4.8 Payment Control Policy

POLICY TYPE: 4.0 Financial
EFFECTIVE DATE: 2020-11-20	LAST REVISED: 2025-12-09
THIS POLICY APPLIES TO: Contractors – Individuals engaged to provide services under a contract with SelfDesign Learning Foundation Support Providers – Individuals engaged under a contract or agreement with SelfDesign Learning Foundation to provide services for a specific learner Families – Learners and parents(s)/guardian(s) of learners participating in SelfDesign Learning Foundation’s programs Volunteers – Individuals providing goods/services under the terms of an agreement with SelfDesign Learning Foundation Board Members – Members of the Board of Directors for SelfDesign Learning Foundation and the Foundation for SelfDesign (FSD)

Policy Statement

SelfDesign Learning Foundation (SDLF) is committed to ensuring that all payments for services, products and/or donations to the organization will be satisfactorily verified and accurate record-keeping practices followed.

Definitions

Suspicious transaction report – A suspicious transaction report is a type of report that you must submit to FINTRAC when a financial transaction occurs, or is attempted, in the course of your activities and there are reasonable grounds to suspect that the transaction is related to the commission or the attempted commission of a money laundering or terrorist activity financing offence (Canada.ca > FINTRAC).

Policy

SelfDesign Learning Foundation will not accept cash donations or payments for services, programs, or products, including the following: tuition, deposits, or supplemental fees for activities, such as camps or gatherings.

Protocol

Acceptable Forms of Payment

Acceptable forms of payment are electronic fund transfers, cheque, or credit card, issued by accredited/recognized financial institutions.

Payment by Mail

Payments by mail will be accepted in the form of a cheque payable to the organization.

Record Keeping Practices

The organization uses NetSuite as its financial software and utilizes SDLF’s approved cloud platform (File system) to store all financial documents, including any Suspicious Transaction Reports that have been filed with FINTRAC according to direction from FINTRAC. The organization also only makes payments to Canadian bank accounts that have been FINTRAC verified.

All Suspicious Transaction Reports will be documented electronically. All enquiries that are made within SDLF in relation to any Suspicious Transaction Report should also be recorded.

SDLF will keep details of actions taken in respect of Suspicious Transaction Reports, including details of information considered by the Chief Financial Officer (CFO) in respect of a Suspicious Transaction Report where no external FINTRAC report is made. SDLF will also keep a copy of any FINTRAC Reports and associated evidence and documentation. All information, evidence and reports with respect to Suspicious Transaction Reports, FINTRAC Reports, and identification and verification of individuals will be kept by SDLF for a minimum of five years.

Refunds

No refund shall be issued without supporting documentation providing evidence of original proof of payment to the organization. Refunds shall be issued in accordance with the same method in which the payment to the organization was received (cheque, EFT, credit card). Refunds must be approved by the department lead and a senior member of the finance staff.

Donations are ineligible for a refund, however a tax receipt shall be issued in accordance with CRA regulations.

Reporting

SDLF contractors will make a report to the CFO, or via the Whistleblower process, 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 (this report is referred to as a “Suspicious Transaction Report”). The report should include as much detail as possible, including:

Full available details of the people, and organizations involved including SDLF contractors and other members of the organization, if relevant.
Full details of the transaction and nature of each person’s involvement in the transaction.
Suspected type of money laundering activity or use of proceeds of crime with reasons for a SDLF contractor’s suspicion.
The dates of any transactions, where they were undertaken, how they were undertaken, and the likely amount of money or assets involved.
Information on any investigation undertaken to date, including whether the suspicions have been discussed with anyone and if so on what basis.
Whether any aspect of the transaction(s) is outstanding and requires action to progress.
Any other information that may help the CFO judge the case for knowledge or suspicion of money laundering and to facilitate any external report.

Once the SDLF contractor has reported their suspicions to the CFO, they will follow any instructions provided. The contractor will not make any further enquiries unless instructed to do so by the CFO. 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 CFO as they happen, unless and until the CFO has confirmed that no report to the FINTRAC is to be made.

The CFO 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 (this external report is called the “FINTRAC Report”). All FINTRAC Reports will comply with FINTRAC reporting requirements. Should a Suspicious Transaction occur, the CFO will notify the CEO and the Board of Directors.

Suspicious Transactions

SDLF contractors will evaluate the source of funds that are paid to SDLF 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 SDLF contractors 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:

Multiple transactions – the payer engages in multiple transactions conducted below the reporting threshold within a short time period, makes inquiries that would indicate a desire to avoid reporting, or exhibits knowledge of reporting thresholds.
Unclear structures – payments involving complex or illogical arrangements that make it unclear who is making the payment or appear to be structured to avoid identification or reporting thresholds.
Involving third parties – payment of fees or involvement by companies, trusts, off-shore entities or other third parties with no obvious relationship to the nature of the service. The payer appears to be collaborating with others to avoid client identification or reporting thresholds.
Assets in doubt – there are reasons to doubt the ability of a person to have a legitimate source of funds.
Hidden identity – the payer has taken steps to hide their identity or is difficult to identify. The 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 payer.
Unusual behaviour – the payer seems unusually anxious to complete a transaction, is unable to justify why they need to make a payment quickly, requests a cancellation, reversal or refunds of earlier transactions or makes an overpayment for no good reason.
Withheld documents – information or documentation is withheld by the payer or their representative or appears falsified. Cash payments are made using old, smelly or extremely dirty bills.