The Autorité des marchés financiers (AMF), the
body responsible for enforcing Québec's legislation
concerning the financial sector, recently adopted a Self-Reporting
and Cooperation Policy. The policy, adopted on May 20, 2025,
encourages individuals and corporations that have contravened a law
administered by the AMF to voluntarily self-disclose or fully
cooperate with the regulator in exchange for the possibility of
reduced sanctions or, in some cases, resolution of the matter
without proceedings.
This initiative is a welcome one. Although comparable regimes
exist in other provinces, the AMF had until now offered no clear
guidance on voluntary disclosure. It had, in some cases, declined
to initiate investigations or enforcement proceedings following
voluntary disclosures combined with corrective action; however,
experiences of parties have varied, and the lack of a framework
discouraged proactive conduct.
