC protection from $100,000 to $250,000, adding temporary protection for high balances after events such as a home sale and removing the limit for eligible deposits in registered and tax free accounts. Finance says stronger coverage can improve smaller banks' access to lower cost funding. Customers holding larger deposits would also have less reason to favour a large bank simply because of its balance sheet. The existing $100,000 limit remains in force until legislation changes it.
Ottawa also plans to improve funding access for small and medium deposit taking institutions, expand voluntary exit options and keep making prudential requirements more proportionate to size and risk. That continues the direction already visible in OSFI's competition and growth approach. Easier entry won't mean much if firms can't afford to stay and compete.
Canada's Real Time Rail is scheduled to launch on November 9, 2026. Budget 2026 didn't create RTR, so the launch shouldn't be treated as a new budget initiative. The budget starts the next policy phase with an early 2027 payments consultation, a review of the Canadian Payments Act and proposed changes to the Retail Payment Activities Act.
Canada had already started opening core payment infrastructure before this budget. Federal changes made regulated PSPs, qualifying local credit unions and designated clearing houses eligible to join Payments Canada. By October 2026, 22 new members had joined Payments Canada after the access reform, with 20 becoming eligible because of the new rules. The group includes Wise, Float, KOHO, Neo Financial, Adyen, Remitly and several credit unions.
Membership changes who can get into the system, but it doesn't provide automatic access to every rail. Canada's Real Time Rail access rules still require settlement arrangements, technical integration, testing and certification. Wider access can reduce dependence on incumbent intermediaries, but fintechs still have to turn that access into better products, pricing or service.
The RPAA amendments would strengthen Bank of Canada supervision as the regulated PSP market matures. Ottawa also wants provinces and territories to work toward more consistent consumer protection for payment firms. Different provincial requirements can add cost to a fintech serving customers nationally even when the service itself runs through one platform.
A voluntary digital credentials pilot is also planned for financial services. Reusable credentials could reduce repeated document checks and strengthen onboarding, but the budget hasn't defined the technical model or participants. Banks and fintechs only gain if the credentials work across organizations rather than create another closed identity system.
Consumer driven banking gets a smaller update because most of the framework was already underway. Budget 2026 proposes clearer annual banking fee information supported by data sharing, while Canada's broader consumer driven banking market continues toward regulated data access and payment initiation. The budget doesn't announce another accreditation model or a new timetable for write access.
Budget 2026 changes how banks could issue stablecoins. Canada has enacted the Stablecoin Act and published proposed operating regulations, but the regime isn't fully in force. Federally regulated financial institutions would be prevented from issuing stablecoins directly and would instead have to use a non financial institution subsidiary regulated under the Act.
A bank would still bring capital, distribution and customer relationships, but its issuing entity would sit inside the same Canadian stablecoin regulatory framework as other covered issuers. Final reserve, redemption, custody, capital and insolvency rules will determine how close the competitive treatment really becomes.
Budget 2026 would also extend the Stablecoin Act to foreign financial institutions that aren't already prudentially regulated in Canada. Canadian PSPs, wallets and exchanges will want access to credible global stablecoins their customers already use. Foreign issuer rules therefore affect product choice, liquidity and integration costs even for Canadian companies that never plan to issue a stablecoin themselves.
Canada and the EU are also exploring connections between their instant payment systems and wider access to each other's banking, insurance and fintech markets. There is no new market access yet. If the work produces operating rights, Canadian fintechs could gain a larger payments corridor without building every international connection separately.
A qualifying individual could exempt up to $15 million in capital gains for each qualifying business under the proposed Canada Growth Incentive. The headline is large, but the eligibility tests narrow the pool considerably.
The person must be at least 18 and resident in Canada in the year of the claim. The company generally needs to be a Canadian controlled private corporation when the shares are issued, with combined related corporate assets of no more than $100 million. The shares normally need to be newly issued on or after November 5, 2026 and held for at least 36 months. Canadian business and asset tests also apply for much of that period.
