Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Category Archives: Venture Funding and Building
National Security Is Now Part of Financial Supervision
October 6, 2026 | Regulation And Policy, Banking And Credit, Financial Crime And Compliance, Cybersecurity And Operational Resilience, Digital Assets Blockchain And Tokenization, Payments And Money Movement
Foreign Interference, Cyber Threats and State Risk Are Now Part of Financial Oversight
On August 20, 2026, Toronto Centre published the podcast episode The Landscape of Financial Supervision and Security, featuring Tom Keatinge, Founding Director of the Centre for Finance and Security at RUSI, in conversation with former Basel Committee Secretary General Bill Coen. They discussed how financial supervisors should respond when foreign interference, sanctions, cyber threats and state activity move through the same institutions and infrastructure they already supervise.
Canada has been building an answer since 2023. OSFI now assesses whether federally regulated financial institutions can protect themselves against threats to their integrity and security, including foreign interference. It has also built a national security function that brings classified intelligence into supervisory work. What began as a legislative mandate is now part of how Canadian financial institutions are supervised.
- OSFI's integrity and security mandate explicitly includes foreign interference
- Its guidance tells institutions to assess undue influence, foreign government connections, malicious activity and third party risk
- OSFI can require institutions to address weak integrity or security controls
- Its national security function works with Canada's security and intelligence community and FINTRAC
- On September 8, 2026, Josée Turcotte became Deputy Superintendent responsible for integrity, national security and threats related to money laundering
A bank can be well capitalized and still face risk from foreign interference, state sponsored cyber activity, opaque ownership or compromised third parties. OSFI's integrity and security framework puts those threats inside its supervisory mandate.
How National Security Became Part of OSFI Supervision
In 2023, parliament expanded OSFI's mandate through Bill C 47. Federally regulated financial institutions became responsible for having policies and procedures to protect against threats to their integrity and security, including foreign interference. OSFI described the expanded mandate as a significant increase in the type of oversight it provides.
In 2024, OSFI finalized its Integrity and Security Guideline. Institutions were expected to assess risks involving foreign interference, undue influence, ownership, third parties, malicious activity and unauthorized access to their operations or assets.
In 2025, OSFI identified integrity and security as a major risk to Canada's financial system. Its work increasingly included state linked actors, cyber threats, geopolitical risk and intelligence sharing with federal security partners.
In 2026, The work continues as part of regular supervision. OSFI's 2026 to 2027 risk outlook continues to identify foreign interference, malicious cyber activity and threats to critical financial infrastructure. In September, OSFI appointed senior leadership with direct responsibility for integrity and national security.
National security has moved through legislation, supervisory guidance, intelligence capability, risk assessment and senior accountability. Banks should expect it to remain part of supervision, while fintechs may face many of the same expectations by extension through third party relationships with regulated financial institutions, including tighter due diligence, cyber, data, sanctions and incident reporting requirements.
What If the Money Is Legal but the Purpose Is Hostile?
Keatinge argues that traditional anti money laundering controls are better at finding known financial crime than activity backed by a hostile state. Money used to fund influence or interference may come from a legal source, move through regulated institutions and involve companies or people that appear legitimate. The problem may not be where the money came from. It may be who is directing the activity and why.
FATF has not said its framework is inadequate for political interference, but its own work shows how difficult state linked financial activity can be to detect. A June 2025 review found only 16% of assessed jurisdictions demonstrated high or substantial effectiveness in implementing targeted financial sanctions related to proliferation. The networks FATF describes often use front companies, hidden ownership, intermediaries, trade and virtual assets. FATF's proliferation financing review documents those methods.
FINTRAC's counter proliferation work covers sanctions evasion and threats to the security of Canada. Reporting entities are expected to look through ownership, control and corporate relationships when suspicious activity appears. A transaction can look ordinary while the people, companies or purpose behind it tell a different story.
Stablecoins Can Affect Bank Funding as Well as Payments
Keatinge uses stablecoins to show how financial innovation can create economic and security risks at the same time. If households and businesses in a smaller economy transfer substantial savings from local bank deposits into US dollar stablecoins, local banks may lose part of the funding they use to make loans. At scale, that can become a financial stability and monetary sovereignty issue, especially when domestic savings and payments depend more heavily on assets and infrastructure controlled outside the country.
