Anti-Money Laundering and Sanctions Policy

To outline Seneca Polytechnic’s commitment to identifying and mitigating risks associated with money laundering and sanctions in providing funded educational services in Canada.

The policy applies to all Seneca employees, students and business partners.

As the Agent Agreement outlines, a third party Seneca entrusts with its operational services.

The activities institutions perform to actively prevent, detect, and deter money laundering.

Includes but is not limited to organizations, individuals, agents, trade vendors, donors, industry partners.

Collecting or verifying additional information to understand and mitigate risks posed by high-risk students.

Creating the appearance of legality through additional transactions. These transactions further shield the criminal from a recorded connection to the funds by providing a plausible explanation for the source of the funds.

Verifying that a student is the person they claim to be. 

Moving funds around the financial system, often in a complex series of transactions to create confusion and complicate the paper trail.

A person or entity on a government or other agency list.

An attempt to conceal or disguise the nature, location, ownership or control of illegally obtained money for the purpose of legitimizing the proceeds of crime. Money laundering typically occurs in three different stages: Placement, Layering and Integration.

The introduction of unlawful proceeds into the financial system without attracting the attention of financial institutions or law enforcement. Placement techniques include structuring currency deposits in amounts to evade reporting requirements or commingling currency deposits of legal and illegal enterprises.

An individual with a high-profile political role or entrusted with a prominent public function. Family members and close associates of a PEP are also considered PEPs. 

Legislation which combats the laundering of proceeds of crime and the financing of terrorist activities in Canada.

Ensuring that a system, process, or individual meets quality standards. 

A systematic process of evaluating the risks an institution may be subject to and analyzing any mitigating controls.

Restrictions put in place against target countries to maintain international security.

An individual enrolled in a course(s) or program at Seneca.

The process of detecting and identifying suspicious monetary transactions. 

1. Seneca is committed to preventing, detecting, and deterring money laundering and maintaining effective Anti-Money Laundering and Sanctions (AMLS) practices and procedures.
2. Funds received by Seneca for services may inadvertently or otherwise get exploited to facilitate money laundering.

1. Canada’s anti-money laundering laws reside within the Criminal Code, the Proceeds of Crime (Money Laundering) and the Terrorist Financing Act. 
2. Canadian sanctions are imposed under the United Nations Act, the Special Economic Measures Act or the Justice for Victims of Corrupt Foreign Officials Act.
   
3. Under the Criminal Code, it is an offence to knowingly deal with any property or provide or facilitate any financial or related service for terrorist activity, terrorist group or listed person. 
4. The Proceeds of Crime (Money Laundering) and the Terrorist Financing Act applies to reporting entities like financial institutions, credit unions, life insurance companies, loan companies, securities dealers, foreign exchange dealers, money services businesses, casinos, real estate brokers and developers.
5. While Seneca is not a reporting entity under the Proceeds of Crime (Money Laundering) and the Terrorist Financing Act, maintains an AMLS program.

1. The AMLS program is governed as follows:
   • Documented procedures clearly outline tasks and processes for administering and maintaining an effective AMLS Program
   • A Transaction Monitoring program identifies transactions with a higher risk of money laundering activity (see Appendix A)
   • A student identification program screens new and returning students for AMLS activities (see Appendix A)
   • An agent and business partner oversight program, which includes AMLS due diligence measures, including ongoing monitoring and agent renewal procedures, as outlined in AMLS Program Procedures (see Appendix C)
   • An annual AMLS risk assessment identifies risks encountered by Seneca, with mitigation measures to reduce risk; assessments are updated annually based on AMLS environments
   • Ongoing AMLS training offered to personnel responsible for administering the AMLS Program
   • An internal review conducted every two years, and an independent review of the AMLS Program as require

1. To the best of its ability, Seneca verifies the identity of all students who apply to and enroll in academic courses or programs. 
2. Seneca conducts the appropriate due diligence to understand the nature and background of its students and confirm that students’ funds do not originate from illicit sources.
3. Screening includes application signatories and third parties against the relevant sanctions, PEP and adverse media lists before admission (see Appendix B). 

1. Seneca will complete verification of its business partners before entering a business relationship and conduct appropriate due diligence checks. This includes collecting and verifying information on the prospective business partner and conducting any required screening (see Appendix C).

1. To maintain an effective internal control environment, Seneca conducts annual risk assessments.
2. Documented risk assessments include all inherent AMLS risk factors, an assessment of Seneca’s internal controls to mitigate AMLS risk factors, and the subsequent AMLS residual risk attributed to Seneca’s business operations.
3. Seneca provides its Risk Based Approach details in the Annual AMLS Program Review and Risk Assessment document.

1. Seneca monitors the transactions of its students, agents, and business partners to identify any suspicious payments and activity. (See Appendix A for details on Seneca’s Transaction Monitoring Procedures)

1. Seneca reviews its AMLS Program annually to assess the effectiveness of policies, procedures and controls.

1. Records about student identification and verification, sanctions screening, business relationship agreements, transaction records and training records will be maintained for seven years after a student leaves or after a business relationship ends.

