Retail Payment Activities Act updated: tighter anti-money-laundering grounds for refusing or revoking PSP registration

Plain-language summary · AI-assisted · not legal advice

The Act has been amended to sharpen the anti-money-laundering criteria that allow the Bank of Canada to refuse or revoke a payment service provider's (PSP) registration. The language now refers to being found guilty of an 'offence' (rather than 'contravening a provision') under the Proceeds of Crime Act, and adds section 77.01 as a new triggering offence. Administrative penalty history that can trigger refusal or revocation is also expanded to include 'compliance order violations,' not just serious or very serious violations. Two future amendments (not yet in force) are flagged: one would bring certain encrypted or tokenized payment instrument transmission into the definition of 'payment function,' and another would require PSPs to notify additional prescribed parties about operational incidents. PSPs applying for or holding registration should review their compliance history under the Proceeds of Crime Act — including any compliance order violations — against these updated grounds.

Who this affects: payment service providers applying for registration · registered payment service providers · compliance and legal teams at fintech and payments companies · Bank of Canada regulated entities