The Bank of Canada (Boc) has initiated enforcement actions against PSPs under the RPAA and is naming non-compliant parties ❌

The BoC recently started publicly listing enforcement decisions on their website - naming each company that has committed a violation where an enforcement action has been taken. These records will stay public for 5-years.

This is not just about potential monetary impact… It's about reputational damage.

In light of these actions, PSps and MSBs need to keep the following in mind:

🔴 Unregistered parties were the first targets. All of the entities in this first batch of violation notices were in breach of section 23 by running payment activities before registering under the RPAA. This is considered a very serious violation.

🔴 Public visibility. Yes, your banking partners and competitors can see these enforcement decisions. Not a good look!

🔴 More violation types to come. The bank has confirmed that this is just the beginning and, in addition to this first batch, other enforcement decision types are to come.

🔴 Be proactive. Confirm your registration status before you begin operating activities and review Supervisory Policies to understand the bank’s expectations and enforcement process. Additionally, if you discover a gap in compliance, taking quick, documented corrective action is recommended and the BoC will take it into account in their assessment.

🔴 Product changes. Remember, rolling out new partnerships, payment features or updates to corporate status can trigger RPAA obligations before you go live. You must always notify the bank of any new or significant changes to your operations and activities.

If you haven’t registered yet - you could potentially face the same “name and shame” treatment. Get in touch with our RPAA expert team today to get your registration application started. Link in comments.