Conduit

What is verified today

Register-verified, Canada. The Bank of Canada’s registry of payment service providers records 12835304 Canada Inc., trade name Conduit, as Registered since 7 April 2026, with no violations recorded. FINTRAC’s money services business registry records the same entity as Registered under MSB number M23837123, first approved 23 May 2023 and running to 27 August 2028, with services recorded as Foreign Exchange, Money Transferring, Virtual Currency and PSP. Both read on 25 September 2026. That is more than a name match: the numbers, dates and declared services all come from the registers rather than from Conduit.

Not verified, United States. Conduit Technology, Inc.’s FinCEN money services business registration stays company-reported. FinCEN’s registrant search at www.fincen.gov/msb-registrant-search returns HTTP 404 and its MSB state selector rendered no result rows to our browser on 25 September 2026.

Operating status, company-reported. Conduit’s homepage, read on 1 October 2026, offers global payouts and pay-ins, named USD virtual accounts and IBANs “through licensed banking partners”, and crypto wallets, and its MTA is written for existing clients. We treat those services as company-reported live; we found no independent evidence of production use or volume.

Company-reported. Everything about the product, the banking partners, the funds flow and the country policy below. Conduit’s own site says it “is a financial technology company, not a bank” and that “any banking services made available through Conduit are provided by third-party banking partners”.

Not established. Which corridors and currency pairs are supported, which institutions hold client funds, pricing, and any named client.

Entity and authority

Note what these checks do and do not cover. They confirm two registrations held by the Canadian entity on the dates shown. They say nothing about the US entity’s permissions, about which corridors are open, or about how any particular transaction is protected. The US side is also the part the agreement leans on hardest (it is deemed performed in Montana), and it is the part we could not confirm, which is a limit on us rather than a finding about Conduit.

Who holds funds in transit

This is where Conduit’s paperwork rewards close reading, because it answers the question twice and the two answers cover different transactions.

The default, Section M. “Conduit maintains Client funds in safeguarded accounts that are segregated from Conduit’s corporate operating accounts, including, when available, accounts held for the benefit of Clients (FBO Accounts) with regulated financial institutions.” Client funds may sit at one or more Asset Providers, in segregated or for-benefit-of accounts, and Conduit may change those providers at any time without naming them.

The carve-out, Pre-Funded Conversions. Where Conduit settles from its own capital before taking in what you deliver, the agreement says something different and says it deliberately. At the Settlement Point “title to, and all legal and beneficial ownership of, the value Client delivered pass to Conduit”. The transaction “constitutes a purchase and sale … and not the receipt of Client’s money or its equivalent for transmission”. Any transitory holding of your value before that point, including “in an intermediary or staging wallet or account”, is “not undertaken as safeguarding for, or transmission on behalf of, Client”. And then, explicitly: “the pre-settlement safeguarding and beneficial-ownership provisions of Section M do not apply to a Pre-Funded Conversion”.

Read plainly: under the MTA, Conduit treats the delivered value as its own property from the defined Settlement Point and assigns the risk of any later sale or conversion to itself. For that class of transaction you are a counterparty who has sold something and been paid, rather than a customer whose money is being safeguarded. Two qualifications belong here. Settlement can be effected by crediting your account rather than by paying out funds you hold elsewhere, and the published material we read does not establish whether an account credit leaves any withdrawal, counterparty or insolvency exposure. And Section M is itself conditional on its own terms: it applies “when applicable”, and the for-benefit-of accounts it describes apply “when available”. The agreement also says nothing in the subsection alters Conduit’s status or registration as a money services business.

Set that next to the register. The payment functions 12835304 Canada Inc. has declared to the Bank of Canada include “holding of funds on behalf of an end user until they are withdrawn by the end user or transferred to another individual or entity”. Both things can be true, since the declared function can describe the Section M flows while the carve-out governs principal trades, but the published material does not tell you which of your transactions will be which. That is the question to put in writing: which of my flows are Pre-Funded Conversions, and what proportion of my money is therefore outside Section M?

The country policy Conduit actually publishes

Conduit’s restricted-countries page links a PDF of its internal policy, RISK-004b Country Risk Rankings, dated 20 April 2026, with the page marking list version 2.3 and a last update of 5 May 2026. It is not a summary. It is the working table: 243 countries and territories, each with a master index score, the number of sources behind that score, a five-band risk rating and Conduit’s own decision. The page also states the default: “Any country not listed here is Allowed by Conduit and all Asset Providers.”

The 18 prohibited: Afghanistan, Burundi, Cuba, Eritrea, Haiti, Iran, North Korea, Libya, Mali, Myanmar, the Russian Federation, Sint Maarten, Somalia, South Sudan, Sudan, Syria, Venezuela and Yemen.

Cross-tabulating the risk band against the decision shows how the policy actually behaves, and it is not a simple threshold. All 20 Very Low and all 49 Low countries are Allowed. Of 105 Medium countries, 104 are Allowed; Zambia is the lone Medium EDD. Of 48 High countries, 47 are EDD; French Polynesia is the lone High Allowed. And the three countries in the Very High band, the Central African Republic, Chad and the Democratic Republic of the Congo, are EDD rather than Prohibited.

