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Legal & Regulatory

Last updated: [Jan 23, 2026]

At a Glance

Regulated by: Bank of Canada (Entity ID: RPS0002273) and FINTRAC (MSB No. C100000306).

Client Funds: safeguarded in trust in segregated accounts at Tier-1 Canadian banks, in accordance with applicable law.

Services: Foreign exchange and payments (not a bank, trust company, or deposit-taking institution)

1. Regulatory Status

FP Operations Ltd., doing business as FirmPay (“FirmPay”, “we”, “our”, “us”), is a Canadian-based foreign exchange and payment services provider.

FirmPay is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business (MSB No. C100000306) and is subject to applicable Canadian anti-money laundering and counter-terrorist financing legislation, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations.

FirmPay is registered as a payment service provider (Entity ID: RPS0002273) with the Bank of Canada under the Retail Payment Activities Act (RPAA) and is subject to ongoing supervisory oversight by the Bank of Canada, including applicable safeguarding, operational risk management, and reporting requirements.

FirmPay operates from Ontario, Canada, and provides services on a non-face-to-face basis through its online platform and supported operational channels.

2. Nature and Scope of Services

FirmPay provides foreign exchange and payment services, including domestic and cross-border electronic funds transfers and related foreign exchange conversion services.

FirmPay’s services are intended to facilitate commercial payments and foreign exchange transactions only. FirmPay does NOT:

  • operate as a bank, trust company, or deposit-taking institution;
  • provide investment, securities, derivatives dealing, or advisory services;
  • offer interest-bearing accounts or insured deposits; or
  • provide legal, tax, or investment advice.

Use of FirmPay’s services does not create any fiduciary, advisory, custodial, or trustee relationship, except solely and to the limited extent required for the safeguarding of end-user funds where mandated by applicable payment services legislation, and for no other purpose.

3. Safeguarding of Client Funds

Where FirmPay holds end-user funds for the purpose of performing a retail payment activity, such funds are safeguarded in accordance with the requirements of the RPAA, the Retail Payment Activities Regulations, and supervisory guidance issued by the Bank of Canada.

FirmPay safeguards eligible end-user funds by holding such funds in trust in segregated safeguarding accounts established with Tier-1 Canadian banks. These safeguarding accounts are operationally and legally segregated from FirmPay’s own operating funds and are used exclusively for the safeguarding of end-user funds.

End-user funds that are held by FirmPay are held in trust for the benefit of end users, subject to the terms of the applicable trust arrangements, governing law, and regulatory requirements. FirmPay maintains recordkeeping, reconciliation, governance oversight, and escalation processes designed to identify and address safeguarding failures or shortfalls without undue delay.

Safeguarding arrangements apply only where funds are held by FirmPay and FirmPay is indebted to the end user for those funds. Funds received with concurrent instructions for immediate transfer may not be considered held funds.

4. Regulatory Compliance Program (Overview)

FirmPay maintains internal policies, procedures, and controls designed to support compliance with applicable Canadian legal and regulatory requirements, including those relating to:

  • customer due diligence and identity verification;
  • transaction monitoring and risk-based controls;
  • sanctions compliance and prohibited activity screening;
  • governance, training, and internal oversight; and
  • recordkeeping and regulatory reporting.

FirmPay applies a risk-based approach to onboarding, transaction monitoring, and ongoing client relationships. FirmPay may impose restrictions, require additional information, suspend transactions, or decline or terminate services where required by law, regulation, or internal risk assessments.

5. Operational Risk Management and Incident Response

FirmPay has implemented an operational risk management and incident response framework designed to identify, assess, manage, and respond to operational risks and incidents that could affect its payment services or end users.

FirmPay is subject to ongoing notification, reporting, and supervisory requirements under the RPAA, including obligations to notify the Bank of Canada of certain safeguarding incidents and operational risk events, in accordance with applicable law and supervisory guidance.

The existence of operational risk management or incident response processes does not imply uninterrupted service availability, the prevention of all incidents, or any obligation to compensate end users, except where required by applicable law.

6. Risk Disclosure

Use of foreign exchange and payment services involves inherent risks, including but not limited to:

  • foreign exchange rate fluctuations;
  • delays or failures involving third-party financial institutions or service providers;
  • operational or systems disruptions;
  • legal, regulatory, or sanctions-related restrictions; and
  • cross-border payment and settlement risks.

FirmPay does not guarantee execution timing, exchange rates, or uninterrupted service availability and does not assume responsibility for losses resulting from market movements or circumstances beyond its reasonable control.

No information on this website should be relied upon as a guarantee of performance, availability, or outcomes.

7. No Advice; No Reliance

Information made available through FirmPay’s platform or website is provided for general informational purposes only and does not constitute legal, tax, investment, or other professional advice.

FirmPay does not guarantee profitability, outcomes, or suitability of its services for any particular purpose. Clients remain solely responsible for determining whether the use of FirmPay’s services complies with applicable laws and meets their own commercial, legal, and tax requirements.

8. Relationship to Terms of Service

This Legal & Regulatory Disclosure is provided for informational purposes only and forms part of, and is incorporated by reference into, FirmPay’s Terms of Service.

In the event of any inconsistency between this Disclosure and the Terms of Service, the Terms of Service shall govern.