Bournemouth University

Cash handling and Anti-Money Laundering Policy V1 November 2021

Owner: Finance Operations Manager

Approved by: Finance Director
(This policy is a subset of BU Financial Regulations)
Version No: V1
Effective Date: November 2021
Date of last review: November 2021
Due for review: November 2023

Cash Handling and

Anti-Money Laundering Policy

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Section A – Cash Handling

1. INTRODUCTION

1.1 RANGE OF ACTIVITIES INVOLVING CASH

2. ACCOUNTABILITY

3. BASIC SECURITY

3.1 PRINTING/COPYING MACHINES

3.2 SAFES

4. GUIDELINES FOR TRANSPORTING CASH

4.1 INTRODUCTION

4.2 HANDLING OF INCOME

5. GUIDELINES FOR OPERATING TILLS AND CASH REGISTERS

5.1 INTRODUCTION

5.2 BASIC SECURITY LEVELS

5.3 TILL MANAGEMENT

5.4 FINANCIAL RECORDS

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Section B – Anti-Money Laundering

6.1 INTRODUCTION AND PURPOSE

6.2 DEFINITIONS AND LEGISLATIVE CONTEXT

6.3 SCOPE

6.4 RISK ASSESSMENT

6.5 RISK MITIGATION

6.6 UNUSUAL OR LARGE PAYMENTS

6.7 CASH THRESHOLDS

6.8 KNOW YOUR CUSTOMER OR SUPPLIER

6.9 PROCESSING REFUNDS

6.10 FINANCIAL SANCTIONS TARGETS

6.11 ROLES AND RESPONSABILITIES

6.12 MONEY LAUNDERING REPORTING OFFICER

6.13 ALL STAFF – REPORTING SUSPICIOUS ACTIVITY

6.14 COMMUNICATION AND TRAINING

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1. INTRODUCTION TO CASH HANDLING

In the context of this document the word “cash” means notes and coins, as well as cheques, debit and
credit card transactions. . The importance of following proper cash handling procedures cannot be
stressed too highly. Following good practices greatly reduces the risk to the University of cash going
missing and provides protection for staff should there be any apparent losses of funds.

1.1 Range of Activities involving Cash

The term “cash handling” covers various activities. Generally, it involves the collection, receipting,
reconciliation and banking of income. However, it may also encompass other areas of financial
activity such as the use of floats and operation of petty cash accounts. Other issues that may be
relevant include writing off bad debts and the prevention of money laundering. The University’s
Financial Regulations and Procedures give information on all these issues. Please note that failure to
comply with the requirements of the Financial Regulations and Financial Procedures may lead to
disciplinary action being taken against the staff concerned. In view of the range of activities across
the University, it is difficult to provide detailed policy on all aspects of cash handling. This Policy is
mainly concerned with general principles and standards of good practice that should underlie cash
handling procedures. Most are common sense measures, which the majority of people follow when
dealing with their own finances.

2. ACCOUNTABILITY
Occasionally where monies have gone missing this may have occurred because proper procedures
have not been followed, for example where cash has been left unattended and not locked away or
safe keys left in desk drawers. In such circumstances, several people have potentially had access to
the funds, but inadequate procedures and lack of accountability has often rendered it impossible to
identify who may be responsible for the loss. In these circumstances, suspicion unfairly falls upon
everyone.
One of the key principles of cash handling is that proper accountability is maintained at all times in
the cash handling process. It must be possible, at every stage of the process, to establish which staff
are responsible for accounting for monies under their control. In the event that monies are found to
be missing it should be possible to identify which member of staff was responsible for the cash at the
time it was “lost”.

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3. BASIC SECURITY
Faculty Directors of Operations (or Operation Managers) and Heads of Professional Services should
be aware of all locations within their Faculty or Professional Service where cash is received or held.
It is helpful to review these regularly and to consider if they are all in fact necessary. Errors can occur
where staff with other duties are required to handle cash on an occasional basis. It is often best if
cash handling can be focussed on one or two staff that can develop the expertise required. Faculty
Directors of Operations (or Operation Managers) and Heads of Professional Services must make clear
to staff that they are accountable for cash, card receipts and cheques under their control, and are
responsible for ensuring that monies are held securely at all times. No other staff should have access
to these monies - not even for brief periods. Cash should never be left unattended, for however short
a period of time. When cash is physically transferred between officers, the monies handed over
should be counted and checked at the time of the transfer and a discharge signature obtained from
the recipient. During this process, the monies should be checked and agreed in the presence of both
officers.