BIS research published in 2026 says stablecoins could make bank funding more expensive if people move money out of deposits. That could leave banks with less money to lend, including to small businesses. The IMF also warns that if money moves from local bank deposits into stablecoins backed by assets held abroad, less funding may remain in the domestic banking system. So far, however, the IMF says there is no clear evidence that this has caused widespread bank disintermediation.
Stablecoins also raise sanctions, cyber and financial crime concerns. FATF has identified virtual assets in proliferation financing and sanctions evasion, while state sponsored cyber actors have stolen digital assets to help fund government programs. Canada's stablecoin regulatory framework brings these risks into the wider debate over how digital money should be supervised.
Financial Infrastructure Is Becoming a Security Target
Keatinge describes the financial system as a domain of geopolitical conflict. Regulators usually use different language, but sanctions, cyberattacks and financial infrastructure already play direct roles in relations between states. Governments can restrict access to financial transactions and services, state sponsored actors target financial institutions and payment networks, and financial infrastructure is treated as critical infrastructure.
In May 2026, G7 finance ministries, central banks, bank supervisors and market authorities ran a cross border exercise based on a large scale cyberattack affecting financial systems across G7 countries. They tested how authorities would respond, restore services, communicate during the crisis and coordinate across borders. The G7 exercise shows how a cyberattack on one part of the financial system can quickly affect institutions in other countries.
A serious attack on payments, banking access, market infrastructure or a major technology provider can disrupt services and weaken confidence at the same time. Firms building payment, identity, digital asset or financial infrastructure need to treat resilience as part of the product, not just an internal technology issue.
Five Cases Show Where Security Risk Reaches Finance
1. Foreign influence and a provincial referendum
In September 2026, Canada's Foreign Influence Transparency Commissioner said the office was aware of concerns about foreign influence activities directed at the Alberta referendum. The Commissioner reminded participants that arrangements with foreign principals intended to influence a provincial referendum can require registration. The Commissioner's statement shows how political influence can intersect with payments, intermediaries and funding relationships.
2. Crowdfunding brought permanently into financial crime controls
During the 2022 Emergencies Act response, Canada temporarily extended anti money laundering and anti terrorist financing obligations to donation crowdfunding platforms and certain payment service providers. After the emergency ended, the government made separate regulatory changes that permanently brought donation crowdfunding platforms and certain payment processors, including businesses handling fiat or virtual currency transactions into Canada's AML regime. NCFA challenged the permanent rules, arguing that the government had not published enough evidence to justify their scope and that smaller platforms would carry a disproportionate compliance burden. The episode shows how a security event can lead to lasting regulatory change for an entire fintech sector.
3. Digital assets used to preserve access to global finance
In August 2026, the US Treasury sanctioned two digital asset exchanges and a network of front companies that it said Iran used to launder billions of dollars, maintain covert access to international financial systems and support sanctioned actors. The Treasury action shows how exchanges, wallets and corporate networks can become part of sanctions enforcement even when a traditional bank is not at the centre of the transaction.
4. Payments routed through intermediaries
FINTRAC requires transactions originating from or bound for Russia to be treated as high risk and calls for additional checks on identity, source of funds or virtual currency, transaction purpose and beneficial ownership. Its sanctions guidance also describes shell companies, intermediary jurisdictions, crypto exchanges and brokers being used to obscure sanctioned activity. FINTRAC's Russia guidance shows why screening the immediate sender or destination may not reveal the real exposure.
5. Cyber theft used to fund weapons programs
FINTRAC has documented North Korea's use of cyber theft, digital assets, front companies and financial intermediaries in activity connected with weapons of mass destruction and ballistic missile programs. FINTRAC's proliferation bulletin connects cyber security, wallet intelligence, beneficial ownership and sanctions controls to the same state backed financing problem.
For fintechs, the risk may be behind the payment in who owns the company, who benefits, where the money is routed or what the transaction is meant to achieve. A security event can also bring new rules to an entire sector with little time to prepare.
Banks and Fintechs Will Need Better Threat Intelligence
Banks and credit unions may have to look beyond capital, liquidity and operational risk to ownership, foreign influence, sanctions, cyber threats and insider risk. Smaller institutions could face higher compliance costs as national security becomes more closely tied to supervision.
