End-User Fund Safeguarding for Registered PSPs
If you hold funds for end users, safeguarding is not optional. We design the accounts, the written framework, and the legal opinions the Bank of Canada expects, so your funds and your registration are both protected.
Safeguarding Is a Substantive Legal Obligation
Any PSP performing the holding funds payment function must safeguard those funds. The Bank of Canada treats this as a substantive requirement, not a declaration. Failure to maintain continuous safeguarding is a serious violation, and weak arrangements are among the most common reasons applications stall.
Two Methods, One Written Framework
You may hold end-user funds in trust, or in a segregated account backed by insurance or a guarantee. Whichever you choose, the regulations require a written framework covering how funds are protected, how end users access them, and how they rank if your business becomes insolvent. The account alone is never enough.
Method Selection
We assess whether a trust or a segregated account structure suits your business best.
Framework Drafting
We write the safeguarding framework the regulations require, covering risks and controls.
Legal Opinions
We coordinate the written legal opinions the Bank expects on your safeguarding arrangement.
Banking Support
We prepare the documentation banks demand before opening a compliant safeguarding account.
Ready to Simplify Your Compliance?
PSPs We Help Safeguard
We support payment processors, digital wallets, remittance operators, and any registered PSP holding funds on behalf of Canadian end users. Every framework reflects the funds you hold and the way your customers access them.
We support banks with program design, oversight, & regulatory examination readiness.
We help credit unions meet obligations proportionate to their membership and scale.
We handle registration, renewals, reporting, & controls FINTRAC expects from you.
We cover Bank of Canada registration alongside your anti money laundering obligations.
We establish what your wallet activity triggers, then build only what applies.
We build compliance around what your product does, before volumes and questions arrive.
We register virtual currency dealers and build the reporting their activity demands.
We support financial institutions across registration, program build, and reporting duties.
Why PSPs Trust Our Safeguarding Work
Insolvency Tested
The Bank expects your arrangement to hold up in insolvency, so we build frameworks that survive that scrutiny.
Bankable Documentation
Safeguarding accounts are hard to obtain, so we prepare the depth of documentation banks actually require before they say yes.
Framework Complete
An account without a written framework fails the regulations, and we deliver both together as a single defensible package.
Serving PSPs Across Canada
We support payment service providers nationwide, from Toronto and Montreal to Vancouver and Calgary, and we also advise foreign PSPs safeguarding funds that are held for Canadian end users wherever they operate.
Let's Talk About Your Compliance Needs
Schedule a Free Consultation
Whether you’re starting a new MSB or need ongoing AML support, our team responds within one business day.
Fund Safeguarding Questions
Clear answers to the questions payment service providers ask most about safeguarding end-user funds under the Retail Payment Activities Act and its regulations.
Which PSPs must safeguard funds?
Any PSP performing the payment function of holding funds on behalf of end users must safeguard those funds continuously, without exception.
What safeguarding methods are permitted?
Holding funds in trust, or in a segregated account protected by insurance or a guarantee. Both require a written framework explaining how the protection works.
Is deposit insurance enough on its own?
No. Deposit insurance protects the accountholder if the financial institution fails. It does not protect end users if your own business becomes insolvent.
Do we need a legal opinion?
The Bank of Canada expects written legal opinions on safeguarding arrangements, addressing validity, regulatory compliance, and effectiveness in an insolvency scenario.
Why do banks refuse safeguarding accounts?
Banks assess your compliance maturity closely. Weak frameworks, unclear fund flows, and missing documentation are the usual reasons a safeguarding account is declined.