Unique AML Requirements for Prepaid Cards


TCAE is excited to invite Ana Badour of McCarthy Tetrault and Michelle Beyo of Finavator Inc to discuss the unique AML requirements that will apply to “prepaid payment products” and “prepaid accounts” following amendments to the regulations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the “PCMLTFA”) that will go into effect on on June 1, 2021. In this session, the speakers will provide a high level overview of the prepaid card industry and types of prepaid products available in the market and potential AML risks associated with these. They will also discuss how the PCMLTFA requirements will apply to these types of products, and provide some practical considerations for ensuring compliance.


  • Understanding what a “prepaid payment product” and a “prepaid account” is (and what it is not)
  • Understanding the various types of participants in the prepaid product ecosystem
  • Understanding the AML obligations that apply to these types of products and who is responsible for ensuring compliance
  • Understanding how these obligations differ from AML requirements applicable to other products


Ana Badour  |   Partner, McCarthy Tetrault

Ana Badour co-leads McCarthy Tétrault LLP’s national Fintech Group.  She is a partner in their Financial Services Group and a Certified Anti-Money Laundering Specialist. She advises financial services entities, including financial institutions and Fintech entities, on regulatory compliance matters, including with respect to consumer protection, anti-money laundering and other regulatory requirements. She holds a LLM in Banking and Financial Law from Boston University, a LLB from Osgoode Hall Law School, and a BMath (Operations Research) from the University of Waterloo. 

Michelle Beyo  |  Founder & CEO, Finavator Inc

Michelle Beyo, a payment, loyalty and blockchain executive with more than 20 years of extensive industry experience driving innovation across the retail and payments industry. Michelle is the Founder of Finavator, a strategic advisor for multiple FinTechs, a Money 20/20 Rise Up alumni, a Women in Payments 2020 Global Council member, Board Member at Open Banking Initiative Canada and Host of OBIC Open Banking Insight Series alongside Senator Colin Deacon.

Nelu Sund  |  Country Manager, PayCompliance

Nelu is an experienced Compliance Professional with a passion for risk management, investigations and maximizing the efficiency of business operations. Nelu has over twenty years of AML experience from the front lines through operations to heading the Compliance department of a national MSB. Nelu currently serves as the Country Manager for PayCompliance (HK) Ltd, an international consulting firm to the Payments Industry. A Certified Anti Money Laundering Specialist (CAMS) and Certified Financial Crime Specialist (CFCS), she strives to continue to learn and expand her knowledge. Passionate about sharing her knowledge and forming valuable connections between all participants in the AML and FINCRIME sphere, Nelu actively mentors both new entrants to the industry as well as experienced professionals, across the globe.