About MDD

MDD sits at the intersection of fintech and banking.

Fintechs are increasingly working with banks, and banks are increasingly responsible for the third-party risk that flows from the fintechs using their rails to move end-user funds. We exist to make that relationship work, by orchestrating safeguarding, custody, payments and accounting so that both sides can operate with confidence.

The introduction of the RPAA.

The Retail Payment Activities Act (RPAA) is Canada’s framework for supervising payment service providers. It is administered by the Bank of Canada, and its funds-safeguarding requirements took effect in September 2025. Under the RPAA, a business that performs a payment function, including holding funds on behalf of an end user, must register and must safeguard those end-user funds.

September 2025: The funds-safeguarding requirements took effect
Bank of Canada: Administers the Act
Registration: Required of businesses that perform a payment function

Safeguarding

The Act recognises two ways to safeguard funds.

In trust

Funds held in trust in a segregated trust account.

Insured or guaranteed

Funds held in a segregated account backed by insurance or a guarantee.

In practice, this means an MSB has to prove, continuously, that its end-user funds are segregated, protected and reconcilable, and it has to hold those funds with an eligible institution such as a bank, credit union or trust company. Getting this wrong is expensive; the RPAA’s most serious penalties run into the millions.

What it means for you

The RPAA turns safeguarding and end-user fund accounting from good practice into a legal obligation, and turns your bank into a party that must manage the risk you create. MDD is built to satisfy both requirements at once.

What “holding funds” means.

You are holding funds when money belonging to your end users sits with you, even briefly, until it is withdrawn by the end user or transferred on to someone else.

01The float in a wallet
02The balance waiting to settle on an embedded-finance platform
03The funds moving through a marketplace

All of it is end-user money you are responsible for while it is in your hands.

Because the financial system is becoming more digital, the number of businesses that hold funds is growing quickly. Holding funds is one of the payment functions the RPAA regulates, which is why so many technology companies that never thought of themselves as financial now find themselves inside the safeguarding regime. If you hold funds, you need to safeguard them, and MDD is how you do that without building a bank.

Why safeguarding trusts are better for Canadian MSBs than insurance.

The RPAA lets you safeguard funds through a trust or through insurance and guarantees. On paper they look like alternatives. In practice, for a Canadian MSB, the safeguarding trust is the stronger choice, and the choice that best protects your banking.

Safeguarding trust

Funds sit with a trustee, legally separate from your business
Comes with a bare trust and access to banking
A structure: funds protected and reachable in the first place

Insurance and guarantees

Funds, and the risk, stay closer to you
A policy: pays out after something goes wrong

01
It reduces the probability of debanking.
A safeguarding trust legally separates end-user funds from your business and places them under a trustee. That gives your bank the comfort it needs to keep you, where an insurance-backed arrangement still leaves the funds, and the risk, closer to you.
02
It comes with banking.
The safeguarding trust company can also provide a bare trust and access to banking, so safeguarding and banking are solved together rather than separately.
03
It is a structure, not just a policy.
Insurance pays out after something goes wrong. A trust is designed so that end-user funds are protected and reachable in the first place, which is exactly what regulators and banks want to see.

This is why MDD’s platform is built around a Canadian safeguarding trust company rather than a safeguarding insurance product.

The people you will actually deal with.

MDD is small on purpose. The same four people who set up your structure are the ones who answer when something needs deciding, and between them they cover tax law, compliance, corporate governance and the engineering discipline it takes to run a platform.

01Barbados

Dr. Jonathan Brathwaite

PhD, TEP

Founder and In-House Counsel

Jonathan is an international tax lawyer who has worked independently for over fifteen years across the United Kingdom and Barbados, with clients connected to Barbados, Canada, Mexico, Brazil, the United States and Switzerland. He specialises in compliant, commercially workable cross-border tax structures for owner-managed international businesses, investment funds and private clients, drawing on a wide range of corporate, trust and business solutions, and has led service teams to deliver on the advice given.

He holds a Master of Laws (LLM) in International Tax Law from the University of Florida's Fredric G. Levin College of Law and is completing a Doctor of Juridical Science (SJD) in International Taxation at the same institution. He also holds an LLB from the University of Wolverhampton, an MSc in Mathematical Finance from Imperial College London, and a BSc in Business and Computing from Brunel University. Jonathan is an Attorney at Law in Barbados, was called to the Bar in England and Wales, and is a member of the Barbados branch of the International Fiscal Association (IFA).

02Barbados

Marilyn Brathwaite

Co-founder

Marilyn spent seventeen years at a multinational corporation across the UK, Ireland and EMEA, managing a P&L in excess of USD 500M with responsibility for contract management, SOX corporate governance and financial disclosure.

For the past six years she has worked with owner-managers on international business and wealth structures, trusts and operating companies. That combination, large-company financial governance alongside close work with owner-managers, is what shapes the group's standard for how a structure should be run once it is in place.

03Canada

Alanna Brathwaite

Private Client Advisor

Alanna leads business development in Canada, advising small to medium-sized businesses on international tax consultancy and cross-border structuring. She has a particular focus on trust companies and fintech structuring, helping money services businesses and payment platforms build compliant, bankable structures that protect end-user funds and support sustainable growth across the Americas.

Alongside her advisory work, Alanna brings a distinctive engineering discipline to client engagements. Trained as a chemical engineer, she spent several years in consulting and project management, delivering complex, high-capital projects in Canada. That experience shapes her structured, execution-focused approach to structuring mandates, where precision and follow-through matter as much as the plan itself.

Alanna holds a bachelor's degree in Chemical Engineering and is based in Canada, where she is the principal point of contact for Canadian clients.

04Barbados

Rianna Holas

Private Client Advisor

Rianna leads private-client engagements, drawing on over eight years' experience in international corporate services, trust and estate administration, and regulatory compliance. She leads AML and CFT compliance for the firm, work that sits close to the compliance obligations an MSB carries under the RPAA.

She also advises on company formation, corporate governance and company administration, and serves as a director on a number of client companies, overseeing statutory compliance, board governance and regulatory affairs. Alongside that, she guides individuals and families relocating to Barbados through property, immigration and settling-in support.

Rianna holds a bachelor's degree in Hospitality and Tourism Management and is a member of the Society of Trust and Estate Practitioners (STEP) and the Barbados Association of Compliance Professionals.

Two sister firms, one group.

Massive Distribution Dynamics, Mithril International and Mithril Tax Law share common ownership. Between them they cover the structure, the legal opinion behind it and the safeguarding platform that runs it.

Cross-border structuring and international tax consultancy for owner-managed businesses, built on the Canada to Barbados and United States to Barbados double tax treaties.

Where an MSB needs the structure itself designed, a Barbados subsidiary to carry low-tax profit and cheaper accounting, Mithril International does that work.