For fintechs and payment firms, onboarding may need to go beyond identity checks and standard AML screening. State linked counterparties, unusual ownership structures, high risk jurisdictions and cyber exposure can all matter. Faster payments and digital assets also leave less time to spot and stop suspicious activity.
See: FINTRAC Revocations Raise The Compliance Bar
RegTech firms have a clear opportunity. The challenge is to combine transaction data with beneficial ownership, sanctions, corporate networks and cyber intelligence without overwhelming compliance teams with false positives. AI, programmable finance and financial crime increasingly meet inside the same monitoring systems.
Founders and investors should expect these issues to arise earlier. They can affect product design, bank partnerships, regulatory approvals and access to capital well before a company reaches bank scale.
Talking Point
National security is becoming part of everyday financial supervision. The difficult challenge is spotting harmful activity when the money and transaction both look legitimate. Banks and fintechs will need to understand not just where money comes from, but who is behind it, where it is going and what it is meant to achieve.
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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How Canadians Pay Is Changing Before Real-Time Rail
October 6, 2026 | Payments And Money Movement, Open Banking Open Finance And Data Sharing, Fintech And Innovation, Digital Assets, SME Finance And Business Banking, Competition And Market Structure
Cards Still Dominate as Transfers, Tap and Crypto Use Grow
On October 6, 2026, Payments Canada released its 2026 payment trends report, showing how Canadians are paying as the country prepares to launch the Real-Time Rail. Canadians made 26.7 billion retail payments worth C$12.9 trillion in 2025, with cards still dominating payment volume while contactless use, online transfers and reported crypto payments continued to grow.
- Total payment value rose 5.7% from 2024
- Cards accounted for 68% of payment volume
- Online transfer volume has grown 110% over five years
- Contactless payment volume rose another 9% in 2025
Canada is already a highly digital payment market before its Real-Time Rail launches. Canadians don't need convincing that digital payments are useful. The next opportunity is to make more of those payments settle in real time and carry better information with them.
Cards Lead Volume While EFT Moves Most of the Money
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- Credit cards accounted for 43% of Canadian payment volume in 2025 and debit another 25%
- Credit card transactions rose 7% to 11.6 billion, with their value reaching C$1.02 trillion
- Electronic funds transfer accounted for 12% of payment volume but 63% of total payment value
- Cash still accounted for 9% of payment volume, while online transfers represented 6%
- Cheques still represented 20% of payment value, followed by credit cards at 8% and online transfers at 5%
That mix is important for fintech founders and payment providers. Cards dominate what consumers see, but much of the money moving through Canada's payment system travels through EFT and other account based channels. Business payments, treasury and reconciliation therefore matter at least as much as what happens at checkout.
Online transfers show how quickly account based behaviour has grown. Their volume increased 110% from 2020 to 2025, faster than any other payment method, while credit card volume rose 75% over the same period. It demonstrates that transferring money digitally between accounts is already familiar behaviour.
Tap Keeps Growing as BNPL and Crypto Gain Users
- Contactless payment volume grew 9% in 2025
- Contactless credit card payments rose 12%
- Grocery stores and supermarkets accounted for 62% of contactless transactions
- Public transit tap use rose 8 percentage points to 14%
See: Shopify Opens WebMCP Checkout to AI Agents
Contactless remains the dominant convenience story, while BNPL and crypto show where newer payment behaviours are developing.
- E-commerce accounted for 6.1% of Canadian retail sales in 2025
- 26% of Canadians reported using buy now, pay later
- 39% of adults aged 18 to 34 used buy now, pay later for a purchase in 2025
- Reported crypto payment use rose from 3% to 5% overall and from 4% to 10% among adults aged 18 to 34
The crypto increase stands out, particularly among younger Canadians, but it needs context. Payments Canada says users most often cited privacy or anonymity, transaction speed and lower fees. The survey doesn't capture how frequently people paid with crypto, which assets they used, whether a crypto linked card was involved or whether merchants ultimately received crypto or Canadian dollars. However it's proof of more reported payment use, not evidence that crypto has become a mainstream Canadian payment rail.
Real-Time Rail Can Improve Payments Without New Habits
Payments Canada's consumer research found 52% of Canadians find real time payments appealing. The result comes from a separate survey of about 1,500 Canadian adults conducted through Leger's online panel in September and October 2025, rather than from transaction data. RTR adoption also doesn't require everyone to abandon cards or learn a new payment method.
