Home >
Download the Strengthening Resilience Against Financial Crime PDF
on
Strengthening Resilience Against Financial Crime
Introduction
UK Higher Education Institutions (HEIs) operate within a complex and increasingly vulnerable financial landscape. With significant public funding, international partnerships, devolved governance, and high-volume transactions across student finance, procurement, and donations, HEIs face multifaceted risks that extend well beyond traditional notions of fraud.
Recent high-profile incidents have brought these risks to the forefront. In one such case, the University of West London became the focal point of £6.2 million in fraudulent student loan applications — the majority tied to its franchised partner, Oxford Business College. Elsewhere, students have been convicted for laundering drug money through institutional payment systems, exploiting weaknesses in oversight and detection. These examples signal an urgent need for HEIs to reframe financial crime not as an isolated threat, but as a persistent and evolving governance challenge.
This document provides comprehensive guidance on how HEIs can embed fraud resilience into core operations, strategic oversight, and institutional culture. It examines legal obligations under the UK’s Failure to Prevent Fraud offence, sector-specific vulnerabilities, and practical methods to foster proactive risk management. Importantly, it encourages institutions to look beyond compliance — advocating for a values-driven, prevention-first approach that aligns with the ethical standards expected of publicly funded education providers.
As the sector continues to engage with global markets, adapt to digitalisation, and navigate funding pressures, building a robust defence against financial crime must be recognised as both a compliance necessity and a moral imperative.
This evolving risk environment is now shaped by new legal obligations introduced through Section 199 of the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Coming into force on 1 September 2025, the Failure to Prevent Fraud offence establishes criminal liability for large organisations where an associated person, such as a staff member, student, contractor, or academic partner, commits a fraud offence intended to benefit the institution or its clients.
Notably, this is a strict liability offence. There is no requirement to prove knowledge or intent by senior leadership; liability arises solely from the failure to prevent. HEIs fall into scope if they meet two out of three criteria:
- 250 or more employees.
- Over £36 million in annual turnover.
- More than £18 million in total assets.
Defence is only available where institutions can demonstrate that reasonable prevention procedures were in place, or that such procedures were not reasonably expected given the circumstances. While smaller HEIs may fall outside the formal scope, the principles of the offence, and the reputational risks it represents, apply sector-wide.
Please download to read the full resource.
How can we help you?
For more advice on how we can help lower the cost of your risk, please email contact@rmpartners.co.uk
Unsubscribe
You can opt out of marketing communications at any time by contacting us.
Related Resources
Sign up to receive the latest from rmp
Sign up to receive the latest from RMP
For information on how we use your personal data please refer to our UK Privacy Notice | EEA Privacy Notice.
