Ask Amber: Grace Period for MSB Licenses from Quebec’s AMF?

Hey Compliance Nerd!
I want to start serving clients in Quebec. I’ve already got a respondent, since I don’t have offices in Quebec…  but my respondent is telling me that it could take as long as six (6) months to get a license under Quebec’s MSB Act?!? What’s up with the time that this takes?  Is there a “grace period” or something that would let me start serving clients ASAP once I’ve submitted the paperwork?
Sleepless in Quebec

Hey Sleepless,
I have good news and bad news. Let’s start with the bad news.
As far as we know, the Authorite des Marches Financiers (AMF) has stated (in this press release for instance) that no grace periods are being offered under Quebec’s MSB Act. In fact, in 2015 the AMF collaborated with additional enforcement agencies, including the Surete du Quebec, to conduct a number of searches related to un licensed MSBs… I interpret this as being a strong signal.
On the bright side, you can serve the remaining 77% of Canada’s population before your AMF licensing has been completed. This is why you see some financial services companies (including banks) that ask for province of residence at the first page. Vive la difference, indeed.

Amber D. Scott, MBA, CIPP, CBP, CAMS
Founder & Chief AML Ninja, Outlier Solutions Inc.
Amber is a long time, self-described “compliance nerd”. Amber is a firm believer in the idea that good compliance can enable good business. Find out how at or reach out to her directly at [email protected].

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