3.1 Printing and Copier Cash Load Machines

Where staff are required to empty coin and note operated printing and copier cash load machines,
some simple rules should be followed:
• The keys for the machines should be kept in a safe, key cabinet or other secure place.
• Two members of staff should open the machine and remove the income.
• If the machine has a counter or meter inside, the reading should be noted.
• The cash should be taken to a secure place for counting by both members of staff.
• A book should be kept for printing and copier cash load machine income. This should record
the date; meter reading and cash received and be signed by both members of staff.
• The income should then be taken to the Cash Office at Talbot Campus or Finance office in
Studland House.
• Machines should not be emptied at a fixed time each week, as this may allow criminals to
target the staff carrying the income.

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3.2 Safes
The level of security will depend upon individual circumstances. Where income is collected the level
of security required needs to take into account the amounts of cash involved. If substantial amounts
of monies are involved it may be necessary for monies to be transferred at intervals to a safe during
the day. In Faculty and Professional Services where there are safes, all other monies such as floats
and petty cash should be kept in the safe when not in use. It may also be helpful to keep certain
monies, such as petty cash floats, in a separate cash boxes within safes. Security is enhanced when
monies are kept in a safe and the practice of keeping cash in drawers, desks and filing cabinets etc.
should be actively discouraged. However, for this to be effective, proper control of keys to safes, cash
boxes, etc. must be exercised at all times. Wherever possible, specified individuals should be made
personally responsible for individual keys. Good practice dictates that the number of keys and
officers having access to safes and their contents should be kept to the minimum required for
operational requirements. Access to safes must always be restricted and authorised key holders must
not hand safe keys to other officers to allow temporary access to safes, for however a short a period
of time. Under no circumstances should safe keys be left in desk drawers, filing cabinets etc. Negligent
handling of cash may invalidate the University’s insurance. Should any safe or office keys be lost, the
matter must be reported to the relevant manager, who must make arrangements for locks to be
changed as soon as possible. No information relating to the premises or location of safes should be
attached to safe keys, in case they fall into the “wrong hands”. In the event of any loss being
discovered, the circumstances must be reported to the Finance Director.

4. GUIDELINES FOR TRANSPORTING CASH

4.1 Introduction
The movement of cash involves significant risks, both to the safety of staff and University funds. Cash
is defined as notes and coins, although when “cash” is transported this will often also include cheques
received in payment and possibly supporting documents such as credit/debit card copy receipts.

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4.2 Handling of Income

The takings must be kept in a secure, locked safe until transportation to the Cash Office at Talbot
Campus or the Finance office in Studland House. Cash, cheques and credit/debit copy receipts should
be kept safely and paid into the bank at the first opportunity. Avoid accumulating large sums, as this
may exceed insurance limits, attract criminals and loses bank interest. Cash/cheques and
credit/debit copy receipts should be taken to a place of security as soon as possible. Whenever
possible, at least two people should accompany significant sums of cash to reduce the risk and this
should be taken to either the Cash Office at Tabot Campus or Finance in Studland House. Cash should
be concealed when in public places. Never establish a routine of going at exactly the same time each
day/week and avoid trips with cash becoming common knowledge. You never know who is listening.
Cash must never be sent in the post or using the internal mail service.

5. GUIDELINES FOR OPERATING VIRTUAL AND PHYSICAL TILLS AND CASH REGISTERS

5.1 Introduction
Any area where significant sums of cash are received on a regular basis should consider obtaining a
cash register (till). When average daily takings exceed £100 or weekly takings are over £500, the use
of a till is strongly advised. There are many types of cash register available, with a wide range of
facilities. Ideally, all cash registers should have the ability to record the staff using them and to
identify which member of staff processed an individual transaction.

5.2 Basic Security Levels

To give a minimum level of security, a physical cash register must have:
• Two till Rolls
• Receipts: One roll produces a receipt that is given to the customer
• Audit roll: This is housed within the till and is retained for audit purposes. It must record
every transaction and show each X and Z total (see below).
The audit roll should only be removable using a key (held by the Supervisor). However, the most
recent transactions should be visible to the operator, and it should be possible to write short notes
(such as initials) on the audit roll.

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5.2(1) X and Z Totals

The cash register should also be able to produce, printed out on a receipt and recorded on the audit
roll, two running totals. An “X reading” the total rung through the till so far that day, A “Z reading”:
the final total for the day. The cash register should record both the date, and ideally the time, when
both an X and Z reading was taken. Each Z reading should also have a unique number, increasing by
one from the previous reading. After a Z reading is taken, this “zeros the till”, so a subsequent X
reading records only takings since the last Z reading. The above features have been available on tills
for many years, and are not limited to modern electronic models. Any till that does not have them
should be replaced.

