Criminal typologies & compliance confidence: TransferMate at EnrolyCon’25 covering Anti-Money laundering
What if your institution was unintentionally enabling money laundering? It’s already happened. And without the right systems in place, it could happen again.
At EnrolyCon 2025, one session tackled one of the most urgent, and under-discussed, compliance risks facing international higher education today: financial crime. Led by Thomas Butler of TransferMate Global Payments, the session explored the increasing vulnerability of UK universities to money laundering threats, and what can be done to stay ahead.
Why this session mattered
International students contributed £58 billion to the UK economy last year, supporting over 260,000 jobs. Deposits processed through Enroly alone were up 27% for the January 2025 intake. With large sums and rapid growth, universities are under greater pressure to ensure that every transaction stands up to scrutiny.
New legislation, including the 2023 Economic Crime and Corporate Transparency Act, puts universities closer to the spotlight, especially when funds originate from high-risk regions or come through third-party payers.
Key takeaways
1. The threats are real
A real-life case study revealed how four university students were involved in laundering millions in drug proceeds through UK institutions. Common tactics include:
- Third-party payees
- Refund fraud
- Insider collaboration
2. Higher education isn't immune
Universities may not be regulated financial institutions, but accepting high-risk funds without due diligence can still lead to serious consequences, from regulatory penalties to reputational damage.
3. The penalties are steep
Violations can result in fines of up to £500,000 (or double the value of the proceeds) and up to 14 years of imprisonment. But for universities, the bigger threat is the potential loss of trust from students, sponsors, and the public.
4. It takes more than ticking boxes
Institutions need to move beyond ad hoc checks and build an Anti-Money Laundering (AML) culture: proactive, process-led, and backed by modern systems.
5. Integrated solutions are key
TransferMate’s global compliance framework is embedded in Enroly’s CAS Shield platform (payment integration) offering built-in transaction monitoring, payer verification, and secure refund workflows, reducing risk without creating new admin burdens.
What you can do now
- Only refund to the original source of payment
- Use platforms with embedded AML typology detection
- Train staff to spot financial red flags
- Ensure every transaction has a clear audit trail
- Actively monitor for suspicious behaviour, don't wait to be audited
Bonus insight
TransferMate’s FinCrime team has helped UK universities recover fraudulent payments, including a recent case in which £30,000 sent to a scam supplier in China was successfully recovered. When integrated with Enroly, their tools help flag risky transactions before they happen.
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