Your refund process could be a money laundering risk

Your refund process could be a money laundering risk

The payment problem universities are only just waking up to

By Thomas Butler, International Commercial Director, TransferMate Global Payments

At EnrolyCon26, I asked a room full of university leaders one question:

How safe are your CAS payments?

While most institutions have tightened admissions and compliance processes over the last few years, payment workflows often remain surprisingly manual, fragmented, and exposed.

And that matters more than many teams realise.

As international recruitment expands into newer markets, universities are handling growing volumes of:

  • International deposits
  • Refund requests
  • Third-party payments
  • Overseas bank transfers
  • Outstanding student debt

At the same time, financial crime risks are becoming harder to spot.

The risks hiding inside “normal” payment activity

One of the biggest themes from the session was how ordinary-looking student payments can create unexpected compliance exposure.

We discussed:

  • Refund schemes used for money laundering
  • Third-party payer risks
  • Fraudulent supplier payments
  • Cash payments with unclear origins
  • Manual refund processes with limited oversight

One example raised was students being encouraged to pay a small deposit, then request a refund to “clean” money through legitimate institutions.

Operationally, it can look routine, but from a compliance perspective, it is not.

Why universities are rethinking payment workflows

The real challenge is not just processing payments quickly.

It is knowing:

  • where money came from
  • who paid it
  • where refunds are going
  • whether transactions should raise concerns

That is why more institutions are starting to look at integrated payment and compliance workflows rather than treating payments as a separate finance process.

During the session, we explored how automated AML screening, sanctions checks, safeguarded funds, and structured refund workflows can reduce both risk and admin pressure.

For many teams, refunds have quietly become one of the biggest operational headaches in international admissions.

The other issue universities rarely talk about: unpaid student debt

Another topic that sparked a lot of discussion was international debt recovery. Many universities still write off large volumes of unpaid international fees simply because recovering them across countries is operationally difficult.

But with financial pressure growing across the sector, that is starting to change.

As I said during the session:

“It’s money left on the table.”

Automated repayment plans, international collection workflows, and student self-service payment portals are now helping universities recover revenue without creating even more manual admin for finance teams.

The bigger shift

The wider point is simple: payments are no longer just a finance function. They are now part of the wider conversation around:

  • compliance
  • operational risk
  • student experience
  • institutional oversight

Because in international education, the risk does not stop once the CAS payment arrives. What used to be viewed as a back-office finance process is quickly becoming a strategic risk area for universities.

And as international recruitment becomes more global, more complex and more regulated, institutions that can combine payments, compliance and operational visibility will be far better positioned to scale safely.

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