EduQuantica Ltd – Anti-Money Laundering Policy

Purpose and scope

EduQuantica Ltd will not be used to launder money, finance terrorism or evade sanctions. International student recruitment is a known target for these crimes, especially through tuition deposits paid and then refunded. This policy explains how we prevent, spot and report them.

It applies to all directors, staff, contractors and sub-agents, in every country where we work.

Legal framework

• Proceeds of Crime Act 2002 – it is an offence for anyone to conceal, arrange, acquire, use or possess criminal property, and to "tip off" someone that a report has been made.
• Terrorism Act 2000 – offences relating to funding terrorism.
• UK sanctions regulations – it is an offence to deal with funds of designated persons. We screen against the UK sanctions list
• Economic Crime and Corporate Transparency Act 2023 – introduces corporate liability for economic crime, including a failure to prevent fraud offence for large organisations.
• Money Laundering Regulations 2017 – as an education agent, EduQuantica is not normally in the regulated sector. We follow their principles as good practice and because our university partners expect it.

Money laundering means turning money from crime into money that appears legitimate. It usually has three stages: placing the money into the financial system, moving it to hide its source, and bringing it back as apparently clean funds.

Our core payment rules

1. We never handle tuition money. Students and sponsors pay tuition fees and deposits directly to the university, using the details on its official website or offer letter. No one at EduQuantica, and no sub-agent, may collect, hold or pass on tuition payments.
2. No cash. Any EduQuantica service fee is paid by bank transfer or card to EduQuantica's own business account. We never accept cash.
3. Payer must match. Service fees must come from the student, a parent or guardian, or a named sponsor. Payments from unconnected third parties are refused.
4. Refunds go back to source. Any refund of our fees goes to the same account that paid, never to a different person, account or country.
5. Commission goes only to verified accounts. Sub-agent commission is paid only to the contracted business's verified bank account in its registered country.

Due diligence

Students and sponsors. We verify identity using a passport for every student, and check that any financial sponsor is named and their relationship explained. We do not verify the source of funds for visa evidence, but we never help create, alter or "arrange" financial documents.

Sub-agents and partners. We identify the business, its owners (25%+) and directors, screen them against sanctions and adverse media, and verify their bank account, under our Sub-Agent Onboarding Policy. We re-screen every year.

Enhanced checks apply when there is a higher risk, such as a link to a high-risk or sanctioned country, a politically exposed person, unusually complex ownership, or any red flag below. A director must approve before we proceed.

Red flags

Stop and report to the MLRO if you see:

• a student or sponsor asks to pay tuition through EduQuantica or a sub-agent;
• large deposits or overpayments to a university, followed by a quick withdrawal and refund request;
• a refund requested to a different account, person or country from the original payer;
• payments from unconnected third parties, multiple payers or many small amounts;
• a student with little interest in the course, university or start date;
• financial documents that look altered, or bank statements that don't match the stated income;
• a sponsor who won't explain their relationship to the student or the source of funds;
• a sub-agent who asks for commission in cash, to a personal account, or to a third country;
• a name or business that matches a sanctions list.

Reporting suspicions

1. Report internally. Any staff member or sub-agent who knows or suspects money laundering, terrorist financing or a sanctions breach reports it to the Money Laundering Reporting Officer (MLRO), as soon as possible.
2. Do not tip off. Do not tell the student, sponsor, sub-agent or anyone else that you have reported, or that an investigation may follow. Tipping off can be a criminal offence.
3. Pause. Do not continue with the payment, refund or transaction until the MLRO says you may.
4. MLRO assessment. The MLRO reviews the report, records the decision and reasons, and, where suspicion is confirmed, submits a Suspicious Activity Report (SAR) to the National Crime Agency. Where needed, the MLRO asks the NCA for a defence against money laundering (DAML) before any further action.
5. Inform partners. Where appropriate and lawful, the MLRO informs the affected university.

Records

We keep due-diligence records, payment records, internal reports decisions for at least 5 years after the business relationship ends.

Breaches

Staff who breach this policy face disciplinary action, which may include dismissal. Sub-agents face termination. Criminal conduct is reported to the authorities.