Payments Canada plans to launch RTR in Q4 2026 with an initial group of direct exchange participants. Initial Interac e-Transfer clearing and settlement migration is scheduled for Q1 2027, followed by additional participants in Q2. Someone could keep sending an e-Transfer much as they do today while the clearing and settlement underneath that service moves onto RTR.
| Use Case | What Faster Settlement Could Change |
|---|---|
| Payroll and earned wages | A payroll service could make wages, bonuses or reimbursements available as soon as the payment settles |
| Refunds | Merchants could return approved funds without adding several more days of payment processing |
| Insurance payouts | Insurers could send an approved claim payment as soon as it is released |
| Supplier payments | Suppliers could receive funds as soon as payment is sent and settled, giving them better visibility over incoming cash |
| Merchant settlement | Payment services built on RTR could give businesses quicker access to proceeds from completed sales |
| Loan funding | Lenders could make approved loan proceeds available immediately after disbursement |
| Government payments | Benefits, refunds, rebates and emergency payments could reach recipients faster when government payment systems support RTR |
| Interac e-Transfer | A familiar service can move onto real time clearing and settlement without requiring customers to learn a new payment method |
Payments Canada says 37% of SMEs identify payment delays as a significant pain point. Instant settlement can't eliminate working capital needs, but it can shorten the period between sending money and knowing it has arrived. For businesses managing payroll, suppliers and daily cash positions, hours can matter even when days matter more.
ISO 20022 Can Cut Payment Reconciliation Work
RTR will use ISO 20022, allowing richer structured information to travel with a payment. That can include remittance information such as an invoice number, giving accounting and payment systems something useful to match against when the funds arrive. Payments Canada's business research says instant payments with enhanced data can make same day invoice matching possible.
With the right software, accounting systems can match payments to invoices automatically, treasury teams can see cash positions sooner and marketplaces can pay sellers faster. Payroll providers can offer quicker payouts, lenders can release approved funds sooner and payment companies can use payment data to improve reporting, fraud checks and cash flow tools.
Competition is opening at the same time. Registered payment service providers can now apply for Payments Canada membership, although membership alone does not guarantee RTR participation. The wider Payments Canada membership reform brings more fintechs and payment companies closer to national payment infrastructure, while the practical choices around RTR access and settlement still depend on technical, operational, security, fraud and settlement requirements.
What Happens When Payment and Banking Data Connect
Canada is also implementing Consumer-Driven Banking, which will let customers securely share financial data with approved providers. RTR does a different job by moving and settling payments in real time. Payment initiation could eventually connect the two, allowing an authorized service to use shared financial data, start a payment with the customer's permission and settle it quickly with useful payment information attached. Canada isn't at that stage yet, so payment initiation remains a future capability.
See: Are Stablecoins Becoming Payment Infrastructure?
For businesses, that could mean using current account information to manage cash, send an approved supplier payment and match the payment to the right invoice with less manual work. Consumers could get more useful account based payment options without needing another standalone app. The bigger opportunity comes when financial data, payment instructions and settlement work together instead of sitting in separate systems.
Talking Point
Cards and tap already work well, while online transfers have more than doubled in five years. RTR doesn't need to replace them to create value. It can make familiar services settle faster and give businesses better payment data to automate more of the work around each transaction. As real time payments connect with financial data sharing, where will faster money and better data create something customers and businesses couldn't do as easily before?
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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Ondo Launches Tokenized Pre IPO Private Markets
October 6, 2026 | Digital Assets, Capital Markets, Investing, Fintech and Innovation
Private Company Exposure Trades Without Share Ownership
On October 5, 2026, U.S. tokenized securities and real world asset platform Ondo Finance launched Ondo Private Markets, offering eligible non U.S. investors in permitted jurisdictions tokenized exposure to private companies before they go public.
The first asset will reference an unnamed leading AI company and is expected to begin secondary market trading this week. Investors aren't buying the company's shares. They are buying notes tied to the value those shares may realize at a future liquidity event.
Ondo plans to add private companies across robotics, cybersecurity, biotech, infrastructure and other sectors. The tokens can be held in a digital wallet and traded 24/7 on secondary markets. That could make private company exposure easier to enter and exit, but it doesn't turn a private company into a public one or give token holders shareholder rights.
