BURSARS
On guard for
MONEY LAUNDERING Tim Ryan gives clear and concise advice on ways to mitigate the problem and avoid unwittingly committing an offence
U “Do you have a Money Laundering Reporting Officer?” It has been estimated that every year about £90 billion of criminal money gets laundered through the UK, but in 2017 only six out of the 423,000 Suspicious Activity Reports submitted to the National Crime Agency (NCA) came from education institutions. In September 2018, the head of economic and cyber crime at the NCA stated that private schools need to be doing much more to address the issue, and later that year, in announcing a major crackdown on money launderers, Ben Wallace, Minister of State for Security and Economic Crime, threatened to come down hard on those schools ‘who don’t ask many questions if suspicious people come along with cash’. Whether the criticisms are fair or not, it can no longer be denied that the risks are significant. According to the latest UK Independent Schools Council census, more than 55,000 pupils at its member schools 14
schoolmanagementplus.com I Autumn 2020
ntil recently, you might be forgiven for thinking that money laundering is really only a problem for banks, accountants and solicitors to worry about and not something to overly-concern schools. Certainly, schools have never been subject to the same strict anti-money laundering regulations that apply to businesses and individuals who carry out work in the so-called regulated sector. A few wellpublicised cases and warnings from senior police officers and politicians have, however, gone some way to change that perception.
“It’s very easy to be complacent, and to think it won’t happen to you” come from overseas, including more than 2,500 Russians, 1,400 Nigerians and almost 600 from Central Asia. While the vast majority of parents choosing to educate their children at schools in the UK are doing so from perfectly legitimate sources of wealth, there are a small number for whom that won’t be the case.
In a nutshell
Money laundering, put very simply, is the process by which the proceeds of crime are converted into assets which appear
to have a legitimate origin. But money laundering is far from simple and can take an almost infinite number of forms, in which money is cycled and recycled through the system, again and again, to prevent it being traced back to the criminal activity from which it first derived. In the independent school sector, money laundering can include any of the following scenarios: • donations to projects for which an appeal is being run • donations to the school for no obvious reason • payments in advance for fees • the requested return of fees paid in advance. Or, it might just be the payment of fees from illicit wealth in order to enhance a family’s reputation by having their child in a prestigious school. Clearly you need to be on your guard.
