As you might already be aware, the final regulations related to the Retail Payments Activities Act (RPAA) were recently released. If you didn’t see them, here is a link.
RPAA will apply to payment service providers (PSP) that perform one or more of the five payment functions defined within the legislation:
Providing or maintaining a payment account
Holding funds
Initiating an electronic funds transfer
Authorizing or transmitting instructions about an electronic funds transfer
Clearing or settling
If you are a money services business (MSB) or PSP, this legislation will almost certainly apply to you. Generally, the obligations under the RPAA will require you to have an operational framework, a safeguarding client funds framework, and an incident reporting framework. The Bank of Canada (the Bank) is expecting registration to begin November 1, 2024, with full compliance expected by November 1, 2025.
If you have not already done so, please sign up to receive updates from the Bank. You can do so here.
The Bank is currently seeking volunteers to help with their registration pilot project. You can sign up here until December 15th, 2023.
There are many other opportunities to get involved in the industry discussions or provide feedback. You can also contact us directly to find out more about industry participation. The more participation we can get from the community, the more likely we are to effect some real change.
Although this new legislation brings with it many compliance challenges, the AML Shop is here to help. If you are not sure how or if RPAA applies to your business, or if you have any questions, please do not hesitate to reach out to us.