Who Is Captured
You are considered in scope if your business:
- Connects private ABMs to payment card networks to facilitate transactions
- Provides processing or settlement services for ABMs not owned by financial institutions
- Engages in cash loading, servicing, or technical operations of non-bank ABMs
If these apply, your company is now deemed a reporting entity under the PCMLTFA, subject to FINTRAC examination and ongoing compliance obligations.
What FINTRAC Now Requires
Private ABM acquirer entities must:
- Register with FINTRAC as an MSB or foreign MSB
- Appoint a Compliance Officer with overall program responsibility
- Develop a written compliance program outlining policies, procedures, training, and review schedules
- Complete a Risk-Based Assessment (RBA) to identify inherent and residual risks
- Conduct client identification, beneficial ownership verification, and PEP assessments
- Submit required reports including Suspicious Transaction Reports (STRs) and Listed Person or Entity Property Reports
- Maintain records of identification, transactions, and reporting for at least five years
Why This Change Matters
Private ABM networks have long been viewed as potential high-risk entry points for cash-based money laundering. FINTRAC’s inclusion of this sector strengthens transparency within Canada’s payment ecosystem by bringing acquirer services under direct regulatory oversight.
Importantly, Québec’s Revenu Québec has already been regulating private ABM acquirers and operators as MSBs under its provincial framework for several years. The new federal expansion harmonises national standards by aligning FINTRAC’s federal requirements with Québec’s earlier compliance expectations — ensuring consistent supervision across Canada.
Next Steps for Businesses
- Confirm whether your operations qualify as acquirer services under FINTRAC’s definitions
- Register with FINTRAC if you are not already listed as an MSB or foreign MSB
- Develop or update your AML/ATF program, ensuring it includes written procedures and defined escalation processes
- Train your staff on identification, monitoring, and suspicious activity reporting
- Prepare for examination by documenting how your controls operate in practice
Need Support with Your New ABM Compliance Obligations?
C&G Professional Services Inc. works with regulated entities across Canada to build and operationalise AML/ATF programs that meet FINTRAC’s evolving expectations. Contact Claudius Otegbade, Principal Partner.