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FINTRAC MSB · N300000193
EU PSP Partner · PSD2 Authorised

Payment operations
for EU digital commerce.
Powered through regulated partners.

Fora Pay provides merchant onboarding, payment orchestration, and settlement operations — enabled through a regulated partner ecosystem of licensed EU PSPs and authorised Open Banking infrastructure providers. AML/KYB governance maintained throughout.

Regulatory Status — May 2026
Legal Entity
Fora Pay Inc.
Province of Ontario, Canada
FINTRAC Registration
Money Services Business
N300000193
Active
EU Payment Services
Via Licensed EU PSP Partner
PSD2 / EMD2 · Sub-merchant arrangement
Open Banking · Enabled via Regulated Partners
vIBAN · C2B Payment Flows
FINTRAC · AML / KYB Compliance
PSD2 · Licensed EU PSP Partner Ecosystem
PCMLTFA · FINTRAC Reporting
SEPA · Settlement via Partner Infrastructure
Fora Pay · Operations & Orchestration Layer
Open Banking · Enabled via Regulated Partners
vIBAN · C2B Payment Flows
FINTRAC · AML / KYB Compliance
PSD2 · Licensed EU PSP Partner Ecosystem
PCMLTFA · FINTRAC Reporting
SEPA · Settlement via Partner Infrastructure
Fora Pay · Operations & Orchestration Layer
Operational foundation

Four principles that define how we operate.

01
Regulatory clarity
Fora Pay is a registered Canadian Money Services Business operating as a merchant operations and orchestration layer. EU payment services are delivered exclusively through authorised PSD2-licensed partners. The allocation of regulated responsibilities is documented, disclosed, and consistently applied.
02
AML/KYB governance
Every merchant undergoes structured KYB due diligence — entity verification, UBO identification, business purpose, risk classification. Ongoing transaction monitoring and FINTRAC reporting obligations are maintained throughout the relationship.
03
Open Banking only
Payment collection is supported exclusively through Open Banking C2B flows, enabled via regulated EU Open Banking providers within the partner ecosystem. No card processing. No anonymous instruments. No nested merchants.
04
Structural fund separation
Fora Pay does not hold or safeguard end-user funds. All EU consumer funds are received and safeguarded by the licensed EU PSP partner under PSD2 Article 10. Separation is contractual and independently auditable.
Partner ecosystem architecture

The complete
payment flow,
layer by layer.

Fora Pay operates as the merchant-facing operational layer — onboarding, KYB/AML, payment orchestration, and settlement. Regulated payment execution and Open Banking connectivity are provided by licensed partners within the ecosystem.


Every regulated function is performed by an entity authorised to perform it. Compliance teams can verify each layer independently, confirming no regulated service is attributed to an unauthorised entity.

Layer 1 · Counterparty
Digital Merchant
KYB-verified EU-facing merchant — e-commerce, SaaS, or digital goods operator. Contracted with Fora Pay; subject to ongoing AML monitoring and periodic review.
Merchant agreement · KYB · AML monitoring · Settlement
Layer 2 · Operations & Orchestration
Fora Pay Inc.
Canadian MSB (N300000193) · Ontario, Canada
Operations layer — not a licensed PISP or EU payment institution
Merchant Onboarding KYB / AML Payment Orchestration Reconciliation Settlement Initiation FINTRAC Reporting Partner Coordination
Sub-merchant arrangement · Regulated payment services via partner
Layer 3 · Regulated Payment Partner
Licensed EU PSP Partner
PSD2 / EMD2 authorised institution. Provides regulated payment services to EU end users; safeguards funds under PSD2 Art. 10; acts as GDPR data controller; operates vIBAN infrastructure; facilitates Open Banking connectivity through regulated providers.
Regulated Open Banking infrastructure · vIBAN · C2B collection
🏦
Open Banking Providers
Regulated third-party Open Banking infrastructure providers facilitate C2B bank transfers from EU consumer accounts — not operated by Fora Pay
📋
vIBAN Infrastructure
Virtual IBANs assigned per merchant by the EU PSP partner for segregated C2B payment receipt and automated reconciliation
💸
Settlement & Payouts
Net settlement disbursed to merchant bank accounts via SEPA, executed through EU PSP partner infrastructure on agreed schedule
Compliance & controls

AML governance
and operational controls.

