As global regulation tightens and the UK government intensifies its crackdown on money laundering, higher education institutions (HEIs) are under increased pressure to demonstrate compliance, especially when onboarding international students. The latest updates to the UK’s anti-money laundering (AML) regulations, including the revised LSAG guidance (April 2025) and the Economic Crime and Corporate Transparency Act 2023 (ECCTA), introduce new expectations around financial scrutiny and risk assessment.
For universities, this marks a shift: Know Your Customer (KYC) checks are no longer “nice to have”. They are fast becoming a compliance imperative, not just to meet evolving regulations, but to safeguard institutional reputation and ensure ethical recruitment at scale.
The compliance gap in Higher Education
Despite the shifting regulatory landscape, many UK universities still do not carry out consistent pre-arrival checks on international students. Basic steps, such as verifying identity, and validating source of funds, are often missing or inconsistent. This creates exposure to financial crime, reputational damage, and regulatory scrutiny.
Recent updates like the revised LSAG guidance (April 2025) and the Economic Crime and Corporate Transparency Act (ECCTA) 2023 bring universities closer to regulated expectations, especially where large sums of international money are received.
Key regulatory expectations for universities
- Enhanced due diligence (EDD) for high-risk applicants
- Source of funds checks
- Documentation of financial histories
- Suspicious Activity Reports (SARs) where necessary
While universities may not be directly regulated under the Money Laundering Regulations 2017, the expectation is clear: institutions must demonstrate awareness, implement appropriate controls, and act where financial risk is evident.
How Enroly supports AML and KYC compliance
Enroly’s CAS Shield platform is designed to close this compliance gap, enabling institutions to meet the expectations of the 2025 AML updates with greater confidence and much less manual burden.
Here’s how Enroly helps:
- Passport verification with OCR
Using advanced OCR technology, Enroly extracts and reads the data from student passports. The system flags discrepancies between the passport data and the information held by the institution, a key step in identifying potential fraud and meeting core customer due diligence (CDD) requirements under the AML regime. - Biometric ID checks (facial recognition)
Our integrated video interview tech confirms that a student matches their submitted ID, aligning with guidance that now prioritises biometric identity validation as part of best-practice EDD. - Financial document collection & source of funds verification
Students upload bank statements and financial guarantees through the platform, which are automatically screened for red flags, such as ties to sanctioned banks or high-risk jurisdictions. Enroly enables institutions to trace the flow of funds and identify where financial documentation may lack a credible trail, a critical step in assessing risk and ensuring that funding sources are legitimate. - Payment integration with TransferMate
As one of the world’s largest regulated education payment providers, TransferMate brings its own suite of embedded KYC and AML checks into Enroly. This integration ensures institutions benefit from world-class transaction monitoring, currency origin tracking, and payer identity verification, all crucial as financial transparency becomes a central compliance concern. - Expanded documentation capture
Enroly automates the collection of immigration documents, previous visas, and travel history, strengthening the institution’s ability to assess student backgrounds holistically and in line with AML expectations for ongoing monitoring and reporting.
Why this matters now
Criminal typologies targeting higher education are becoming more sophisticated. A recent EnrolyCon session highlighted tactics like third-party payments, refund fraud, and insider collaboration. A UK university reportedly recovered £30k sent to a fraudulent supplier, showing how real and immediate the risks can be.
Meanwhile, TransferMate’s compliance team supports global financial crime detection in over 90 jurisdictions, bringing global intelligence directly into Enroly’s workflows.
The cost of inaction? Civil or criminal penalties, reputational harm, and potential visa sponsorship implications.
In summary
KYC and AML checks are fast becoming foundational to ethical, compliant student recruitment. Enroly CAS Shield equips universities with the tools they need to help meet these rising standards, automatically, transparently, and at scale.
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