Ondo Tokens Track Value, Not Company Ownership
Each token is a note whose payout is linked to the per share value realized on the reference company's common shares at a qualifying liquidity event. The notes are obligations of their issuer, PM Issuer Co (BVI) Limited. They are not shares in the referenced company and don't give holders voting, ownership or other shareholder rights.
The structure separates access from ownership:
- An investor can gain economic exposure to a sought after private company without joining its shareholder register
- The token can also move between eligible holders before the company reaches an IPO, acquisition or another qualifying liquidity event
Access isn't global without restrictions. Ondo says Private Markets is available to eligible non U.S. investors in permitted jurisdictions. U.S. persons cannot subscribe for, acquire or redeem the tokens, and orders cannot be placed from within the United States. The launch announcement does not provide a simple country by country eligibility list, so local securities rules and Ondo's onboarding requirements still determine who can participate.
The notes haven't been registered under the U.S. Securities Act or securities laws in other jurisdictions. Ondo says eligible clients receive the offering documents, token terms and risk factors before subscribing, so the legal wrapper is as important as the token itself.
Citi took a different route in June when it launched digital depositary receipts on private shares. Citi acts as issuer and custodian for tokenized receipts representing private company equity. Ondo instead gives investors a contractual claim tied to the economic performance of a reference company. Two products can both offer tokenized private market exposure while giving investors very different rights to the company underneath.
Ondo already operates at decent scale. Its tokenized stock platform has more than 450 stocks and ETFs and over US$1 billion in total value locked. The company says its stock and Treasury infrastructure together represent about US$3.7 billion in total value locked and more than 1 million cumulative holders. See Ondo Gains US Approval For Tokenized Shares And Funds.
24/7 Tokens Still Need a Private Market Price
Ondo can make its notes transferable around the clock, even though the private company underneath still doesn't have a continuously quoted public share price.
The timing gap is important when the token trades more often than the asset used to value it. Private company transactions can be infrequent, different share classes may carry different rights, and new financing rounds can reset valuations. A token market may therefore offer more opportunities to trade without automatically providing better information about what the reference company is worth.
Nasdaq Private Market launched Daq in July to address part of the information gap. It brings together pricing, share class, transaction and company data covering more than US$5 trillion in private company valuations. Longer trading hours can make a token easier to trade, but they don't necessarily make the private company underneath easier to value.
Liquidity has a similar limit. Being able to trade 24/7 gives eligible investors more opportunities to find a buyer or seller. It doesn't guarantee a deep market, tight spreads or enough buyers when someone wants to exit. Limitations that will become more important as tokenized private markets expand beyond a small group of highly sought after companies.
On September 30, the U.S. SEC proposed expanding responsible retail access to private markets. The proposals would widen access through regulated fund structures while maintaining investor protections. The SEC is also considering additional ways for individuals to qualify as accredited investors, including an exam and certain professional credentials.
Digital distribution can move faster than the rules that historically defined private market access. It can also move faster than disclosure, price discovery and investor understanding. For another example of how digital markets are reaching earlier stages of the investment cycle, see Bybit Opens Tokenized IPO Access To Retail Investors. More investors want access to companies before they go public, while regulators and financial firms are testing different ways to provide it.
Talking Point
Ondo is making private company exposure easier to hold, move and potentially trade without turning the token into company stock. That could open private markets to more investors, but easier access doesn't change the legal rights investors receive. As private markets move onchain, investors still need to ask the simplest question: what do I actually own?
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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Snaplii Puts AI Agent Spending in a Separate Wallet
October 5, 2026 | Last Updated October 5, 2026 | Artificial Intelligence And Data, Payments Infrastructure And Money Movement, Cybersecurity Fraud And Financial Crime, Fintech And Innovation
How Snaplii, Visa, Stripe and OpenAI Limit AI Agent Spending
On October 5, 2026, Toronto based fintech Snaplii presented Snaplii Cash as a separate wallet for AI agent spending, letting users fund a limited balance instead of giving software access to a bank account or stored card. The payment system itself isn't new today. Snaplii launched its Agent to Merchant payment skill on April 29 and published detailed Muse payment controls on October 1. Today's announcement makes the consumer proposition clearer and adds cashback to the pitch.
Snaplii is making a specific payment choice. The agent gets enough money to complete a purchase without gaining access to the account that funded it. Visa, Stripe and OpenAI are tackling the same problem differently, using restricted credentials or permission tied to a particular transaction.