Financial and insurance businesses are excluded. A software company selling technology to banks may qualify depending on what business it actually carries on. A bank, lender, insurer or other company operating as a financial business shouldn't assume it does.
Existing founders also shouldn't assume shares they already own suddenly qualify. The new rules generally apply to shares issued on or after Budget Day. Finance estimates about $715 million in fiscal cost over four years but doesn't publish a reliable count of qualifying individuals or companies. Its impact analysis expects nearly 84% of beneficiaries to have adjusted gross income above $200,000 and more than 75% to be men.
The incentive leaves more capital with qualifying founders and investors after a successful exit. The enhanced small business rollover also gives investors more time to reinvest qualifying proceeds, including additional flexibility for some future equity agreements such as SAFEs.
SR&ED may reach a wider group of fintech and regtech companies. Budget 2026 proposes adding certain commercialization costs tied to eligible R&D, including necessary regulatory approvals, certifications and intellectual property protection. Ottawa estimates $930 million over five years and $235 million annually after that. Marketing, distribution and ordinary sales costs don't suddenly become eligible.
The $750 million Early and Growth Stage Investment Strategy remains part of the startup capital picture, but it isn't new Budget 2026 money. Budget 2025 announced the BDC managed program, with $75 million for pre seed and seed investment and $675 million for later and growth stage capital.
The $25 billion Canada Strong Fund adds another route for private capital into Canadian projects and high growth companies. The Fund launched earlier in 2026, while Budget 2026 adds more detail on minority co investments, strategic investments and a new retail product planned for 2027. Canada Strong Notes would let individuals invest alongside the Fund through participating financial institutions, with principal protection, a coupon and some participation in Fund returns. Final terms will determine whether the Notes become a meaningful new retail investment channel.
Ontario's decision to join Canada's securities passport system could reduce duplicated work for companies raising capital across provinces. Ontario is the country's largest capital market and has historically sat outside the passport. Joining won't create more investors, but fewer duplicate filings and reviews can make national financings easier to execute.
Budget 2026 leaves NI 45-110, accredited investor rules and retail exempt market access largely untouched. Canada's C$1.5 million crowdfunding issuer cap remains in place, despite NCFA's longstanding position that the limit should rise to at least C$5 million to give smaller issuers a more practical path to growth capital.
Life insurers get more investment flexibility as well. Ottawa plans to broaden the infrastructure investments permitted under the Insurance Companies Act. Canadian life insurers manage large pools of long duration capital, so wider investment powers could direct more institutional money into domestic infrastructure without creating another government funding program.
Budget 2026 combines stronger competition with more accountability for firms serving consumers. Fraud losses, banking fees, mortgage costs and account switching all affect whether consumers can benefit from having more providers in the market. Several measures therefore target the cost and risk of everyday financial services rather than market entry itself.
Fraud prevention becomes more commercially important when firms carry more of the loss. Banks and fintechs have stronger reasons to improve authentication, identity verification, transaction monitoring and intervention before money leaves an account. Wider access to non public beneficial ownership information and stronger powers to dissolve corporations used for fraud add another layer to those controls.
Several other measures deal with financial system resilience rather than fintech competition. The Bank of Canada would gain authority to hold foreign currency for emergency lending to banks under severe stress. Ottawa also plans a Canadian Earthquake Insurance Facility, while federal pension rules would allow more electronic communication and reduce some administrative requirements.
The Minister of Finance would also gain authority to order banks and related institutions to sell investments in Canadian businesses when national security concerns arise. Financial institutions buying technology companies or other strategic assets would therefore face another potential review consideration.
Canada has spent years talking about more financial competition. Budget 2026 puts more of the plumbing behind it. The opportunity is real, but access and competitive gains only appear if new entrants can turn it into better products, lower costs and meaningful customer choice.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, 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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casano@ncfacanada.org
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