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West African Elites’ Spending on UK Schools and Universities: A Closer Look

04 February 2021

ISBA has published a working paper by Matthew Page, of the Carnegie Foundation,  entitled 'West African Elites' Spending on UK Schools and Universities: A Closer Look', sent to ISBA and the ISC by the Foreign, Commonwealth and Development Office.

The association has raised awareness of money laundering in the past and since 2018 has worked with the Home Office in this critical area.  This paper is a detailed extension of this ongoing work and draws our sector's attention to this issue. Political, business, and cultural elites from around the world have a strong affinity for the United Kingdom education system. Nowhere is this truer than in West Africa, where some families in Nigeria and Ghana have a long tradition of sending their children to independent schools in the UK.

The paper is a timely reminder that independent schools may be destinations for the children of politically exposed persons (PEPs) from the region and globally. In the past, immigration officials, admissions staff, and UK law enforcement agencies were perhaps less likely to scrutinise the financial circumstances or political status of the families concerned.  In a changed world, we need to ensure that the appropriate background and anti-money laundering checks are followed without fail to ensure compliance with current legislation, particularly relating to unexplained wealth.

To assist schools in complying with the law, there is an Anti-Money Laundering advice note and model policy here.   The most basic background checks on international pupils should reveal whether a UK school place was affordable for their families and thus whether their children should be enrolled. This, in itself, would effectively counter many potential money laundering activities. And remember, the anti-money laundering legislation applies equally to children of parents in the UK, not just international pupils.

Work will continue on this issue and updates to the AML policy and advice note will be issued regularly. The West African paper is available here.