Snaplii Caps What Muse Can Spend
The current Muse payment setup starts with a Snaplii Cash balance. Canadian users can add money by Interac e Transfer, while U.S. users can use Apple Pay. The user then creates an API key and gives it to Muse. Snaplii says there is no bank login, account link or stored card for the agent to reach.
The user chooses a daily limit of $100, $200, $500 or $1,000. Snaplii enforces that limit outside the agent and says Muse cannot read or raise it. Users can create separate keys for different agents and revoke each one independently. The wallet balance provides another limit because spending stops when the available money runs out.
Spencer Xu, Founder and CEO, Snaplii:
“You wouldn't hand a new assistant your credit card on day one. You'd give them a budget.”
Once access is set up, Muse can shop within the permission the user has already granted. In Snaplii's documented flow, the agent finds the item, prices the order, buys a gift card sized for the purchase and applies it at checkout. The merchant receives an ordinary gift card value, so it doesn't need a separate Snaplii integration for that transaction.
Snaplii reports more than 350,000 users, more than US$100 million in annual app transaction volume and more than 500 partner brands. Its October 5 announcement also cites cashback of 10% at DoorDash, 3% at Uber Eats and up to 15% at selected brands.
The extra separation comes with a bit of friction. Snaplii Cash cannot be withdrawn to a bank account and is used for future gift card purchases. Users therefore have to move money into another balance before an agent can spend it. That limits what the agent can reach, but it also gives the customer another pool of money to manage.
Visa, Stripe and OpenAI Draw the Limit Elsewhere
Other payment companies are giving agents controlled spending access without requiring a separate funded wallet. Other payment companies are giving agents controlled spending access without requiring a separate funded wallet. A Canadian card based example is the AI purchase involving Mastercard, Flybits and Rogers Bank. The approaches below put similar limits in different places.
How AI Agents Get Permission to Spend
Four approaches put the spending control in different places. Select each model to compare.
| Approach | How Spending Is Limited | Main Advantage | Main Tradeoff |
|---|---|---|---|
| Snaplii | Separate funded balance plus a user set daily limit | The documented Muse flow keeps the agent away from the user's bank and stored card credentials | The user has to fund and manage another balance |
| Visa Intelligent Commerce | An agent specific token is linked to an existing Visa card and checked against user instructions | The user keeps the existing card relationship while the agent receives a restricted credential | The card remains the funding source, so token and network rules carry more of the control |
| Stripe Link with Muse | The user approves each purchase and Link can issue a single use virtual card when needed | The agent does not receive the underlying payment details and permission stays close to the purchase | The user still approves the transaction total |
| OpenAI delegated payments | A one time payment request sets a maximum amount and expiry | The amount and duration of the payment permission are both limited | The merchant and its payment provider still complete the payment |
Snaplii limits the pool of money the agent can reach. Visa limits the credential it can use. Stripe keeps permission close to the individual purchase. OpenAI limits the payment request by amount and time.
Visa says its system can check payment credential requests against the customer's authenticated instructions and confirm that the merchant authorization matches the request. Stripe's Muse integration is already live for U.S. consumers. At more than one million businesses that accept Link, Muse can use a saved payment method after the consumer approves the transaction. Elsewhere, Link can issue a single use virtual card for the approved purchase.
Spending Limits Cannot Judge the Purchase
These controls can restrict how much money an agent reaches. They cannot tell whether it chose the right product, ordered the right quantity or understood the request correctly. An agent can also stay inside its spending limit while reacting badly to misleading content or choosing a merchant the customer would not have picked.
Important limits are stronger when the payment or financial system enforces them outside the AI model. The agent can still make a bad decision inside the permission it has been given. For more on this issue, see financial AI agent control failures.
Snaplii offers 120 day purchase protection for problems including inactive gift cards, incorrect balances and delivery of the wrong brand. Its policy excludes buyer's remorse, several redemption problems, lost cards and merchant insolvency. That isn't the same protection model as a conventional credit card dispute.
Talking Point
AI agents don't need access to all of a customer's money to become useful shoppers. Snaplii puts the spending limit around a separate wallet. Visa, Stripe and OpenAI put more of the control around credentials and individual transactions. The stronger model may be the one that gives agents enough room to act without adding more payment work than the automation removes.
