Three people were arrested last week in raids at properties across the North West as part of an investigation into £1 million of financial irregularities at the University of Greater Manchester, formerly the University of Bolton. The individuals remain under suspicion of offences of money laundering and bribery.
These arrests follow other high-profile stories in the media relating to allegations of financial misconduct and impropriety in a number of higher and further education establishments in the UK over recent times.
A person commits fraud if they –
(a) Dishonestly make an untrue or misleading representation, which they know is false AND
(b) Intend -
(i) To make a gain for themselves or another, or
(ii) To cause a loss to another
The UK higher education sector is susceptible to various types of fraud. Some common forms of fraud in higher education include:
Academic Fraud: this includes misrepresentation of educational qualifications, such as lying on CV’s or submitting fake qualifications. It is a common form of fraud that can lead to serious consequences for individuals and institutions.
Procurement Fraud: This involves the misuse of public funds for personal gain, such as obtaining contracts for services without proper approval or payment.
Financial Fraud: This includes financial mismanagement, such as embezzlement, money laundering and the use of false invoices or inflated time records.
Fraud Indicators
Risk factors can often provide an indication that a fraud is taking place, or could take place, and can be used to help detect fraud. For organisations, signs to look out for include:
Internal controls – where there is a lack of transparent processes or governance. Time pressures should not override internal processes.
Transactional indicators – Transactions that are not transparent or have inadequate audit trials or only require one person to approve. Payments may relate to connected parties, sub-contracting or consultancy agreements.
Methods to conceal fraud – these may include unusual working hours and patterns, refusing to take leave or share work, working in isolation or a reluctance to explain processes.
Administrative indicators – may include irregular or suspicious documents or unusual accounting and banking practices.
Preventative measures
Education providers need to consider implementing preventative measures and have robust policies in place to combat these frauds in order to create a counter fraud culture where challenging and reporting suspected fraud is encouraged. Some of the actions providers can take to prevent fraud are to:
Give specific fraud awareness responsibilities to named job roles. Fraud can occur because nobody in an organisation has been tasked with responsibility for leading on fraud awareness and prevention.
Have clear policies including robust internal systems to counter frau, including how specific fraud risks are identified, assessed and managed.
Ensure staff have good awareness of fraud, including training on new and emerging types of fraud.
Ensure sub-contractors also manage fraud risk and are not a fraud threat themselves. It is important that organisations have robust due diligence procedures and carefully consider how sub-contractors manage their own fraud risks. This should be done, ideally prior to contracting and as part of ongoing monitoring and review of their sub-contractors.
Educate students and learners on fraud threats. Providers will be aware of the responsibilities they have to their students and learners. Methods used by fraudsters to target students include:
I. Offers of cheap accommodation, work, loans and credit cards.
II. Using students as money mules
III. Social media and students using WiFi in publicly accessible areas.
Organisational Liability
The Economic Crime and Corporate Transparency Act (“ECCTA”) became law in 2025 and heralded a fundamental change in approach to combatting fraud and financial crime in the UK. ECCTA made it much easier to hold organisations criminally liable for the dishonest acts and omission of its senior managers. The Act also made it a criminal offence for any large organisation that does not have in place reasonable anti-fraud procedures in place and which benefits directly or indirectly from fraud committed by an associated person.
How we can help
Weightmans national financial crime team work closely with clients across all sectors and provide advice and support to increase awareness and reduce exposure to criminal and regulatory liability. Some of the services we offer include:
Preparation and review of fraud prevention policies.
Fraud specific risk assessments.
Bespoke anti-fraud and ECCTA training.
Assistance with privileged and internal investigations.
Support during criminal and regulatory investigations and prosecution.
For guidance on dealing with fraud in Higher Education, please get in touch with our expert Education lawyers.
