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Anti-Money Laundering Procedures and Additional Information

University procedures for preventing money laundering: identify risks, verify customers, keep records, report suspicions promptly and comply with legal duties.

Procedure

Owner
Director of Finance
Version
2.0
Approval date
10 Sep 2026
Approved by
Finance Committee
Date of last review
01 Jun 2026
Date of next review
01 Jun 2029

What is Money Laundering?

Money laundering is the process of taking the proceeds of criminal activity and making them appear legal. It also includes financial transactions involving money, however obtained, which is used to fund terrorism. The definition of money laundering under UK legislation is broad.

There are three principal money laundering offences under the Proceeds of Crime Act 2002:

  • Concealing, disguising, converting, transferring criminal property or removing it from the UK (Section 327)
  • Entering into or becoming concerned in an arrangement which facilitates the acquisition, retention, use or control of criminal property (Section 328)
  • Acquiring, using or possessing criminal property (Section 329)
  • These offences are punishable by unlimited fines and/or imprisonment of up to 14 years.

Associated offences include:

  • Failure to disclose knowledge or suspicion of money laundering
  • Failure to maintain adequate procedures to prevent money laundering
  • Tipping off – where a person informs someone that they are under investigation, potentially prejudicing that investigation

Preventing Money Laundering

The University complies with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.

Record Keeping

Departments conducting relevant transactions must maintain records for at least six years, including:

  • Student/Customer identification evidence (CDD/KYC documents)
  • Details of financial transactions carried out

In practice, routine business records are generally sufficient to meet this requirement.

Reporting Suspicious Activity

The University must disclose where it has knowledge or suspicion of money laundering, or where it ought reasonably to have formed such a suspicion. Staff should be familiar with normal customer behaviour. Any unusual transactions or requests should raise suspicion.

Concerns must be reported immediately to the Money Laundering Reporting Officer (MLRO). Suspicion may also arise from notifications received from the University’s bank, payment providers or other third parties.

Customer Due Diligence (CDD/KYC)

Staff must be reasonably satisfied as to the identity of customers and third parties. Evidence may include passports, visas, birth certificates, and proof of address. For organisations, staff should verify authenticity through official documentation, websites, credit checks, or direct contact.

Risk Assessment

The University’s maintains an AML Risk Assessment and reviews it periodically. The AML Policy is subject to triennial review.

Risk assessment must consider: - Product/Service Risk - Jurisdiction Risk - Customer/Third Party/Donor Risk (including Politically Exposed Persons and sanctioned parties) - Distribution Risk (delivery channels such as in-person, digital, or telephone)

Training

The following departments are identified as higher risk and must complete AML training every two years:

  • Finance & Procurement Office (F&PO)
  • Department for Development and Alumni Relations

Money Laundering Reporting Officer (MLRO)

The University has appointed Mr Martin Williams, Director of Finance, as MLRO. The MLRO is responsible for receiving, considering, and reporting disclosures. The MLRO may delegate responsibilities to the Director of Finance Operations.

Reporting Suspicious Activity

If you know of, suspect, or have concerns about money laundering, or believe your involvement may breach AML regulations, you must report this immediately to the MLRO.

Disclosure reports must be submitted using the proforma available from the Income Team in Finance & Procurement Office (F&PO) and completed on the same day the concern arises.

Failure to report may result in personal liability under AML legislation.

Reports should include:

  • Full details of individuals and organisations involved
  • Full details of the transaction
  • Reasons for suspicion
  • Dates, locations, methods, and amounts involved
  • Any other relevant information

Support is available from the F&PO Training and Compliance Officer for completing disclosure reports or investigations.

Upon receipt, the MLRO will acknowledge the report and advise on response timescales.

To avoid tipping off, once a report is submitted, you must not make further enquiries or discuss the matter unless instructed by the MLRO.

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