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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Building a Legal Bench: How Fintech and Crowdfunding Companies Can Hire the Right Legal Talent
Oct 5, 2026 | Legal, Regulation, FinTech, Crowdfunding, Human Capital
In the early days of a fintech or crowdfunding platform, legal work often falls to a founder, an outside firm on retainer or a part time advisor. That works for a while. Then the company grows, regulators take notice, partners ask harder questions during due diligence, and it becomes clear that legal expertise is no longer a supporting function. It is part of the product.
Hiring the right legal talent at the right time can be the difference between scaling smoothly and stalling under compliance pressure. Here is what Canadian fintech leaders should know.
Why Legal Talent Is a Growth Issue
Fintech companies operate in one of the most heavily regulated corners of the economy. Every new product, market or partnership can trigger obligations around money laundering, privacy, securities or payments.
Investors understand this. Strong legal and compliance leadership signals that a company can grow without costly surprises. Banks and payment partners often expect it before they will sign an agreement. And when something does go wrong, experienced counsel can limit the damage.
The Regulations Driving Demand
The Canadian regulatory landscape explains why legal hiring has become so competitive.
Anti-Money Laundering
Many fintechs, including money services businesses and some crypto platforms, have reporting and compliance obligations to the Financial Transactions and Reports Analysis Centre of Canada. These obligations typically include appointing a compliance officer, maintaining a written compliance program and reporting certain transactions. Getting this wrong can lead to significant penalties.
Privacy and Data Protection
Fintechs handle highly sensitive personal and financial information. In most provinces, private sector privacy is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), and the Office of the Privacy Commissioner of Canada explains how organizations must collect, use and protect that information. Some provinces also have their own private sector privacy laws.
Securities and Crowdfunding
Crowdfunding portals and investment platforms must navigate provincial securities rules, including the national start-up crowdfunding exemptions. Offering documents, investor limits and marketing all require careful legal review.
Payments
The Retail Payment Activities Act requires many payment service providers to register with the Bank of Canada and meet operational and fund safeguarding requirements, adding a new layer of compliance work for payments companies.
The Legal Roles Fintechs Hire For
Not every company needs a full legal department on day one. As companies grow, these roles tend to appear in roughly this order.
General Counsel
A first general counsel usually handles everything from contracts and financing to regulatory strategy. The best early hires are generalists who are comfortable working at startup speed and know when to bring in outside specialists.
Compliance Leadership
A dedicated compliance officer, often with anti-money laundering expertise, becomes essential once regulatory obligations grow. This person builds policies, trains staff and manages relationships with regulators.
Privacy and Technology Counsel
As products become more data driven, specialized counsel can manage privacy programs, vendor agreements and cybersecurity requirements.
Commercial and Partnership Counsel
Growing fintechs sign agreements with banks, processors, software vendors and distribution partners. Counsel who can negotiate these efficiently keeps deals moving.
Why Fintech Legal Hiring Is So Difficult
Lawyers with real fintech experience are in short supply. Fintechs compete with major banks, large law firms and global technology companies for the same people, often with smaller budgets. Candidates also need a rare combination of skills: regulatory knowledge, commercial judgment and comfort with ambiguity.
Startups can compete by offering meaningful equity, broad responsibility and the chance to shape a legal function from the ground up. But they need to find the right candidates first.
Practical Tips for Hiring Legal Talent
A few steps can make the process more effective:
- Define the regulatory scope of the role before writing the job description.
- Decide which work stays with outside counsel and which moves in house.
- Look for candidates who can explain complex rules in plain language.
- Test for commercial judgment, not just legal knowledge.
- Plan the reporting line, since legal and compliance leaders need direct access to senior leadership.
Many companies also find it worthwhile to work with specialists. Experienced legal recruiters like The Heller Group understand the Canadian legal market and can identify candidates with the right regulatory background, including those not actively searching. That can save months on a critical hire.
Legal Strength as a Competitive Advantage
In fintech and crowdfunding, legal expertise is not overhead. It is infrastructure. The companies that thrive are the ones that treat compliance as part of their product, build legal capacity ahead of regulatory pressure and hire people who can help them grow responsibly. Investing in the right legal bench early is one of the smartest moves a growing platform can make.
