Last update : April 23, 2020
This FAQ answers the questions most frequently received from money-services businesses (MSB) about the COVID-19 pandemic. This FAQ will be updated on an ongoing basis to reflect new developments.
Can MSBs continue to carry on activities during the COVID-19 pandemic?
The Government of Québec has ordered that all non-essential services and activities be reduced to a minimum until May 4, 2020.
The list of essential services and activities This link will open in a new window includes financial services (financial institutions, ATMs and other payment methods).
Depending on their nature, an MSB’s activities may or may not be considered essential.
For example, maintaining an ATM located inside a business that is not operating because of COVID-19 is not essential.
You can check if your business’s activity is essential by completing the on-line form on the Government of Québec website.
MSBs that are permitted to continue operating must comply with public health directives and keep on-site staff to a minimum.
Will the invoices of MSBs that temporarily suspend their activities during the COVID-19 pandemic be adjusted?
No, the annual fees must be paid in full.
In March, each AMF-registered MSB received an invoice for the annual fees that it must pay to maintain its licence.
Businesses that are unable to pay their annual fees at this time may make a payment deferral arrangement by contacting the AMF Information Centre.
Note that these fees are non-refundable.
Will an MSB that decides to temporarily suspend its activities and withdraw its licence during the COVID-19 pandemic benefit from a streamlined licence application process when it resumes its activities?
No. Before resuming activities, the MSB must complete the entire licence application process, including disclosing its business relationships and paying the required fees. The Sûreté du Québec will have to issue another security clearance report to the AMF for each person who is subject to this requirement under the Money-Services Businesses Act (MSBA) This link will open in a new window.
Can MSBs carry on their activities off-site?
Yes, provided that they comply with all their obligations under the MSBA and its regulations and other laws applicable in Québec, such as the Act respecting the protection of personal information in the private sector. This link will open in a new window When an MSB carries out an off-site transaction, via Internet or over the phone, for example, it must identify the customer and verify the customer’s identity, where applicable, in the manner stipulated by the Regulation under the Money-Services Businesses Act This link will open in a new window.
In the current environment, MSBs and their customers are more likely than usual to fall victim to phishing and other such activities. Heightened vigilance should be exercised in the face of cyber threats.
Is the AMF currently processing licence applications and information updates submitted by MSBs?
Yes. AMF E-Services is fully operational and still the best way to submit any applications related to registrants’ activities and the forms required to process them. Additional delays may occur in processing documents received by mail.
For registrants without access to E-Services, the AMF will, exceptionally, accept copies of signed documents that are sent by e-mail. The original documents must still be mailed to the AMF.
Will MSB inspections continue?
Yes, inspection activities are being maintained off-site. The AMF will show flexibility and tailor its interventions to the current context.
Extensions may be granted as needed for the submission of documents or comments.
You can contact the inspector assigned to your file if you require any information.
The AMF website, especially the Money-Services Businesses section, contains a wealth of information to help guide you in your practice.
The AMF also reminds you that there are guides available to assist you in your practice:
- Money -Services Businesses User Guide (pdf - 1 MB)This link will open in a new windowUpdated on 1st January 2020
- Protecting vulnerable clients – A practical guide for the financial services industry (pdf - 688 KB)This link will open in a new windowUpdated on 3 June 2019A PRACTICAL GUIDE FOR THE FINANCIAL SERVICES INDUSTRY, PROTECTING VULNERABLE CLIENTS