Cash Payment Policy

Purpose of Policy

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, and to align with anti-money laundering requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

Scope

This Policy applies to all employees of Kelowna Christian Center Society (KCCS).

KCCS is committed to detecting and preventing any money laundering activities and to ensuring that it does not become involved in any arrangements involving criminal or terrorist property. 

In order to fulfil this commitment, KCCS 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.

Where risk factors are identified, KCCS will ensure that the identities of donors, parents, guardians or other persons making any substantial cash payment to KCCS are satisfactorily verified.  KCCS will also ensure adequate cash handling and record keeping practices are followed.

Procedures

KCCS will accept the following payment types for tuition payments, deposits, fees and donations:

KCCS will accept payment from the following financial institutions:

Receiving Cash Payments

KCCS will not accept cash payments in excess of $5,000.00 in any single transaction[1] and any cash payment in excess of $5,000.00 will require KCCS to verify the identity of the individual making the payment and the source of the payment. All parents and guardians should be encouraged to pay tuition, deposits, and supplemental fees through an alternative payment method such as Electronic Funds Transfer (EFT), cheque or credit card.

If any employee is offered funds that he or she knows or suspects are criminal property or may represent terrorist finance, or if he or she receives any unusual request to receive or transfer money, it will be reported immediately, in accordance with the Reporting section of this Policy, to the KCCS Finance Manager (the “Reporting Officer”) who will, if appropriate, contact the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”), police or other relevant agency.

Verification Process

Before entering into any transaction with a person which involves the payment of cash in excess of $5,000.00, KCCS needs to take reasonable steps to ascertain and verify the identity of that person and the source of the cash.

In the case of individuals, the following information will be collected:

KCCS will also seek independent verification of identity, for example by requiring production of originals of official documents confirming identity.  Suitable documents will include passports, driver’s license, birth certificate, health insurance card or other similar record.  An employee of KCCS will verify the individual’s identity in the individual’s physical presence, while viewing the original identification. When checking such documents, employees will ensure that the documents are current and be alert to any signs that they might have been forged or stolen. A copy of the identification will be taken, and the date of verification recorded.

KCCS will also seek to verify the source of the cash. 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 financial institutions. An employee will record the date on which the money was received by KCCS from the payer and the date the verification was completed.

Refund Procedures

Refunds will be issued only in accordance with the applicable KCCS departmental refund policies. Precautions will be taken in respect of refunds requested in cash following a payment by credit card, wire transfer, cheque, etc. Cash payments will be refunded by cheque made payable to applicable payor.  All other refunds will be made to the original form of payment unless otherwise approved by the KCCS Finance Manager.

Suspicious Transactions

Employees will evaluate the source of funds that are paid to KCCS 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 not possible to produce an exhaustive list of the matters that might give rise to a suspicion of money laundering or other terrorist financial crime. It is therefore important that employees use their own judgment when looking at any business relationship or transaction. Facts, context and money laundering/terrorist financing indicators need to be assessed to determine whether there are reasonable grounds to suspect that the transaction 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 KCCS will provide a Suspicious Transaction Report to the Reporting Officer, as soon as reasonably possible, where they have knowledge or suspicion, or where there are reasonable grounds for having knowledge or suspicion, that another person is engaged in money laundering, or that terrorist property exists.

Your report should include as much detail as possible including:

Once you have reported your suspicions to the Reporting Officer, you will follow any instructions provided. You will not make any further enquiries unless instructed to do so by the Reporting Officer. Any further transactions or activity in respect of the person in question, whether or not it is related to the matter that gave rise to the original suspicion, should be reported to the Reporting Officer as they happen, unless and until the Reporting Officer has confirmed that no report to the FINTRAC is to be made.

The Reporting Officer will consider all Suspicious Transaction Reports and will make an external report to the FINTRAC (who will undertake any necessary investigation) as soon as is practicable if he/she considers that there is knowledge, suspicion or reasonable grounds for knowledge or suspicion, that another person is engaged in money laundering, or that terrorist property exists, even if no transaction takes place (“FINTRAC Report”). 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 enquiries that are made within KCCS in relation to any Suspicious Transaction Report should also be recorded. KCCS will keep details of actions taken in respect of Suspicious Transaction Reports, including details of information considered by the Reporting Officer in respect of a Suspicious Transaction Report where no external FINTRAC report is made.   KCCS will also keep a copy of any FINTRAC Reports and associated evidence and documentation.

KCCS will retain copies of the information the employee obtained regarding the identification and verification of individuals from whom it received cash payments in excess of $5,000.00, together with details of all transactions including relevant dates.

All information, evidence and reports with respect to Suspicious Transaction Reports, FINTRAC Reports, and identification and verification of individuals will be kept by the School for a minimum of five years.

Cash Handling

KCCS will establish responsibility and describe the minimum requirements for cash handling.  

The following procedures will be followed by employees when handling cash:

[1] For the purposes of this Policy, a single transaction includes multiple payments within a 24-hour period.


Revision #1
Created 27 October 2020 21:43:06 by Natalia Baelde
Updated 19 November 2020 17:34:26 by Natalia Baelde