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:

  • cheque
  • pre-authorized debit
  • credit card
  • wire transfer
  • money order or bank draft
  • online banking payment
  • cash (up to a maximum amount of $5,000.00).

The School will accept payment from the following financial institutions:

  • The Bank of Montreal (BMO)
  • Canadian Imperial Bank of Commerce (CIBC)
  • The Bank of Nova Scotia (Scotiabank)
  • Royal Bank of Canada (RBC)
  • TD Canada Trust (TD)
  • All cooperative credit societies, savings and credit unions incorporated under the British Columbia Credit Union Incorporation Act.
  • All banks incorporated, formed, or authorized under the Bank Act of Canada.

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:

  • Full legal name
  • Residential address
  • Date of birth
  • Nature of principal business or occupation
  • Contact information
  • Relationship to the student
  • Amount and currency of funds received.

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.

1 For the purposes of this policy, a single transaction includes multiple payments within 24 hours.

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:

  • Transactions: The parent, guardian, or payer uses multiple transactions to avoid the reporting threshold of $5,000. Doing so indicates a desire to avoid reporting or exhibits the knowledge of reportable cash thresholds.
  • Structures: Payments involving complex or illogical arrangements make it unclear who is making the payment or appear to be structured to avoid identification of reporting thresholds.
  • Third parties: Payment of school fees or involvement by companies, trusts, off-shore entities or other third parties with no apparent relationship to the student. The parent, guardian or payer appears to be collaborating with others to avoid client identification or reporting thresholds.
  • Assets: There are reasons to doubt a person's ability to have a legitimate source for the funds.
  • Identity: The parent, guardian or payer has taken steps to hide their identity. The parent, guardian or payer uses a post office box or general delivery address where other options are available. There are doubts about the honesty, integrity, identity or location of the parent, guardian or payer.
  • Behaviour: The parent, guardian, or payer seems unusually anxious to complete a transaction, cannot justify why they need to make a payment quickly, requests a cancellation, reversal or refunds of earlier transaction or makes over-payment for no good reason.
  • Information or documentation is withheld by the parent, guardian or their representative or appears falsified. Cash payments are made using old, smelly or filthy bills.

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:

  • Full available details of the people and organizations involved, including themselves and other staff members, if relevant.
  • Full details of the transaction and the nature of each person's involvement in the transaction.
  • Suspected type of money laundering activity or use of proceeds of crime with reasons for suspicion.
  • The dates of any transactions, where they were undertaken, how they were launched, and the possible amount of money or assets involved.
  • Information on any investigation undertaken to date. Include suspicions that have been discussed with other employees and individuals. Include the contact information for all individuals outside the organization and list those individuals.
  • Whether any aspect of the transaction(s) is outstanding and requires action to progress.
  • Any other information that may help the Reporting Officer judge the case for knowledge or suspicion of money laundering and facilitate any external report.

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:

  • Cash is stored in a locked and secure location until the money is deposited.
  • Cash is deposited on a weekly.

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.

  • Cash receipts will be reviewed and reconciled to ledger accounts on a timely basis to ensure they have been correctly recorded. Accounting adjustments to ledgers will also be made each calendar month and on a timely basis.
  • Cash shortages or other discrepancies that exceed $100 must be reported immediately to 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