CASH PAYMENT POLICY
PHIL & JENNIE GAGLARDI ACADEMY
Policy Rationale
The purpose of this policy is to mitigate the risks associated with accepting cash as payment for tuition and other related fees, goods, and services aligning with anti-money laundering requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
The School is committed to detecting and preventing any money laundering activities and ensuring that it does not become involved in any criminal or terrorist property arrangements.
To fulfil this commitment, the School has established procedures for assessing the risk of financial crime, for internal reporting of suspicious activities and for making suspicious transaction reports to the relevant agencies if necessary.
Scope of this Policy
This policy applies to all Northgate Christian Education Society employees, dba Phil & Jennie Gaglardi Academy (the “School”).
The Policy
The School will apply appropriate cash handling and record-keeping practices. The School will ensure that the identities of parents, guardians or other persons making any substantial cash payments to the School are satisfactorily verified.
Procedures
The School will accept the following payment types for tuition payments, deposits, and fees:
The School will accept payment from the following financial institutions:
Receiving Cash Payments
The School will not accept cash payments over $5,000.00 in a single transaction1 for any purpose. Any cash payment received over $5,000.00 will require the employee to verify the payer's identity. All parents and guardians should be encouraged to pay tuition, deposits, and supplemental fees through an alternative payment method such as online banking, pre-authorized debit or credit card.
If employees are offered funds that they know or suspect are from criminal or terrorist finance, they are required to report their suspicions immediately to the School's Comptroller (Reporting Officer). If employees receive an unusual request to receive or transfer money, they must inform the School's Comptroller. If appropriate, the School Comptroller will contact the Financial Transactions and Reports Analysis Centre of Canada("FINTRAC"), police or other relevant agency.
Verification Steps
Before entering into any transaction with a person that involves the payment of cash above $5,000.00, the School needs to take reasonable steps to ascertain and verify the person's identity and the source of the money. Employees will collect the following information from the payee:
The School will seek independent verification of the payer's identity. For example, an employee will photocopy original or official documents confirming the payer's identity. The employee will date and initial each photocopied page. Suitable documentation to verify a payer's identity would include passports, driver's license, birth certificate, health insurance card or other similar records. Employees should visually verify the payer's identity against their original documentation. When checking such documents, employees must ensure that the documents are current and be alert to any signs of forgery or theft.
The payer will provide independent confirmation of the full name and address of all financial institutions or other entities through which the payer processed the cash, such as a withdrawal receipt from their financial institution. Employees will record the date the School received the money from the payer.
Refund procedures
All refunds must follow the School's refund policy.
Cash payments are refunded by cheque only. Other refunds are paid using the original form of the transaction unless otherwise approved by the School Director. Employees who receive a request from a payer for a cash refund following a payment made by credit card, wire transfer, or cheque will report the incident immediately to the Reporting Officer.
Suspicious Transactions
Employees will evaluate the source of funds paid to the School and be alert to unusual patterns of behaviour or activities that may indicate the possibility of money laundering or other terrorist financial crimes. It is impossible to produce an exhaustive list of all the matters related to a suspicion of money laundering or other terrorist financial crime. Therefore, employees should use their judgment when looking at any business relationship or transaction. Employees will assess the facts, context and money laundering/terrorist financing indicators to determine whether there are reasonable grounds to suspect that the payment is related to the commission or attempted commission of a money laundering/terrorist financing offence.
The following are some possible money laundering/terrorist financing indicators:
Reporting
Employees of the School will make a report to the Reporting Officer, as soon as reasonably possible, when they have knowledge or suspicion of criminal activity, or when there are reasonable grounds to suspect that a person is engaged in money laundering or that terrorist property exists. The employee will complete a "Suspicious Transaction Report" and provide the Reporting Officer with the documentation.
The employee’s report should include as much detail as possible, including:
Once an employee has reported suspicious cash payments and given appropriate documentation to the Reporting Officer, they will not take any further action unless directed or the individual continues in their suspicious behaviour. The Report Officer will initiate a report to FINTRAC if warranted. Once the Reporting Officer has confirmed that no notice to FINTRAC is justified, the individual will be released from suspicion.
The Reporting Officer will consider all Suspicious Transaction Reports and file an external report to the FINTRAC (who will undertake any necessary investigation) if warranted. Whether or not an actual "transaction" is completed, the Reporting Officer must file a report to FINTRAC if there is cause for suspicion of money laundering for criminal or terrorist activity. All FINTRAC Reports will comply with FINTRAC reporting requirements.
Record Keeping Practices
All Suspicious Transaction Reports will be documented, either on paper or electronically. All inquiries made within the School concerning any Suspicious Transaction Report should also be recorded. The School will keep the Suspicious Transaction Reports details, including the Reporting Officer's information concerning a Suspicious Transaction Report, even if there is no external FINTRAC report filed. The School will also keep a copy of any FINTRAC Reports and associated evidence and documentation.
The School will retain copies of all information collected by an employee regarding identifying and verifying individuals who pay in cash over $5,000.00, together with details of all transactions, including relevant dates.
The School will keep all information, evidence and reports concerning Suspicious Transaction Reports, FINTRAC Reports, and identification and verification of individuals for a minimum of five years.
Cash Handling
The School will establish responsibility and describe the minimum requirements for cash handling.
The following procedures will be followed by employees when handling cash:
Separate individuals will perform the collection of cash, deposit preparation, and reconciliation duties to the extent possible to ensure the safeguarding of money. At a minimum, deposit preparation and reconciliations are to be completed by separate individuals. All cash deposits exceeding $5,000 will be reviewed and initialled by the School Director.
Review
This policy will be reviewed and updated as needed, but at least annually.
Cash Payment Policy, adopted and approved effective February 24, 2021