Free webinar - Transacting Both Ways Across the Atlantic: Canada, UK and EU
Overview
Canada has become a serious exporter of payments capability. Canadian money services businesses, payment service providers and fintechs are moving cross-border faster than at any point in the last decade, and the UK and EU remain the destination of choice for firms that want scale, corridor depth and a credible regulatory badge.
The problem is that the journey is rarely as linear as the business case suggests. Firms arrive at the FCA’s door with a mature Canadian compliance programme and assume it travels. It doesn’t. Not automatically, and not in the way most applicants expect. At the same time, the ground has moved on both sides of the Atlantic. Canada’s Retail Payment Activities Act is now fully operational, with the Bank of Canada supervising and enforcing rather than onboarding. The 2026 amendments to the PCMLTFA have widened the perimeter again. And in the UK, the FCA’s new safeguarding regime came into force in May 2026, while HM Treasury has confirmed the Payment Systems Regulator will be folded into the FCA and payments law will be brought inside the FSMA framework. In Europe, the PSD3/PSR package has cleared political negotiation and is heading for adoption, collapsing the payment institution and e-money institution regimes into a single licence.
For a Canadian firm planning a transatlantic move, this is not a stable picture to plan against. It is a moving one.
This session brings together three practitioners who work at the sharp end of it (two from the Canadian side, one from the UK and European side) to walk through what a Canadian fintech or MSB actually has to do, in what order, and where the expensive mistakes are made. It is a practical conversation, not a legislative recital: what regulators are looking for right now, what they are refusing, and what a credible expansion plan looks like from both ends of the corridor.
What will be discussed
The Canadian baseline: what you’re already carrying
Which activities pull a business into the money services business perimeter under the PCMLTFA (foreign exchange dealing, money transferring, money orders and traveller’s cheques, dealing in virtual currency, and crowdfunding platform services), and where payment processing sits in relation to that line
Domestic MSB versus foreign MSB: why the trigger is directing services at persons in Canada, not where you are incorporated, and why that test increasingly cuts both ways for firms building outward
What a FINTRAC compliance programme has to contain to survive examination: the compliance officer, written policies and procedures, the risk assessment, ongoing training, and the two-yearly effectiveness review
Reporting in practice: suspicious transactions, large cash and large virtual currency transactions, electronic funds transfers and terrorist property, plus Travel Rule obligations and the aggregation rules that catch people out
The March 2026 PCMLTFA amendments and what they mean going forward: universal enrolment, the stablecoin issuer registration requirement, and expanded penalty exposure
Why FINTRAC’s recent registration revocations matter more than the headline penalties, and what programme decay looks like to a regulator
The Retail Payment Activities Act and the Bank of Canada
Who is caught, who is genuinely out of scope, and how narrow the “incidental to another business activity” exclusion really is
Life after the transition period: registration is now a precondition to activity, not a parallel work stream
The operational risk management and incident response framework: what the Bank expects to see, and the gap between a documented framework and a functioning one
Safeguarding end-user funds: the Bank’s supervisory guideline, and how it compares with what the FCA now demands of the same firm in the UK
Annual reporting, significant change notifications and incident reporting: the ongoing supervisory rhythm that firms consistently under-resource
The Bank of Canada as a live supervisor: what its first enforcement actions signal about appetite and speed
Where the RPAA and the PCMLTFA overlap, where they diverge, and how to run both off a single control set rather than two parallel programmes
How money flows change the analysis
Why the same product can be squarely in scope in one corridor and out of scope in another
Direction of travel: Canada-to-UK, UK-to-Canada, and third-country corridors routed through either
Principal versus agent, and who actually owns the payer and payee relationship, which is the question that determines most of the answer
When a Canadian entity can serve UK customers from Canada, and the point at which it can no longer
Group structures, intragroup settlement and the “directed at” tests applied on both sides of the Atlantic
The UK pathway and the FCA’s current appetite
The end of passporting and what the UK establishment requirement means in substance: head office, mind and management, and the difference between a UK business and a UK letterbox
Choosing the right permission (authorised payment institution, small PI, authorised EMI, small EMI), and what that choice locks in for capital, safeguarding, scope and future optionality
What a credible application pack contains: the regulatory business plan, financial projections that survive challenge, the wind-down plan, governance and individual approvals, outsourcing and third-party arrangements
Safeguarding under the FCA’s Supplementary Regime, in force since 7 May 2026: reconciliations, books and records, acknowledgement letters, audit requirements and reporting, plus how to plan around the deferred Post-Repeal Regime rather than wait for it
What the FCA is actually assessing at the gateway, why applications stall, and the recurring reasons overseas-owned applicants are refused or withdraw
The moving perimeter: the PSR’s consolidation into the FCA, HM Treasury’s April 2026 payments package, the migration of the PSRs 2017 and EMRs 2011 into the FSMA framework, and stablecoins being brought inside the payments perimeter rather than treated as a separate crypto regime
Europe, sequencing and the practical build
UK or EU first, or both? Two authorisations, two cost bases, and the strategic logic behind each route
PSD3 and the PSR: what the agreed texts change, the collapse of the PI and EMI regimes into a single authorisation, and the implementation runway firms should be planning against now
The EU AML package and the single rulebook, and what a Canadian group’s existing programme will and won’t satisfy
MiCA where digital assets sit anywhere in the model
The unglamorous blockers: banking and safeguarding account access for a foreign-owned applicant, realistic timelines and cost, who has to physically be in the UK, and what can stay in Canada
What you’ll take away
By the end of this session you will be able to:
Determine your perimeter on both sides: assess whether your business is caught by the PCMLTFA as an MSB or foreign MSB, whether the RPAA applies alongside it, and where UK or EU authorisation becomes unavoidable rather than optional.
Pressure-test your Canadian programme against what FINTRAC and the Bank of Canada examine against today, including the March 2026 amendments and the current enforcement pattern, and identify where a programme built for registration falls short of one built for supervision.
Explain how money flows drive obligations: articulate why direction, structure and the location of the customer relationship change the regulatory answer, and apply that analysis to your own corridors.
Map the UK authorisation route: identify which permission fits your model, understand what the establishment requirement demands in practice, and know what a credible FCA application pack contains before you start writing it.
Anticipate FCA expectations rather than react to them, including the safeguarding rules now in force, the direction of travel on the UK payments perimeter, and the specific weaknesses that cause applications to stall.
Make an evidenced sequencing decision: choose between a UK-first, EU-first or dual-track strategy with a realistic view of timeline, cost, resourcing and the PSD3/PSR runway.
Who should attend
Founders, CEOs and COOs of Canadian MSBs, PSPs and fintechs with UK or EU ambitions
Chief compliance officers, MLROs and heads of financial crime
General counsel and heads of legal
Corporate development, strategy and market expansion leads
Investors and boards assessing the cost and deliverability of a transatlantic plan
UK and EU advisers, banking partners and correspondents with Canadian clients
The session assumes working familiarity with payments and financial crime compliance. It is pitched at practitioners, not at a general audience.
The panel
Panellists
Gilbert van Roon
UK and European perspective
Sean Parker
Canadian perspective
Cindy Zhang
Canadian perspective
Moderator
Jonny Greenstein