Since 2019, a series of media reports have highlighted the fact that universities in Canada and the United Kingdom have been willing to accept cash payments from ostensible students for student fees, despite the risk that accepting such payments could implicate those universities in possible money laundering activity. In the United Kingdom’s case, an investigation by The Times found that at least 49 British universities let students use banknotes to pay £52 million in fees.
A new report yesterday by The Times disclosed that a leading United Kingdom university, the London School of Economics (LSE), accepted £350,000 in cash from students between 2015 and 2019 despite the risks of association with money laundering. Although other United Kingdom universities accepted larger amounts of cash from students between 2015 and 2019 – notably Queen Mary University of London, which took in £7 million, and Teesside University, which took in £1.2 million – LSE had been the target of substantial criticism in 2011 when it accepted a £1.5 million donation from a son of the late Libyan dictator Muammar Qaddafi for training “future leaders” of the Libyan government.
An LSE spokesperson stated that “LSE stopped accepting cash as a form of payment for tuition from summer 2019,” and “has a robust ethics code and process for all potential grants and donations, which is kept under regular review.” Nonetheless, Members of Parliament on the Education Select Committee reportedly called “for a complete ban on higher education institutions taking cash.”
In view of these continuing revelations, there is no point in any university, whether in the United Kingdom or elsewhere, continuing to allow students to pay cash for tuition or, for that matter, any university service other than de minimis cash purchases of meals or incidentals. No college or university needs to take the risk of becoming a conduit for criminal proceeds, and it can only ease the compliance obligations of universities to refrain from accepting any amounts of cash that could be reportable under anti-money laundering regulations.