5.3 Till Management

One member of staff should be appointed as Supervisor of the till(s) in their area. This person should
be of senior status to the till operators and should not usually work the tills themselves. A deputy
should be appointed to cover absences from annual leave, sickness etc. The Supervisor should, as
well as generally managing the operation of the tills, undertake such roles as taking Z readings,
cashing up and authorising refunds and “no-sales”.

5.3 (1) Linking Staff to Transactions.

Records should exist to show which member of staff used the till at a particular time and date and
ideally who undertook a particular transaction. How this is done depends on the sophistication of
the tills used. In a traditional till, the member of staff on duty at the start of business should check
that the till has been zeroed (by taking an X reading) and sign the top of the audit roll. The till will
have a key, and whenever the employee is away from the till, even for a few seconds, it must be
locked. If the employee hands over the till to a colleague, an X reading should be taken and the two
employees sign the audit roll to mark the hand over. Ideally, the till should be cashed up whenever
this happens. Alternatively, a special form can be used to record when the till was handed over.
Where several employees use one till, it should be of sufficient sophistication that the person using
the till for a particular transaction is recorded on the audit roll. This can be done in several ways
depending on its design, for example by giving staff a personalised key that the till recognises. Staff
must never pass their key to another person without permission.

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5.3 (2) Cashing Up

This must be done as soon as possible after the close of business each day, although it may be done
more often or earlier if an outlet is very busy, or this is required for any other reason. The cashing-
up process will normally involve the following: Removal by the Supervisor of the cash drawer from
the till to a secure place, ideally a dedicated cash office. Taking of a Z reading by the Supervisor, and
taking the Z receipt and the audit roll with the cash drawer. Two members of staff should then count
the takings, and reconcile them to the total received as recorded by the Z reading and audit roll.

5.4 Financial Records

The actual and recorded takings, any discrepancy (“unders/overs”), and Z reading number (i.e. the
number of Z readings taken) should be recorded in a permanent register by a person independent of
the machine operator. The Z reading number should be checked against the previous day’s reading
to ensure that there is no gap. Both members of staff who counted the takings must sign the register.
Where takings are divided between cash, cheques and debit/credit cards, the total paid using the
various types of payment method should be recorded separately. The register, Z reading receipt and
audit roll should all be stored safely. These are permanent financial records that must be retained for
at least three years.

5.4 (1) Discrepancies

Whenever discrepancies are found e.g. till shortages ("unders/overs"), or Z number discrepancies,
the member of staff should inform their line manager without delay. The line manager should inform
the Head of Faculty and the Finance Director immediately should he/she have reasonable grounds
to suspect a financial irregularity, or fraud or that the incident is not isolated in nature.

5.4 (2) Security

The takings must be kept in a secure, locked safe until transportation to the Cash Office at Talbot
Campus or Finance office in Studland House.

5.4 (3) Refunds and “No Sale”

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Each area should have a policy on refunds, but the basic rule is that a Supervisor must approve all
payments out of the till. All such payments must be recorded when made and included in the
reconciliation at close of business. A record must also be made of any occasion when “no sale” is used
to open the till.

5.4(4) Deductions
With the exception of properly authorised refunds, no cash should be removed from the till at any
stage. Similarly, at the cashing-up stage, all takings must, without any deductions, be transported to
either Cash Office at Talbot Campus or Finance office in Studland House. The only exception is the
till float, which should equal that received at the start of business. Cash must never be deducted to
replenish a petty cash float, pay casual staff wages or for any other purpose.

COUNTERFEIT BANK NOTES

There are forged bank notes in general circulation and the University can incur losses through the
acceptance of counterfeit bank notes. These tend to be mainly £10 and £20 notes but other
denominations may be found.
A number of simple checks can be carried out by staff when bank notes are tendered for payment.
Most up to date information available on the Bank of England’s website.
https:/www.bankofengland.co.uk/banknotes/counterfeit-banknotes. Staff should exercise vigilance
when accepting bank notes. In the event of a counterfeit bank note being detected when it is tendered
for payment, the strict legal position is that the note should not be passed back to the person
tendering it - the counterfeit note should be retained by the officer and the incident reported to the
police. It is a serious crime to deliberately tender a forged note. Receipts for payment should not be
issued until bank notes have been examined and confirmed as being genuine, as identification of a
counterfeit note after receipting will result in the University having to bear the loss.

MONEY LAUNDERING

6.1 Purpose
The purpose of this document is to make staff of the University aware of the strict money laundering
policy that the University follows. Bournemouth University is committed to the highest standards of
openness, transparency and accountability and to conducting its affairs in accordance with the

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requirements of the relevant funding and regulatory bodies. Bournemouth University has a zero-
tolerance approach to money laundering and the policy applies to activity both at home and abroad
and to any activity with University partners.

