STEFA PAY← Back to site

Stefa Pay Inc. - Customer Complaints Policy

Version 1.1 · Effective date: 6 October 2026 · Last updated: 6 October 2026

I. About this Policy

Stefa Pay Inc. ("Stefa") is a Canadian money services business operating cross-border B2B payments, multi-currency accounts, foreign exchange and electronic funds transfer services. Stefa is incorporated in the Province of Ontario (Ontario Corporation Number 1001533856) and registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business under number N300001170.

The multi-currency account and IBAN services referenced in this Policy are provided through regulated banking and payment partners. Stefa takes customer concerns seriously. This Policy explains how clients can raise concerns about Stefa's services, how those concerns will be handled, and what avenues for further recourse exist if a client remains dissatisfied with Stefa's response. The Policy is published on Stefa's website and provided to every client upon onboarding.

Stefa Pay is not a bank. Registration with FINTRAC and the Bank of Canada does not constitute endorsement, guarantee or prudential supervision of our services, and client balances are not insured by CDIC.

II. What this Policy covers

This Policy applies to any expression of dissatisfaction by a client about Stefa, its services, its personnel, its compliance posture, or any aspect of the client's interaction with Stefa. Clients may raise concerns relating to (without limitation): a delayed or refused transaction, an unexpected fee or exchange rate, a customer service interaction, an account suspension or closure, the handling of personal information, the handling of identity verification or due diligence, or any other matter the client considers warrants a formal response.

For the purposes of this Policy, a distinction is drawn between a service inquiry and a complaint:

This Policy does not replace any rights clients hold under Canadian law or under any contract with Stefa. Clients retain the right to seek legal advice and to pursue any remedies available to them outside of this Policy.

III. Submitting a concern

In the first instance, Stefa encourages clients to raise concerns with their assigned account representative. Many matters can be resolved quickly and informally at this level.

Complaints may be submitted by a client, former client, prospective client, authorised representative, director, officer, beneficial owner or other person directly affected by Stefa's services, provided Stefa can verify the person's identity and authority where required.

Where the matter cannot be resolved informally, where it involves the assigned account representative directly, or where the client prefers to escalate formally, the client should submit a written complaint to:

To allow Stefa to investigate effectively, clients are encouraged to include: the client's full name and account identifier; the date and circumstances of the matter; relevant transaction reference numbers; a clear description of the concern and the desired outcome; and copies of any supporting documentation.

A complaint is treated as formally received on the date Stefa receives a written submission addressed to the channels above. Before investigating or disclosing account-specific information, Stefa may require the complainant to verify their identity, account relationship and authority to act on behalf of the relevant client.

IV. How Stefa handles complaints

Complaints are escalated promptly to the Compliance Officer and, where appropriate, senior management, where they involve material financial impact, suspected fraud, unauthorised activity, sanctions exposure, AML concerns, privacy breach, legal or regulatory breach, or reputation risk.

Every formal complaint is logged in Stefa's complaint register, assigned a unique reference number and routed to a designated handler. The handler is selected based on the subject matter and is, where appropriate, independent of the personnel or function whose conduct is the subject of the complaint. The handler may investigate, engage internal subject-matter experts, request information from banking partners where relevant, and propose a resolution. Where the matter involves a regulatory, sanctions or compliance dimension, the Compliance Officer is engaged.

The handling of complaints follows a structured process:

  1. Acknowledgement. Stefa confirms receipt within five (5) business days, identifying the assigned handler, the reference number and expected next steps.
  2. Investigation. Stefa conducts a substantive investigation drawing on internal records, transaction logs, communications history, banking-partner records where relevant, and documentation provided by the client.
  3. Substantive response. Stefa provides a written response setting out the findings, the resolution proposed (if any) and the reasoning supporting Stefa's position.
  4. Opportunity for dialogue. Where the client wishes to provide additional information, Stefa will consider it and respond.
  5. Final response. Stefa issues a written final response representing the conclusion of its internal complaints process and explaining the avenues for external recourse in Section VII.

Possible outcomes may include an explanation, correction of records, completion or reversal of an operational step where available, a fee adjustment, a process improvement, staff coaching, escalation to a third-party service provider, or other appropriate corrective action. Nothing in this Policy obligates Stefa to provide compensation except where required by law, contract or Stefa's final complaint determination.

V. Timing

Stefa aims to issue a final response within fifteen (15) business days of receiving a formal complaint. Where the matter is complex, requires input from third parties (such as banking partners or external advisors) or involves a parallel compliance investigation, more time may be required; Stefa will inform the client of the delay, explain the reason and provide an updated expected response date. In all circumstances, Stefa will issue a final response no later than thirty-five (35) business days after the date the complaint was formally received.

VI. Constraints on Stefa's response

Where a complaint relates to a delayed, refused, frozen, blocked, returned, cancelled or restricted transaction, or to an account suspension or closure, Stefa may be unable to provide complete reasons where doing so would conflict with AML/ATF, sanctions, fraud-prevention, banking-partner, law-enforcement, regulatory or legal obligations.

In particular, the "no-tipping-off" prohibition under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) prohibits Stefa from disclosing whether a Suspicious Transaction Report or related regulatory filing has been made or is contemplated. Sanctions law may impose comparable constraints. Where Stefa's response is so constrained, Stefa will inform the client to the extent permitted by law. The client's avenues for external recourse in Section VII remain available regardless of these constraints.

VII. External recourse

As a payment service provider registered with the Bank of Canada under the Retail Payment Activities Act (RPAA), Stefa is required to register, manage operational risks and respond to incidents in accordance with that framework.

If a client is not satisfied with Stefa's final response, the available avenues depend on the nature of the matter. Canada does not operate a single statutory ombudsman service for money services businesses; clients are directed to the most appropriate channel:

VIII. Record keeping

Stefa maintains a complaint register recording each complaint received, the date of receipt, the identity of the complainant, the subject matter, the handler assigned, the steps taken, the resolution proposed, the final outcome and the date of closure, together with supporting correspondence. The register also records, for each complaint: category, severity/risk rating, root cause, financial impact, closure evidence and a repeat/systemic-issue indicator.

Complaint records are retained for a minimum of five (5) years from the date of resolution, consistent with Stefa's record-retention obligations under the PCMLTFA. Records may be reviewed by FINTRAC, Stefa's Compliance Officer, the Board, Stefa's banking partners (within the limits of confidentiality) and any independent reviewer engaged in Stefa's biennial effectiveness review.

IX. Learning from complaints

Standard complaint categories: transaction delay/non-execution; transaction refusal/cancellation; fees/FX rate/pricing; account restriction/suspension/closure; customer service; onboarding/KYC/due diligence; privacy/personal information; fraud/unauthorised activity; sanctions/AML/compliance restriction; technical/platform issues; third-party banking-partner issue; contractual/commercial dispute; other.

Customer complaints are a meaningful source of intelligence about how well Stefa's products and processes work in practice. The Compliance Officer reviews complaint trends regularly and reports findings to the Board. Where complaints reveal systemic issues, those issues are referred for corrective action and tracked to resolution. Where a complaint reveals an actual or potential compliance breach, the matter is escalated immediately to the Compliance Officer, independent of and in parallel to the resolution of the underlying complaint.

X. Changes to this Policy

Stefa may amend this Policy from time to time to reflect changes in regulatory expectations, business practice or operational arrangements. The current version is always available on Stefa's website. Material changes will be communicated through Stefa's website or by email.

XI. Contact