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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, 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 BC Waldorf Schools. Policy Statement BC Waldorf Schools are committed to detecting and preventing money laundering activities and ensuring that they do not become involved in arrangements involving criminal or terrorist property. In order to fulfil this commitment, BC Waldorf Schools have 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. BC Waldorf Schools will ensure that adequate cash handling and record keeping practices are followed. Where risk factors are identified, schools will ensure that the identities of parents, guardians or other persons making any substantial cash payment to a specific school are satisfactorily verified. Definitions Reporting Officer: Each BC Waldorf School shall list an employee as the Reporting Officer for that school. This person will report any suspicious activities to relevant agencies. Procedures BC Waldorf Schools will accept the following payment types for tuition payments, deposits, and fees:
BC Waldorf Schools will accept payment from the following financial institutions:
Receiving Cash Payments BC Waldorf Schools will not accept cash payments exceeding $10,000.00 in a single transaction for any purpose. Additionally, any cash payment in excess of $5,000.00 will require the specific school to verify the identity of the individual making the payment and the source of the payment. All parents and guardians of BC Waldorf Schools will be encouraged to pay tuition, deposits, and supplemental fees through an alternative payment method such as pre-authorized debit, cheques etc. If any employee of a BC Waldorf School 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 Reporting Officer/Principal who will, if appropriate, 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 which involves the payment of cash in excess of $5,000.00, a BC Waldorf School will 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:
The specific school 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 the specific school 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 will 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. The specific school 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 the school from the payer and the date the verification was completed. RefundsRefunds will be issued only in accordance with a specific school’s refund policy. Cash payments will be refunded by cheque made payable to the parent or guardian of the student. All other refunds will be made to the original form of payment unless otherwise approved by specific school personnel. All requests for a refund in cash following a payment by credit card, wire transfer, cheque, etc., will be reported to the Reporting Officer. Suspicious Transactions Employees of BC Waldorf Schools will evaluate the source of funds that are paid to the specific 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 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:
ReportingEmployees of BC Waldorf Schools will make a report to the Reporting Officer of their school, 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. The report should include as much detail as possible including:
Once an employee has reported suspicions to the Reporting Officer, the employee will follow any instructions provided. The employee will not make any further enquiries unless instructed to do so by the Reporting Officer. Any further transactions or activity in respect to 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 they consider 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. All FINTRAC Reports will comply with FINTRAC reporting requirements. Record Keeping At BC Waldorf Schools all Suspicious Transaction Reports will be documented, either on paper or electronically. All enquiries that are made within a specific school in relation to any Suspicious Transaction Report should also be recorded. The specific school 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. The specific school will also keep a copy of any FINTRAC Reports and associated evidence and documentation. BC Waldorf Schools will retain copies of the information any employees obtained regarding the identification and verification of individuals from whom they 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 specific school for a minimum of five years. Cash Handling The following procedures will be followed by employees of BC Waldorf Schools when handling cash:
Authority Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) Independent School Act Resources Anti Money Laundering BC Waldorf Collective - AWNSA Registered Initiative, Associate, and Full Member Waldorf Schools of BC
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