Status: in development
Nothing on this page is a claim that any control is in place today. Soundy Pay Limited is pre-launch: FINTRAC registration is in preparation, we are not currently offering regulated money services to the public, and launch is subject to required registrations and approvals.
Everything below is being designed and documented now so that it is ready, tested on paper, and habitual before the first client instruction is ever accepted. This page is dated July 23, 2026 and will be revised as the program matures.
Our approach
Our planned services — foreign exchange dealing, remitting or transmitting funds, issuing or redeeming money orders and similar negotiable instruments, dealing in virtual currencies, and business payment services — sit squarely within Canada’s anti-money-laundering framework under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations.
We are building the program to fit that framework and the actual shape of our planned business: commercial clients, cross-border corridors, and documented instructions. The design principle is simple — compliance before commerce.
Governance and accountability
We are establishing a designated compliance officer role with direct access to management, supported by written policies and procedures that management formally adopts before launch. Responsibility will sit with named people, not with a mailbox, and the program will be resourced as a core function rather than an afterthought.
Business verification
We are designing procedures to identify and verify every business client before providing any service: confirming the entity’s existence and good standing, the people acting for it, and the nature of its business. A client we cannot verify is a client we will not serve.
Beneficial ownership
The planned onboarding process includes obtaining and assessing beneficial-ownership information — the individuals who ultimately own or control a client — and keeping it current. Opaque structures without a good explanation will be a reason to decline, not a puzzle to work around.
Transaction review
We are designing processes to review activity against each client’s stated profile — expected corridors, counterparties, and volumes — with written escalation paths when something does not fit. The aim is for every unusual pattern to have a named reviewer, a documented question, and a documented answer.
Recordkeeping
The service is being designed so that records required by law — client information, instructions, reviews, and decisions — are created as a by-product of doing the work, retained for the prescribed periods, and retrievable when a regulator or auditor asks. Records that hold up are one of our product principles, not just a legal duty.
Regulatory reporting
We are preparing processes for the reports the law requires of a money services business — including suspicious-transaction and other prescribed reports to FINTRAC — so that identifying, documenting, and filing them is a defined workflow from the first day services exist, with confidentiality handled as the law requires.
Sanctions screening
Planned screening covers clients, their beneficial owners, and payment counterparties against applicable Canadian sanctions lists and other lists relevant to the corridors we serve, at onboarding and on an ongoing basis, with documented handling of potential matches before anything moves.
Risk assessment
We are drafting a written risk assessment covering our planned products, client types, geographies, delivery channels, and the particular risks of virtual-currency dealing. It will set the risk appetite the rest of the program enforces, and it is designed to be refreshed on a schedule and after any material change.
Training
Everyone involved in the business will complete documented compliance training before launch and refresher training on a recurring cycle afterwards — covering our obligations, our procedures, and the practical question that matters most: what to do when something looks wrong.
Effectiveness review
The program design includes a periodic effectiveness review on the prescribed cycle, carried out by someone independent of the program’s day-to-day work, with findings reported to management and tracked to resolution. We want the program tested by someone whose job is to find its weaknesses.
Retail Payment Activities Act readiness
Separately from the anti-money-laundering framework, we are assessing which of our planned business payment services fall within the scope of the Retail Payment Activities Act. Any in-scope retail payment activity will begin only after applicable registration under that Act with the Bank of Canada, and the associated risk-management and incident-response expectations are part of the same preparation.
Registration under either framework, once completed, is a legal requirement — not an endorsement of Soundy Pay Limited by any authority.
Questions and corrections
If you work in compliance, banking, or regulation and see something on this page we should sharpen, we genuinely want the note. We do not yet publish a public contact channel; details will be published before any service becomes available.
Questions about this document
Soundy Pay Limited does not yet publish a public email address, telephone number, or contact form. Contact details will be published before any service becomes available.