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Cards & Payments
Access to the infrastructure and providers required to build the product.
Medici Expert Cases
From a European EMI to a Canadian MSB + RPAA Structure
The product needed cards, third-party transfers and retail customers. A European EMI was the obvious route, not necessarily the right one. We mapped each function to the Canadian regime and completed the MSB registration from scratch in 6 weeks.
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Case
at a Glance
Client:
Payments / crypto company
Situation:
Payments product in development: cards, third-party transfers, retail users
Challenge:
Launch payment functionality without the time and capital of a full European EMI
Medici Scope:
Regulatory strategy · MSB registration · RPAA · Canadian setup · Banking and integrations
Jurisdiction:
Canada
Timeline:
6 weeks to MSB registration*
Outcome:
MSB registered · Banking partners connected · Product integrations under way
Context
The client needed payment capabilities, not an EMI for its own sake.
The product required cards, third-party transfers and services for retail customers.
A European EMI would cover that.
A CASP alone would not cover the payment functions at all.
The question therefore shifted from "which licence?" to "what does this product need to be authorised to do?"
The Challenge
One product. Several regulatory layers.
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Third-Party Transfers
Payment functionality beyond the scope of a standalone CASP.
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Retail Customers
The requirements triggered by serving end users.
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Time & Capital
A route that does not require a full EMI where the model does not need one.
From Strategy to Banking Rails
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Product Mapping
Cards, transfers, retail and crypto flows checked against the regulatory perimeter.
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Regulatory Structure
MSB plus the applicable RPAA requirements.
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MSB Registration · 6 weeks
FINTRAC registration completed from scratch.*
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Canadian Setup
Corporate, accounting and local operational infrastructure for a non-resident client.
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Banking & Integrations
Banking partners, onboarding and APIs.
What Made the Case Difficult
Similar licence names. Very different scope. In plain terms:
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EMI (EU)
Electronic money institution licence. Broad and passportable across the EU, but capital-intensive and slow to obtain.
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MSB (Canada)
Registration with FINTRAC, Canada's financial intelligence unit, for money services such as transfers, currency exchange and virtual currency dealing. Primarily an AML regime.
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RPAA (Canada)
The Retail Payment Activities Act. Payment service providers serving end users register with the Bank of Canada and meet requirements on safeguarding and operational risk.
Our Approach
Product first. Regulatory structure second. We mapped each product function against the regulatory perimeter and compared the Canadian route with the EMI the client had originally considered.
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FINTRAC / MSB
for the money services activities
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Bank of Canada / RPAA
for the retail payment activities
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Canadian operational setup
to make the structure workable for a client operating from abroad
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Banking & payment partners
to move from registration to an operating product
The Outcome
MSB registered in 6 weeks. Banking and integrations followed.
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6 Weeks
MSB registration completed from scratch.*
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Regulatory Structure
MSB and the applicable RPAA requirements mapped to the product.
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Banking
Partners identified and onboarding supported.
04
Integrations
The project moved into API integrations for the payment infrastructure.
The client proceeded on a route requiring less time and capital than the full EMI originally considered.*
*Timelines, costs and regulatory requirements depend on the specific business model and services. MSB + RPAA is not a direct equivalent of, or substitute for, an EMI in every case.
Considering an EMI?
Start with what the product needs to do.
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Which functions do you actually need?
Cards, transfers, acquiring, retail payments, crypto on/off-ramps.
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What is the real cost of the structure?
Not only regulatory capital, but substance, compliance staff, banking and infrastructure.
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Do you need the full EMI perimeter?
Depending on the model, a different combination of registrations and banking partners may cover the required functions.
The question is not which licence is better. It is which structure fits the product.
Building a Payments or Crypto Product?
Tell us what the product needs to do. We will map the regulatory perimeter and assess the structure against your functionality, timeline and budget.
Discuss Your Case