1. Seneca employees initiate action to prevent and detect money laundering and any activity that facilitates it, within the scope of their job description and Seneca’s documented AMLS policies and procedures, and/or report such activities or suspected activities to the Compliance Department. 
2. Financial Services ensures sufficient resources and controls are in place to manage and monitor the AMLS Program.
3. Financial Services monitors and assesses the overall effectiveness and oversees the day-to-day activities of the AMLS Program, and reports any issues or findings to the Senior Executive Committee.  
4. Financial Services monitors for suspicious activity, payments and/or transactions and screening students, agents and necessary third parties against applicable watchlists.  
5. Compliance is responsible for developing and implementing an ongoing assessment of AMLS controls to ensure that emerging risks are highlighted, resolved or mitigated; this includes ongoing AMLS training for all necessary personnel. 
6. Financial Services ensures sufficient resources and controls are in place to manage and monitor AMLS policies and procedures. 

• Appendix A: Procedures - Transaction Monitoring – Money Laundering
• Appendix B: Procedures - Transaction Monitoring – Sanctions Screening
• Appendix C: Student and Agent Identification Processes
  

• Academic Integrity Policy
• Academic Partnership Policy
• Admissions Policy
• International Student Recruitment Agency Management Policy

• Criminal Code
• Justice for Victims of Corrupt Foreign Officials Act
• Proceeds of Crime (Money Laundering) and the Terrorist Financing Act
• Special Economic Measures Act
• United Nations Act

1. Seneca does not accept cash payments.
2. Payment for tuition fees is accepted using a third-party international payment processor or credit cards. 
3. Third-party vendors or credit cards follow the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

1. Student refunds are returned to the original payer, account and country using a third-party international payment processor with an anti-money laundering and sanctions (AMLS) review prior to releasing funds.
2. For exceptions, Seneca ensure funds are paid to an individual or organization that are clear of AMLS; these requests are screened using third-party AMLS software and are approved by the Finance department prior to funds being released. 

1. Seneca monitors and reviews incoming and outgoing transaction activity associated with its students, and business partners daily, maintains a log of suspicious transactions.
2. Seneca engages third-party service to identify unusual or suspicious activity with its transactions. The third-party service outlines issues with a specific transaction and will put on hold until further investigation is complete and will decline the transactions if the outcome of the investigation confirms the suspicious activity. 
3. Seneca maintains a Transaction Monitoring Issue Log (TM Log) managed by the payment office for incoming funds and accounts payable for outgoing funds and logs issues identified for both incoming and out-going transactions. 
4. The TM Log tracks:
   • suspicious transactions that have been flagged for review and the outcome of each transaction 
   • transactions and issues that are identified over the normal course of business.  
5. The TM Log is reviewed monthly by the Finance department, and each quarter, a summary of the TM Log is generated for senior leaders outlining number of suspicious transactions, reason for suspicion, emerging trends and any recommendations for changes to Seneca’s AMLS process. 

1. Seneca performs sanctions screening on all its students prior to admission, and on a per-term basis thereafter.
2. Seneca perform sanctions on all business partners and third parties, including the beneficial owners of legal entities that are making tuition payments on, or on behalf of, a student. 
3. A third-party licensed AMLS subscription service is used to screen students against the necessary sanctions lists.

1. Seneca will not process a transaction, nor accept an application, if a student (or associated agent or third-party) or transaction is a match for an individual/entity appearing on any Canadian or international sanctions lists. 
2. In instances where Seneca identifies a sanction match after having processed the non-refundable application deposit, Seneca will immediately reject the application and return the non-refundable deposit to the original payee; the denial of the application is noted on the student record along with the reason for non-acceptance. 

1. Seneca’s Sanctions Screening Manual provides a detailed overview of Seneca’s sanctions screening procedures. 

1. Seneca maintains detailed procedures on student identification and verification.
2. Seneca conducts student identification procedures prior to admission, or if identification information maintained by Seneca has changed during the period in which the student has been enrolled at Seneca. 

1. Prior to admitting a student, Seneca will collect sufficient and appropriate information from the student, such as name, gender, date of birth (“DOB”), birth country, citizenship country, application country, primary language, email address and primary mailing address.
2. Collected information is verified by collecting government-issued photo ID and validating that the information on the government-issued photo ID matches the information provided by the student. 
3. Examples of acceptable government-issued photo IDs include, but are not limited to, passports, driver licenses, citizenship cards or permanent residency cards. 
4. All government-issued photo ID documents provided to Seneca must be authentic, valid and current. 

1. Seneca will screen all international students (including, whenever possible, application signatories and third parties) against relevant sanctions, politically exposed persons and adverse media lists prior to admission. 
2. Thereafter, students are screened every academic term where they are actively enrolled.

1. Enhanced Due Diligence may involve:
   • seeking further information from the student (or other sources) regarding the student’s “Know Your Student” information
   • seeking further information to clarify the nature of the relationship between a student and an application signatory or third-party, undertaking a more detailed analysis of the student’s “Know Your Student” information
   • undertaking a more detailed analysis and monitoring of the student’s past and future transactions
2. In instances where a Student’s funds are being paid for by a third-party or legal entity, Seneca will whenever possible collect and verify information about that third-party or legal entity, including, but not limited to, beneficial ownership information, as well as screening beneficial owners against sanctions, politically exposed person and adverse media lists. 

1. Seneca performs ongoing monitoring of its students every academic term. 
2. Ongoing monitoring entails a review of the student’s “Know Your Student” information provided by the student and ensuring that it is accurate and up to date.
3. Seneca will monitor students’ payments and account activity for suspicious activity and for alignment with expected activity and the intended purpose and nature of the account. 

1. Seneca takes various steps to know its agents and business partners prior to entering into a business relationship. 
2. For new agents, Seneca will conduct an in-depth discussion with them as outlined in the International Student Recruitment Agency Management Policy. 

Approval Date: July 2022

Last Revision: July 2024