Academic Handbook Financial Management Policies

Anti Money Laundering Risk Assessment

Last modified on January 31st, 2023 at 9:57 am

This Risk Assessment is to be read in conjunction with Northeastern University London’s (the University) Anti Money Laundering Policy and Guidance.

Risk Area	Description of Risk	Risk Mitigation/Control
Products & Services	Cash transactions, anonymous transactions, transactions involving unknown third parties and unregulated transactions	Most risks are mitigated as a result of the funds being paid directly to the University as the course or service provider by Northeastern University and Student Loan Company and a smaller proportion coming directly from the student or their nominate payee. Third party payments are only accepted under limited circumstances, such as where the third parties have been authorised by a student and are closely related to the student. Additional due diligence checks are performed where the third party is unrelated. We recognise that there are AML risks associated with refunds and will raise the awareness of those involved in processing such transactions that constant vigilance is required.
Customers, third parties and donors	Whilst many of our students are UK residents, or come via our parent company Northeastern University we recruit a proportion of international students some of which will come from/study in higher risk locations. The University conducts a modest amount of research in partnership with international partners, and is seeking to increase its international partnerships.	Customer due diligence procedures are implemented to mitigate this risk: (a) All new students have to present proof of identity as part of our registration processes. (b) Refunds are made to the original payer of the money or the student. (c) Maximum limit for cash payments is £500 (d) Anonymous payments not accepted.
Jurisdiction	Our activities are conducted primarily in the UK. Some of our activities are conducted in partnership with our parent institution, Northeastern University (NU).	We do not currently conduct business with countries that lack robust AML approaches (which might make them subject to sanctions or embargoes). Should this change a risk assessment will be undertaken on a case by case basis.
Distribution	Most of the University’s teaching activity is delivered on its London Campus and represents a low risk. However, the University has in recent years increased its provision of blended/online delivery which presents a higher level of risk however these customers are currently based in the UK.	Online and distance learning students must produce proof of identity and prior qualifications. Business relationships with International Agents are governed by formal contracts. MoUs and other academic partnerships are only confirmed after implementation of the appropriate procedures.

The University has assessed each of these risk areas on a RAG (Red, Amber, Green) scale equating to high, medium and low risk. All of these risk areas are currently assessed as Green.

In addition, the British Universities Finance Directors Group has identified the following areas of potential risk:

Payments in cash
Unidentified cash receipts
Applicants from high-risk countries
Requests for refunds
Overpayments
Failure to take up places
Agents who do not fit in with normal procedures relating to deposits and tuition fees
Identity fraud

Title: Anti-Money Laundering Risk Assessment Approved by: Executive Committee Location: Academic Handbook/ Strategies/ Financial Management Strategy and Policies
Version Number	Date Approved	Date Published	Owner	Proposed Next Review Date
2.0	November 2022	November 2022	Director of Finance	July 2024
1.0	September 2021	September 2021	Director of Finance	July 2024

Related Documents	Anti-Money Laundering Policy, Anti-Money Laundering Form
External Reference Point(s)	Proceeds of Crime Act 2002 (as amended by the Crime and Courts Act 2013 and the Serious Crime Act 2015); Terrorism Act 2000 (as amended by the Anti-Terrorism, Crime and Security Act 2001); Counter-Terrorism Act 2008 Schedule 7; Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017; HM Treasury Sanctions Notices and News Releases, now incorporated in the Money Laundering Regulations 2017 ; Criminal Finances Act 2017.