Retail Payment Activities Act (RPAA) – Canadian MSBs moving to Montana

Canadian Money Service Businesses (MSBs) with international operations are packing their bags and heading south, to Montana, the only US state without state-level MSB licensing. Montana is witnessing an influx of Canadian MSBs seeking refuge from the impending “Retail Payment Activities Act (RPAA)”, requirements to register with the Bank of Canada and other major changes.

The RPAA promises a stricter regulatory climate for MSBs. This translates to more paperwork, stricter compliance procedures, and licensing hurdles. For MSBs juggling international operations, these changes can be a compliance nightmare and a financial burden and defy the reasons for which they registered a MSB with FINTRAC in Canada in the first place.

Montana offers a welcome escape. Unlike other US states that require additional licensing on top of federal regulations, Montana relies solely on FINCEN (Financial Crimes Enforcement Network) oversight for MSBs. This simpler system is a major draw for Canadian MSBs seeking a smoother regulatory ride.

The long-term impact on both the Canadian and US financial ecosystems remains unclear. Canadian regulators might see a decline in the number of MSBs under their watch, while Montana could experience a surge in MSB activity-

One thing’s for sure: the RPAA is prompting a regulatory chess match, and Montana has emerged as an unexpected, yet potentially winning, move for Canadian MSBs navigating the changing game. For further information about Montana MSBs, see

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