That last line is the interesting one, and it needs care, because the table carries three different things: a numeric score, a band label and a final decision. All three jurisdictions labelled Very High are marked EDD: the Central African Republic at 0.578, Chad at 0.765 and the Democratic Republic of the Congo at 0.416, on a scale where 10 is the lowest risk. Meanwhile Venezuela scores 0.426 and the Russian Federation 1.917, and both are Prohibited; the 18 Prohibited countries carry “Prohibited” in the band column too, rather than a Very High rating. So the decision does not follow the score: the Democratic Republic of the Congo scores below Venezuela and is open with enhanced diligence, while Russia scores well above both and is closed. On the face of it that looks like a sanctions-and-policy layer applied over the scoring, but the document does not state its rationale, so treat that reading as our inference, not Conduit’s explanation.

Two cautions before anyone plans around this table. An EDD classification is a policy label, not a promise: it does not establish that a customer in that country will be accepted, that a banking partner will take them, or that a usable payment route exists. And the table is a country-policy classification, not a coverage list: it tells you who is excluded, not where money can actually be sent. Both need separate confirmation from Conduit.

Who cannot use it, by business type

Conduit also publishes a restricted-industries list. The categories include aggregation businesses and payment facilitation, bearer share companies, counterfeit or unauthorised goods, foreign exchange trading unless the client is itself licensed, get-rich-quick and multi-level marketing schemes, governmental missions, embassies and consulates, intellectual property infringement, internet gambling, marijuana-related businesses, and weapons and explosives.

Two are worth flagging because they catch legitimate businesses off guard. Payment facilitation and fund aggregation are excluded, which rules out a common model: collecting into one account on behalf of many third parties. And consumer use is prohibited outright: the MTA restricts the service to “legitimate commercial purposes”, with “family, household, and personal purposes” named as prohibited.

The Montana clause

One more provision deserves daylight, because it is unusual and a reader would not find it without opening the agreement. A US client must swear, affirm and attest that “Conduit did not solicit you to enter into this Agreement” and that “you did not see any advertisements or marketing materials from Conduit within, or directed towards, the U.S. or its territories that caused or influenced your decision to become a client”. The agreement calls that attestation “a material inducement”. Separately, it deems the agreement entered into, signed and performed within the boundaries of Billings, Montana for US clients, and within Calgary for Canadian ones.

We are not going to characterise the legal effect of that, and this is not legal advice. What we can say is what it asks of you: a US business signing this is attesting to something about its own conduct, in writing, as a condition of the deal. If your compliance team has a view on reverse-solicitation clauses, this is the paragraph to hand them.

Alternatives

Alfred and Triple-A are the closest comparisons for a cross-border business-payments buyer, since both sell collection and payout to businesses; Rain is included for its eligibility disclosure only, as card issuing is a different purchase. This compares what each company published in the pages we read between 23 and 25 September 2026, not what any of them can do. Of the four, Conduit is the only one that publishes a dated policy document covering every country, and the only one whose permissions we confirmed on a register. It is no better than the others at naming the institutions that hold client money: none of them does. For a provider that maps its contracting entities by customer residence instead, see our Bridge company profile.

Limitations and unknowns

• Which corridors, countries and currency pairs are actually supported: not publicly disclosed. The country policy says who may be onboarded, not where money can be sent; the MTA says supported currencies are displayed on the platform to signed-in clients.
• Which institutions hold client funds, and in which jurisdictions: not publicly disclosed; the MTA calls them Asset Providers and names none.
• Which of a client’s flows are Pre-Funded Conversions, and what share of volume sits outside Section M: not publicly disclosed.
• How the Bank of Canada holding-of-funds declaration sits alongside the Pre-Funded Conversion carve-out: not yet verified; we report both and have not put the question to Conduit.
• The FinCEN MSB registration of Conduit Technology, Inc.: not yet verified; the register was unusable on 25 September 2026, which is a limit on us, not a finding about the company.
• US state money transmitter licences: could not be verified; none is published.
• Pricing: not publicly disclosed; the MTA says money transmission fees and the foreign exchange rate are disclosed before each transaction.
• Named clients, volumes or production references: not publicly disclosed in the pages we read.
• The two registers record different websites for the same entity, FINTRAC conduit.fi and the Bank of Canada conduitpay.com: not yet verified which is current; neither register explains the difference.
• Which MTA version a given client signed: not yet verified. The published page is marked version 3.05, last updated 20 July 2026 (read 1 October 2026); updates take effect 15 days after notice, and modifications that materially affect the handling, safeguarding or loss allocation of client funds “may require affirmative acceptance”.

Key facts (as of 25 September 2026)

• Subject: Conduit, cross-border business payments settled over stablecoin rails
• Entities in the agreement: Conduit Technology, Inc. (Delaware; Billings, Montana address and Kalispell, Montana mailing address) and 12835304 Canada Inc. (Calgary)
• Canada, register-verified: FINTRAC MSB M23837123, Registered, 23 May 2023 to 27 August 2028; Bank of Canada PSP, Registered 7 April 2026, no violations
• Declared FINTRAC services: Foreign Exchange, Money Transferring, Virtual Currency, PSP
• Declared Bank of Canada payment functions: EFT initiation, EFT instruction authorisation or transmission, and holding funds on behalf of an end user
• Country policy: 243 countries: 174 Allowed, 51 EDD, 18 Prohibited (RISK-004b, 20 April 2026; list version 2.3)
• Client type: business only; consumer use prohibited by the MTA
• Safeguarding: Section M describes segregated accounts, and for-benefit-of accounts “when available”, at unnamed Asset Providers, and applies “when applicable”; its pre-settlement safeguarding and beneficial-ownership provisions are expressly disapplied to Pre-Funded Conversions
• Operating status: payouts, pay-ins, virtual accounts and wallets offered as live on its site (company-reported, read 1 October 2026); not a bank; banking services provided by third-party partners, none named
• Website: conduitpay.com