Fora Pay's compliance framework operates under Canadian regulatory obligations — PCMLTFA/FINTRAC — and is aligned with international AML standards. The framework covers merchant onboarding, ongoing monitoring, and mandatory reporting.

🔍
KYB Due Diligence
Structured entity verification for all merchant applicants: incorporation documents, UBO identification (≥25%), business purpose assessment, source of funds, and risk classification prior to onboarding.
📡
Transaction Monitoring
Ongoing automated and manual monitoring of merchant transaction flows. Thresholds, velocity rules, and behavioural patterns reviewed continuously. Suspicious activity triggers STR filing with FINTRAC under PCMLTFA.
📄
Regulatory Reporting
Fora Pay files STRs, Large Cash Transaction Reports (LCTR), Electronic Funds Transfer Reports (EFTR ≥CAD 10,000), and Terrorist Property Reports (TPR) independently with FINTRAC.
🛡️
Fund Safeguarding
Fora Pay does not hold or custody end-user funds. All EU consumer funds are received and safeguarded by the licensed EU PSP partner under PSD2 Article 10. Structural separation is contractual and independently verifiable.
⚖️
Regulatory Cooperation
Fora Pay cooperates with competent Canadian and international authorities — including FINTRAC, courts, and regulators — responding to valid legal process such as production orders, warrants and MLAT requests, in accordance with applicable law.
📋
Policy Framework
Six published governance documents — Terms of Use, Privacy Policy, Cookie Policy, AML Policy, Complaints Procedure, and Law Enforcement Policy — reviewed at least annually and maintained alongside internal operational procedures.
Risk perimeter

What Fora Pay
does not do.

Explicit scope boundaries are a feature of a mature compliance programme. The following activities are contractually prohibited and operationally enforced.

No anonymous payment instruments
All payment flows are Open Banking C2B — fully identified bank account to bank account transfers, enabled through regulated partners. No prepaid instruments, no anonymous wallets, no bearer instruments.
No nested merchants
Fora Pay does not permit merchants to onboard their own sub-merchants. Each merchant is individually KYB'd. Marketplace structures with unknown sub-sellers are prohibited.
No unregulated high-risk verticals
Fora Pay does not onboard businesses operating outside applicable regulatory frameworks or without the licences required to operate in their jurisdiction and sector.
No end-user fund custody
Fora Pay is not a custodian. It does not hold wallets, maintain end-user balances, or provide stored value services. All fund holding is performed by the licensed EU PSP partner.
No card processing
Fora Pay is not a card acquirer. Payment collection is supported exclusively through Open Banking C2B bank transfers enabled through regulated payment partners.
What Fora Pay does.
  • Onboards and KYB-verifies digital merchants selling to EU consumers
  • Maintains AML monitoring and FINTRAC reporting obligations throughout all merchant relationships
  • Provides technical integration layer connecting merchants to payment infrastructure operated by licensed EU PSP and Open Banking partners
  • Orchestrates Open Banking C2B payment flows supported through regulated payment partners — vIBAN infrastructure operated by EU PSP partner
  • Handles reconciliation, settlement calculation, and payout initiation to merchant bank accounts
  • Maintains internal operational procedures for complaints handling and merchant support
  • Cooperates with competent authorities and regulators in response to valid legal process
  • Maintains marketing communication practices compliant with CASL and the EU ePrivacy Directive
Responsibility allocation

Who is responsible
for what.

Each operational and regulatory function mapped to the entity responsible. This allocation is contractually defined and available to compliance reviewers on request.

Function Fora Pay Inc. EU PSP Partner Merchant
Merchant KYB due diligence● Fora Pay
AML monitoring — merchant level● Fora Pay
FINTRAC STR / EFTR / LCTR filing● Fora Pay
EU end-user fund safeguarding (PSD2 Art. 10)✕ Not Fora Pay● EU PSP Partner
PSD2-regulated payment services to EU consumers✕ Not Fora Pay● EU PSP Partner
PISP / Open Banking payment initiation✕ Not Fora Pay● Via regulated OB providers
vIBAN assignment and C2B account managementOrchestration & reconciliation● EU PSP Partner operates
GDPR — EU end-user personal data controller✕ Not Fora Pay● EU PSP Partner
Merchant settlement and payout initiation● Fora Pay initiatesExecutes transfer
Consumer rights (EU Directive 2011/83/EU)● Merchant
Merchant website content compliance● Merchant
Scroll to see full table
Merchant operations

How Fora Pay runs
merchant operations.

