Banking as a Service
BaaS platforms enabling non-bank companies to offer banking products raise questions about liability, diligence, and regulatory exposure of each party.
Infrastructure Fintech
Fintech legal intelligence for infrastructure innovators and operators in Canada.
Practical legal and regulatory information for infrastructure and embedded finance teams navigating role allocation, regulated activity, vendor diligence, and partner risk in Canada.
Topics within this pillar
Infrastructure companies often carry regulatory and contractual risk even when they are not the regulated entity facing customers.
FINTRAC Compliance
How infrastructure providers may engage FINTRAC obligations depending on their role.
Payment Structuring
How infrastructure role allocation and fund flows affect regulatory treatment.
MSB Banking Risk
Banking and processor diligence issues relevant to infrastructure providers.
FINTRAC/MSB Hub
Central map for MSB and FINTRAC analysis relevant to infrastructure products.
Infrastructure companies often carry regulatory exposure they did not design for.
Role allocation in the transaction chain — not direct customer contact — determines who bears FINTRAC obligations, banking risk, and contractual liability.
Infrastructure models in Canada
Responsibilities are distributed across multiple entities — the key question is who bears regulated activity and how.
Payments infrastructure
Processing, routing, or managing payments as an infrastructure provider may engage MSB registration analysis depending on custody and fund flow.
API platforms
Enabling developers to integrate financial functionality into applications requires careful consideration of role allocation in the transaction chain.
Embedded finance platforms
Allowing non-financial companies to offer financial products raises questions about who is the regulated entity and how obligations are allocated.
Data and open banking
Financial data access and connectivity raise questions about privacy obligations, data governance, and evolving open banking frameworks.
Custody and safekeeping
Holding or safeguarding financial assets on behalf of others typically engages registration and conduct obligations.
Practical analysis on infrastructure
View all insights »Banking-as-a-Service and partner risk
BaaS products depend on regulated bank sponsors whose requirements, risk appetite, and operational decisions can determine whether and how the fintech product can operate.
Buy now pay later regulation in Canada
BNPL products in Canada face evolving disclosure and consumer protection requirements that depend on product structure, term length, and cost of credit.
Common AML program failures for Canadian MSBs
The compliance program failures that most frequently produce FINTRAC findings are structural, not incidental — and most are preventable.
Need legal and regulatory clarity on your infrastructure product?
Use fintechlawyer.ca to understand the Canadian rules, risks, and market context behind financial infrastructure — or request a consultation.