1.0 Purpose and Scope

This policy supports the University's commitment to good governance, integrity, regulatory compliance and protection of its reputation.

The purpose of this policy is to outline how the University and its staff will manage money laundering risks, apply Customer Due Diligence (CDD)/ Know Your Customer (KYC) principles, and comply with applicable UK legal and regulatory requirements relating to Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and financial sanctions.

This policy applies to all members of University staff, including students acting as employees, members of Council, and associated parties. It covers University activities undertaken in the UK and overseas. Money laundering legislation applies to all employees.

Potentially any member of staff could be committing an offence under the money laundering laws if they suspect money laundering or if they become involved in some way and do nothing about it. If any individual suspects that money laundering activity is or has taken place or if any person becomes concerned about their involvement it must be disclosed as soon as possible to the University’s Money Laundering Reporting Officer MLRO), as outlined in this policy’s accompanying ‘Anti-Money Laundering Policy – Procedures and Additional Information’ document.

2.0 Definitions

Associated Parties

Individuals or entities connected to the University, including members of Council, contractors, agents, suppliers, and partners.

Customer / Payer

Any individual or organisation that makes a payment to, or conducts financial transactions with, the University, including students, sponsors, donors, and third parties.

Disclosure Report

An internal report made by a member of staff to the Money Laundering Reporting Officer (MLRO) where there is knowledge or suspicion of money laundering activity.

Due Diligence

The process of identifying and verifying the identity of customers, payers, or third parties, and assessing potential risks associated with a business relationship or transaction.

Customer Due Diligence (CDD)/ Know Your Customer (KYC)

Procedures undertaken to verify the identity and legitimacy of the source of funds and the individual or organisation making a payment to the University.

Money Laundering

The process of concealing, disguising, converting, transferring, or handling the proceeds of criminal activity to make them appear legitimate, including the funding of terrorism.

Money Laundering Reporting Officer (MLRO)

The individual appointed by the University to receive, assess, and report disclosures of suspected money laundering activity to the appropriate authorities. The MLRO is responsible for overseeing AML compliance procedures.

Suspicious Activity

Any transaction or behaviour where there is knowledge, suspicion, or reasonable grounds to suspect that money laundering or terrorist financing may be taking place.

Suspicious Activity Report (SAR)

A formal report submitted by the MLRO to the National Crime Agency (NCA) when there is a suspicion of money laundering or terrorist financing.

Terrorist Financing

The provision or collection of funds, by any means, with the intention that they should be used to support terrorist acts or organisations.

Transaction

Any exchange, payment, transfer, or movement of funds or assets involving the University.

3.0 Roles and Responsibilities

Finance Committee

Approval of the Anti-Money Laundering Policy and any amendments to it, as recommended by the University Executive Board and Finance Department.

All staff or associated parties

Any member of staff or associated party who suspects that money laundering activity is or has taken place or becomes concerned about their involvement in a transaction must disclose this, in writing, as soon as possible to the MLRO, as outlined in the policy’s accompanying ‘Anti-Money Laundering Policy – Procedures and Additional Information’ document. Individuals must then co-operate fully with any subsequent investigations whilst maintaining confidentiality about the suspected activity.

Money Laundering Reporting Officer (Director of Finance)

The MLRO, supported by the Finance & Procurement Office (F&PO) Training and Compliance Officer, is responsible for developing and maintaining appropriate anti -money laundering procedures (including the ‘Anti-Money Laundering Policy – Procedures and Additional Information’ document) and for receiving, considering and reporting, as appropriate, on any disclosure of suspicious activities by staff.

The MLRO or their delegation will investigate all reports or disclosures in accordance with the procedure.

The MLRO will instruct the Income Office Manager to suspend a transaction(s) and may delegate the submission of a Suspicious Activity Report to the National Crime Agency (NCA) to the F&PO Training and Compliance Officer or another member of staff as appropriate, if there is a suspicion of terrorist financing or money laundering.

An Anti-Money Laundering Risk Assessment will be reviewed on an annual basis; and the Anti-Money Laundering Policy shall be reviewed on a three-year cycle, or as new legislation prompts a review.

Income Office Manager

Responsibility for maintaining a register /log of Disclosure Forms and Suspicious Activity Reports.

University Secretary

If appropriate, the Office for Students shall be notified of a 'Reportable Event' in accordance with the University's ongoing conditions of registration obligations.

4.0 Policy Statement

The University of Bath is committed to maintaining the highest standards of ethical conduct and adopts a zero-tolerance approach to financial crime, including money laundering and terrorist financing.

The University will comply with all applicable UK legislation relating to anti-money laundering, counter-terrorist financing, and financial sanctions, including but not limited to:

• The Proceeds of Crime Act 2002 (as amended)
• The Terrorism Act 2000 (as amended)
• The Counter-Terrorism Act 2008
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) The Criminal Finances Act 2017
• UK financial sanctions legislation, including regulatory requirements administered by HM Treasury and the Office of Financial Sanctions Implementation (OFSI)

Any breach of this Policy may constitute a disciplinary matter and will be investigated in accordance with the University’s disciplinary procedures. This may result in disciplinary action up to and including dismissal. In addition, failure to comply with applicable legislation may expose individuals to personal criminal liability.

Non-compliance with these legal and regulatory obligations may result in significant financial and reputational damage to both the University and the individuals involved. While the overall risk to the University is considered low, it is essential that all staff understand and adhere to their responsibilities under this Policy. Serious criminal sanctions may be imposed for breaches.

All staff are required to remain vigilant and must promptly report any knowledge or suspicion of money laundering or terrorist financing to the Money Laundering Reporting Officer (MLRO) in accordance with University procedures.

Further guidance and additional information can be found in this policy’s accompanying Anti-Money Laundering Policy – Procedures and Additional Information document.