01 · ONBOARDING
Structured merchant onboarding
Merchant applications are reviewed by Fora Pay's compliance team. Required documentation includes incorporation evidence, UBO declarations, source of funds, business model description, website review, and transaction volume estimates. Risk classification determines enhanced due diligence requirements.
KYBUBORisk RatingEDD where applicable
02 · INTEGRATION
Payment integration and vIBAN setup
Once onboarded, the merchant is connected through Fora Pay's integration layer. A dedicated vIBAN is assigned by the EU PSP partner for C2B payment receipt. Payment confirmation events — generated by the regulated payment infrastructure — are relayed to the merchant's system via webhook on each successful transfer.
vIBANAPIWebhookHosted Link
03 · MONITORING
Ongoing transaction monitoring
Merchant transaction activity is monitored continuously against expected patterns established at onboarding. Material deviations, structuring behaviour, and unusual counterparty patterns are escalated for review. Periodic merchant reviews conducted on a risk-rated schedule.
Automated TMSTR FilingPeriodic Review
04 · SETTLEMENT
Reconciliation and settlement
Fora Pay reconciles merchant transaction records against EU PSP partner settlement reports. Net settlement amounts — after fee deduction — are calculated and disbursed to merchant bank accounts on the agreed schedule. Full transaction-level reporting available via the merchant dashboard.
SEPANet SettlementReportingDashboard
Supported industries

Digital commerce verticals
we actively support.

All merchant applicants are assessed individually. Industry classification informs risk rating and due diligence depth — not eligibility per se.

🛒
E-Commerce
Online retailers selling physical or digital products to EU consumers. Payment collection supported through Open Banking C2B flows — enabled via regulated partners — removes chargeback exposure inherent to card-based digital commerce.
Typical risk: Standard · No enhanced licence required
🖥️
SaaS & Digital Subscriptions
Software-as-a-service platforms and subscription businesses monetising EU user bases. Recurring and usage-based billing models supported via Fora Pay's merchant integration layer and partner payment infrastructure.
Typical risk: Standard · No enhanced licence required
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AI Products & API Services
AI-powered products, developer tools, and API-based services with EU customer bases. Payment confirmation — delivered via partner infrastructure — enables immediate service activation on receipt of cleared funds.
Typical risk: Standard · No enhanced licence required
📚
Digital Content & Media
Publishers, course creators, and media platforms selling access to digital content. Bank-to-bank transfers facilitated through licensed payment partners are irrevocable, removing chargeback exposure on delivered digital goods.
Typical risk: Standard · Content review at onboarding
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Online Marketplaces
Platform businesses with defined merchant-of-record structures. Note: nested merchant models are not permitted. The platform entity is the sole onboarded merchant; sub-seller flows are outside scope.
Typical risk: Medium · Requires MoR structure confirmation
📦
Digital Goods & Software Licences
Software licence vendors and game publishers selling to EU consumers. Bank-to-bank payment flows — powered through regulated Open Banking providers — remove card fraud vectors that disproportionately affect digital goods sellers.
Typical risk: Standard · Product review at onboarding
Contact & enquiries

Ready to discuss
your payment operations?

Fora Pay reviews merchant applications and partnership enquiries on a structured basis. Initial review completed within three business days of receiving complete documentation.

Phone
+1 (647) 824-3697
Address
220-1110 Finch Avenue West
Ontario, Canada
AML
Anna Lukyanova
Compliance Contact
Legal
Legal Requests →
Attn: Anna Lukyanova
For Merchants
Merchant Application
Submit a merchant enquiry to begin the onboarding assessment. Provide your company name, jurisdiction, business model, estimated monthly volume, and target merchant category.
Submit application →
For Compliance Teams
Compliance Enquiries
Compliance and partnership teams may direct enquiries regarding Fora Pay's regulatory registrations, AML programme, or operational structure to our compliance contact below.
Contact compliance →
Legal & Authorities
Legal Requests
Requests for information from competent authorities must be submitted on official letterhead with valid legal process to the address below, marked for the attention of the Compliance Officer.
Submit request →