What if the biggest threat to your money service business isn’t another fintech — but a chat app?
From WhatsApp to Telegram and Signal, messaging platforms are quietly transforming into payment gateways. With built-in trust, global reach, and seamless interfaces, they could redefine how money moves across borders.
At Walker Guidance, we help Canadian and U.S.-based startup MSBs navigate compliance, licensing, and growth strategy. Here’s what you need to know to stay competitive — and compliant — in this new landscape.
💬 Messaging Apps Are Now Payment Channels
Messaging apps are rapidly integrating financial features:
- WhatsApp Pay (Meta): Available in India and Brazil. Peer-to-peer and merchant payments using local systems like UPI and PIX.
- Telegram: Offers a crypto wallet and in-chat payments through its integration with the TON blockchain.
- Signal: Testing end-to-end encrypted payments using privacy coin MobileCoin.
- Apple Messages: Supports Apple Cash for instant iOS-based transfers.
These platforms can move fast because they don’t usually handle fiat directly. Instead, they integrate crypto or embedded wallets — and avoid regulatory complexity by design.
⚖️ But Compliance Still Matters — Especially for Startups
If you’re launching an MSB, your obligations are very different from a messaging app. You may be required to:
- Register as a Money Services Business (MSB) with FINTRAC (Canada) or FinCEN (U.S.)
- Obtain state money transmission licenses in the U.S.
- Implement and maintain a full AML/CTF program
- Report suspicious transactions, conduct KYC, and keep audit trails
Messaging apps often offload compliance responsibilities to partners. As a startup, you can’t rely on that flexibility unless your model is carefully structured.
📥 On-Ramps, Off-Ramps, and the Role of Exchanges
Messaging platforms stay agile by avoiding fiat handling. Instead, they rely on exchanges and wallet providers to serve as:
- On-ramps – where users convert fiat into crypto (e.g., USD to USDC)
- Off-ramps – where users cash out crypto back to fiat (e.g., BTC to CAD)
These conversion points are where regulatory obligations apply: identity checks, transaction monitoring, and licensing.
Example: A Telegram user sends USDT to a friend. The app never touches fiat — but the exchange that converts USD into USDT does the heavy compliance lifting.
🧩 For Startup MSBs, This Matters
If you control user funds or enable fiat–crypto conversion, you’re likely acting as an on- or off-ramp — and must register, license, and comply.
If not, you may still face legal exposure depending on:
- How you custody assets
- Whether you handle user on-boarding
- Who controls the transaction flow
🧠 Competing With Convenience: Your Strategic Edge
Messaging apps prioritize convenience. You can compete by offering transparency, compliance, and tailored services:
✅ Lean Into Compliance as a Strength
- Build trust with banks, partners, and regulators
- Serve regulated use cases that chat apps can’t touch (e.g. business transfers, licensed remittances)
🧩 Focus on Specific Niches
- Under-served payment corridors
- Cross-border freelancer payouts
- Community lending or local agent networks
🔐 Use Embedded Compliance Partnerships
- Integrate with regulated crypto exchanges or Banking as a Service (BaaS) providers
- Outsource custody while owning the user experience and reporting
🛠 How Walker Guidance Helps MSBs Compete
We work with early-stage fintech and MSB founders to:
- Structure Canadian and U.S.-compliant business models
- Register with FINTRAC, FinCEN, and state regulators
- Draft custom AML/CTF programs
- Navigate crypto custody, stable coin integrations, and embedded finance
- Align growth plans with regulatory frameworks
Whether you’re just validating your idea or launching across borders, we help you build a compliant, scalable MSB from day one.
Walker Guidance 