Anti-Money Laundering / Cash Payment

Date came into force or revised

September 1, 2020

Status

Current

Policy statement

Independent schools are required to have an anti-money laundering / cash payment policy which describes the school’s policies and procedures regarding cash payments, and aligns with requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). This policy will be included as part of the standard required independent school policies and will be reviewed during the Ministry of Education and Child Care’s regular independent school inspection processes.  

As set out in the External Evaluation and Monitoring Policy for B.C. independent schools, a range of policies are reviewed during External Evaluation Committee (EEC) and Monitoring Inspections (MI) processes.

Rationale or purpose of policy

To inform B.C. Independent Schools about responsibilities related to money-laundering.

Authority

A requirement of the Inspector of Independent Schools under Section 4 of the Independent School Act.

Policy in full

The school anti-money laundering / cash payment policy must address the following:

• Criteria to identify and report suspicious transactions, i.e. transactions where there are reasonable grounds to suspect that payment may involve the proceeds of crime
• Cash payments acceptance limits, including tuition payments, deposits and supplemental fees that are aligned with FINTRAC standards
• Acceptable types of payment and acceptable financial institutions
• Steps taken by the authority to verify the identity of individuals making payments and to identify the source of payment (e.g. withdrawal receipt from one of 5 major Canadian banks) in cases where cash payments exceed a predetermined dollar value

• Procedures for issuing refunds for cash payments; and
• Cash handling and record keeping practises

Procedures related to policy

Each school’s anti-money laundering / cash payment policy will be reviewed during an EEC or MI to ensure it addresses the items noted above. Schools will be advised in the EEC or MI report (received after school inspections) if they are required to revise or develop related policies.