The AMF inspects and oversees individuals and entities registered with it in the following money-services classes:

  • Currency exchange
  • Funds transfer
  • The issue or redemption of traveller’s cheques, money orders or bank drafts
  • Cheque cashing
  • The operation of automated teller machines, including the leasing of a commercial space intended as a location for an automated teller machine if the lessor is responsible for keeping the machine supplied with cash 

Scope of inspection

The AMF may inspect a money-services business to verify whether it complies with the Money-Services Businesses Act. The inspection can focus on:

  • Display and compliance of the licence
  • Disclosures required by the Act
  • Keeping of records and registers
  • Verification of the identities of clients and co-contracting parties
  • Supervision
  • Computer security and the protection of personal information 

Inspection fee

 The fee payable for the preparation of an inspection, the inspection itself and the follow-up on the recommendations is determined by regulation. As of January 1, 2017, the fee was $92 per hour, per inspector. This fee is adjusted on January 1 every year based on the rate set out in the Regulation respecting fees and tariffs payable under the Money-Services Businesses Act.

The inspection fee applies after the fourth hour of work completed (the first four hours are at no cost), and is payable within 30 days of the date shown on the statement of fees. Once the response to the inspection report is received, the case is closed and the statement of fees owing is issued.

To avoid incurring additional inspection billing hours, here are a few steps you can take to help expedite the process:

  • Submit the requested documents on time
  • Make sure documents are available on the day of the inspection
  • Complete all questionnaires in full
  • Ensure that the respondent and any officers are present on the day of the inspection 

Main findings inspections

AMF inspections across all money-services classes have created a positive impact on the industry’s compliance culture.

For example, the areas that generated the most frequent findings by the AMF during its inspections are:

  • Incomplete or non-compliant transaction registers
  • Deficient disclosure of related persons
  • Non-compliant verification of customer identity
  • Failure to keep records on the identification of co-contracting parties
  • Non-compliant records on sources of liquidity
  • Use of a third-party bank account 

ATMs: Reminder of requirement to display AMF sticker