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