Criminals will try to launder or spend their illicit gains in different ways, including paying tuition fees or making donations to independent schools.

Based on National Crime Agency (NCA) data on suspicious activity report (SAR) volumes, and the low number submitted by the independent education sector, independent schools may be under-reporting and/or failing to identify funds that may be linked to criminal activity or breaching international sanctions.

This means schools could unwittingly become involved in criminal activity with the associated legal and reputational risks.

We have updated our guidance to include a list of ‘red flags’ which could indicate an attempt to commit financial crime or breach sanctions.

The following are some scenarios where schools may want to undertake further due diligence.

• The school receives funds for donations or fees from an unexpected third party without a logical reason or explanation.
• Third parties dealing with your school request account details outside the normal course of business.
• A fee payer takes steps to hide their identity and/or is difficult to identify.

Our updated guidance includes suggested actions schools could take if something concerning is discovered. For example, you may wish to:

• ask the fee payer/donor to provide evidence of the rationale and their connection to a third party
• scrutinise the source of funds and consider identifying the third party yourself independently through a screening tool and/or open-source information
• consider verifying any ID documents