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Anti-Money Laundering (AML)

Administrative Policy Number: IC-600

The Anti-Money Laundering policy aims to enhance the University's compliance with anti-money laundering laws and regulations, assist law enforcement in combating illegal money laundering, and minimize the risk of misusing the University resources.

Money Laundering is taking profits from crime and corruption and transforming them into legitimate assets. It takes criminally derived 'dirty funds' and converts them into other assets so they can be reintroduced into legitimate commerce. This process conceals the true origin or ownership of the funds and so 'cleans' them. As the university receives significant amounts of funds from all over the world for tuition, accommodation, and other services, as well as making thousands of payments globally, it is exposed to the risk of being unwittingly used to launder funds. 

The university's policy aims to comply fully with all United States legislation concerning anti-money laundering and to ensure it minimizes the risk of money laundering in its operations. It does this in several ways:

• This policy provides a helpful list of "warning signs" for anyone who suspects money laundering is occurring.
• The university has introduced several key controls to reduce the risk of money laundering affecting the university, including a robust "know your customer policy."
• The university has a clear reporting structure for anyone who suspects money laundering is taking place.
• The university has a regular review process to update the policy and check that we understand existing risks and can recognize new ones.

To avoid doubt, the university will not do business with anyone it suspects of taking part in any activity, knowingly or unknowingly, that it regards as linked to potential money laundering.

Money Laundering Activities include:

• Acquiring, using or possessing criminal property;
• Handling the proceeds of crimes such as theft, fraud, and tax evasion;
• Knowingly being involved in any way with criminal or terrorist property;
• Entering into arrangements to facilitate laundering criminal or terrorist property;
• Investing the proceeds of crimes in other financial products;
• Investing the proceeds of crimes through the acquisition of property/assets and 
• Transferring criminal property

Compliance Framework

The university has developed processes and controls to ensure compliance with AML regulations in its daily operations. It also manages compliance and monitors the university's efforts in areas identified as affected activities.

1. Procurement to Pay (P2P)
   • Vendor Compliance refers to OFAC's Specially Designated Nationals and Blocked Persons list.
   • Vendor IRS ITIN match

2. International Travel
   • International travel and security management – restrictions based on destination
   • On-campus foreign Visitors Visa Assistance 

3. Treasury and Bank Management
   • Wire Transfers
     • Funds settle in the domestic US clearing through the Federal Reserve System
     • Funds settle cross-border using the Swift Network 

4. Student Accounts and Cashiers
   • Touchnet Services are NACHA and PCI-compliant for all electronic distributions, including all student refunds.
   • FlyWire services are PCI and SOC II compliant.
   • Cash Receipts => $10K are reported as required. 

5. Human Resources
   • I-9 Verification 

6. Foundations
   • Cash Management and Investment Policies and Processes
   • Donor validation 

7. Office of Sponsored Programs
   • Export Control Compliance Program
   • Sponsored projects/technology transfer (for research conducted by faculty and students on campus as well as research projects conducted abroad) 

8. Record Keeping in accordance with Commonwealth retention policies
   • Daily records of all transactions processed in ERP