Strengthening Money Services Oversight
The Minister of Finance of Québec amended the Regulation under the Money-Services Businesses Act, chapter E-12.000001, updating the required recordkeeping and authorized communication of information by certain government employees. Under the Act, the Minister has the authority to determine the nature, form, and content of the books, registers, and records that money-services businesses must maintain, as well as to designate who may communicate information for purposes related to the application of the Act. The recent amendment addresses several specific points. First, it requires that, when a money-services business cashes a cheque, it must retain a copy of both the front and back of the cheque, ensuring better documentation of financial transactions. This change improves the transparency and traceability of transactions and supports compliance with regulatory requirements. Additionally, the amendment clarifies the status of employees at the Agence du revenu du Québec, specifying which personnel are authorized to communicate information to police forces for purposes not connected to criminal or penal investigations, particularly in relation to the application of provisions of the Money-Services Businesses Act or the operations of the Agence du revenu du Québec.
The amendment also includes minor technical revisions in the regulation’s text, such as changes to wording in section 14, including the substitution of certain French terms and the replacement of the phrase “information that” with “information and documents that,” reinforcing the scope of documentation that must be maintained by money-services businesses. Section 14 was further updated to explicitly require copies of both sides of a cheque in relevant transactions, formalizing a practice that improves accountability in financial operations. Section 16.1 was amended to replace the term “director who” with “service head who,” reflecting updated terminology and organizational structure for regulatory purposes. These changes collectively modernize and clarify the regulatory language, ensuring that it accurately reflects current operational practices and aligns with administrative structures within governmental oversight bodies.
The regulatory amendment was preceded by a draft published on June 11, 2025, in Part 2 of the Gazette officielle du Québec, providing for a 45-day public consultation period. No comments were received during this consultation period, supporting the decision to proceed with the regulation without further modifications. The amendment will come into force on the fifteenth day following its publication in the Gazette, thereby providing money-services businesses and relevant agencies time to implement the necessary adjustments to comply with the new requirements. Overall, the regulation underscores Québec’s commitment to ensuring accurate recordkeeping, clear lines of authority in information sharing, and improved compliance measures within the financial services sector. It represents a focused effort to balance operational efficiency for money-services businesses with strong regulatory oversight to safeguard transparency and* accountability in financial transactions.
Quebec (MO 2025) October 1, 2025
Disclaimer: Insights are for informational purposes only and do not reflect RRI’s official position or constitute legal opinion.