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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🔥 TOKEN2049 Singapore — Tech EZ KOL Club
October 5, 2026 | Event, Digital Assets, Blockchain, Web3, Networking, Singapore
One of NCFA's media partners Block Tides is co-hosting a Web3 and digital assets ecosystem networking and industry event, Tech EZ KOL Club by DigiMaaya this October 6 at Gardens by the Bay — bringing together KOLs, creators, founders, exchanges, investors, traders, and ecosystem leaders in one curated room.
📍 Flower Field Hall, Gardens by the Bay
📅 October 6, 2026
⏰ 7:00 PM – 10:00 PM SGT
Expect:
✨ High-value networking
🤝 Founder, investor & exchange introductions
📣 KOL + creator collaborations
🌐 Partnership, media & ecosystem opportunities
🏆 Leader Awards + Book Launch
🥂 Premium hospitality with a waterfront setting
🎟 Partner Pass — Free, subject to approval
💎 VIP Pass — 99 USDC
If you're in Singapore for TOKEN2049 Week, this is one of the rooms you’ll want to be inside.
👉 Register here:
https://luma.com/twvhx8s4
Hosted by DigiMaaya
Co-Hosted by AKARI × Block Tides
See you at the Bay. 🌊⚡
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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How Fintech Companies Can Document R&D Involving Machine Learning Models
Oct 5, 2026
Financial technology firms use machine learning to improve how they identify fraud, analyze risk, predict financial trends and verify identities. When researchers must conduct experiments to solve technical problems, detailed records provide evidence of the research process. Effective documentation connects the initial technical problem to the specific tests, results, decisions and resources that the developers used.
Define the Technical Objective
Project records are effective when they begin with a description of the technical goal. Managers can describe how the system is intended to function, the technical limitations that exist at the start and why current methods do not work. As an example, a firm might try to build a tool that identifies rare transaction sequences while ensuring the system does not increase the number of false alarms.
Technical problems that require investigation are a central part of the record. Stating that a firm built an artificial intelligence tool is not enough to show that experimental work happened. Documentation is more precise when it describes difficulties with the structure of a model, training data, the selection of variables, the accuracy of predictions, the ability of the system to handle more data, speed or how the tool works with existing financial platforms - these descriptions provide a record of the specific problems that developers tried to solve.
Record the Development Process
Development logs show how a machine learning system changes over time. Teams are encouraged to save information about the models they test, the datasets they use, changes to internal settings, training methods and the computing environments. Version control tools, experiment trackers, digital notebooks and coding logs are reliable evidence when employees update them frequently.
Unsuccessful experiments are important to document - When a model does not meet requirements, the record shows why developers changed their strategy and what they learned. Records are clear when they explain that a specific set of data variables caused many errors, which led developers to try a different way to organize data - this practice makes the sequence of experiments easy to follow.
Connect Experiments to Results
Scientific outcomes are clear when each experiment is linked to data and the resulting technical choices. Documentation is specific when it includes measurements like accuracy levels, recall rates, processing speed or how often errors occur. Developers choose these metrics based on the technical improvements they want to achieve.
These findings then justify the next steps - If a test produces poor results, the firm can record the specific limitation and the next method they tested - this creates a timeline that connects technical problems to experiments and progress. For firms that prepare reports for tax incentives like SRED, this narrative is helpful because it explains the context for the work.
Track Resources & Personnel
Financial technology firms are encouraged to keep records of the specific employees who performed technical tasks. Task management software, digital tickets and code contributions help confirm the involvement of software developers, data scientists and engineers.
Costs are also linked to project activities - Organizations can track expenses for employee salaries, software subscriptions, cloud computing power and testing environments. G6 Consulting is available to help firms organize these files so that technical activities and financial records are easy to compare.
Maintain Supporting Evidence
Evidence is accurate when employees collect it during the project instead of trying to remember details later. Code repositories, experiment logs, previous model versions and internal messages show what work happened and the date of the work. Storing the files in a central system ensures that future audits do not interrupt daily operations.
Standardized habits are useful for all machine learning projects. Each project is best served by a central file that lists the goals, technical problems, tests and results - this systematic approach ensures that the firm does not rely on vague summaries after the project is over.
Conclusion
Documenting research involves more than saving the final version of a model. Financial technology firms are more successful when they preserve evidence of their goals, technical challenges, tests, results and the resources they used. Consistent record keeping provides a history of experimental work and makes it easy to evaluate development activities.
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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