Payment & Refund Policy

GENERAL STATEMENT

SDLF will ensure that all payments for services, products and/or donations to the organization will be satisfactorily verified  and accurate record keeping practices followed.

SCOPE

All areas of the organization.

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.

 PROCEDURES
  1. ACCEPTABLE FORMS OF PAYMENT

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

  1. PAYMENTS BY MAIL

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

  1. 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.

  1. 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:

  • 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. 
  • 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. 
  • 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: There are reasons to doubt the ability of a person to have a legitimate source of funds 
  • 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. 
  • 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 transaction or makes overpayment for no good reason. 
  • 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. 

  1. REPORTING

SDLF contractor/s will make a report to the Director of Finance, 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 (“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 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 Director of Finance 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 Director of Finance, they will follow any instructions provided. The contractor will not make any further enquiries unless instructed to do so by the Director of Finance. 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 Director of Finance as they happen, unless and until the Director of Finance has confirmed that no report to the FINTRAC is to be made. 

The Director of Finance 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. 

  1. RECORD KEEPING PRACTICES

All Suspicious Transaction Reports will be documented, either on paper or 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 Director of Finance 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.

Change Log

  • Policy page updated November 10, 2020
  • Last reviewed/updated November 10, 2020