6.2 Definitions & Legislative Context

The Money Laundering, Terrorist Financing & Transfer of Funds Regulations 2017 (MLR 2017) came
into force on 26 June 2017. They implement the EU’s 4th Directive on Money Laundering. In doing
so, they replace the Money Laundering Regulations (MLR 2007). The UK Anti-Money Laundering
(AML) framework also incorporates the Proceeds of Crime Act 2002. MLR 2017 adopts a more risk-
based approach towards anti – money laundering and how due diligence is conducted. Money
laundering is the process of 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. There are three stages in money laundering; placement, layering and
integration. Placement is where the proceeds of criminal activity enter into the financial system;
layering distances the money from its illegal source through layers of financial transactions; finally,
integration involves the re-introduction of the illegal proceeds into legitimate commerce by
providing an apparently genuine explanation for the funds.

6.3 Scope
This policy applies to all members of staff of the University and subsidiary companies including
academic partners, undertaking business on behalf of the University and its subsidiary companies.
Money laundering is a criminal offence. In the UK, penalties include unlimited fines and/or terms of
imprisonment ranging from two to 14 years. Offences include:
• Failing to report knowledge and or suspicion of money laundering
• Failing to have adequate procedures to guard against money laundering
• Knowingly assisting money launderers
• Tipping-off suspected money launderers
• Recklessly making a false or misleading statement in the context of money laundering

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The University could also face a range of sanctions for non-compliance, imposed by HM Revenue and
Customs (HMRC). Therefore, disciplinary action under the University’ procedures may be taken
against members of staff who fail to comply with this policy.

6.4 Risk Assessment

MLR 2017 requires the university to undertake a risk assessment and assess its exposure to money
laundering. There are 4 main areas that need to be considered to assess its overall risk.
• Product / Service Risk – This is the risk associated with delivery of University activity
including teaching, research, enterprise and conferencing activity.
• Jurisdictional Risk – This is the risk associated with the Universities’ countries of operation,
location of students and customers, suppliers and agents.
• Customer/Third-Party Risk – This is the risk associated with the people and/or organisations
that we undertake business with including customers/third-parties, beneficial owners,
agents, contractors, vendors and suppliers. Politically Exposed Persons (PEP’s) and
Sanctioned Parties are also considered within this risk.
• Distribution Risks - This is the risk associated with how we undertake business, including
direct and indirect relationships (e.g. via an agent or third-party), face-to-face, digital/online
and telephonic.
Whilst much of the Bournemouth University’s financial activity could be considered relatively low
risk from the perspective of money laundering, all staff need to be vigilant against the financial crime
and fraud risks that the university faces day-to-day.

Possible signs of money laundering include:

• An individual or company makes a large unexpected payment to the University but fails to
provide evidence confirming their identity and reason for payment.
• An individual or company attempts to engage in “circular transactions” where a payment is
made to the University followed by an attempt to obtain a refund. For example, a student pays
a significant sum, then withdraws and seeks a refund.
• A person or company undertaking business with the University fails to provide proper
paperwork (examples include charging VAT but failing to quote a VAT number or invoices
purporting to come from a limited company, but lacking company registered office and
number)

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• A potential supplier submits a very low quotation or tender. In such cases, the business may
be subsidised by the proceeds of crime with the aim of seeking payment from the University
in “clean money”.
• Involvement of an unconnected third party in a contractual relationship without any logical
explanation.
This list above is not exhaustive and money laundering can take many forms. If there are any
concerns, then these should be raised with the Money laundering Reporting Officer.

6.5 Risk Mitigation

The University has a number of policies and procedures in place to minimise the risk of money
laundering – in particular the Financial Regulations and Student admission procedure, with regards
to Know your customer (KYC) requirements.

6.6 Unusual or Large payments

The University will investigate and establish what they are for. The University’s bankers also advise
on high risk countries where financial transactions are either prohibited or heavily restricted.

6.7 Cash Thresholds

MLR 2017 has reduced the limit for eligible cash transactions from €15,000 [ £13,000] to €10,000
[£8,800] and is extended to receiving, as well as making, payments in cash. In the light of this and the
security risk of carrying large amounts of cash, the University will continue not to accept cash
payments for tuition fees. Any other cash payments will be limited to £100 (for example Sports
Memberships).

6.8 Know Your Customer /Supplier

Anti- Money Laundering Regulations requires that the university must be reasonably satisfied as to
the identity of the customer (and others) that they are engaging with in a contractual relationship.
To discharge the “reasonably satisfied” the University must obtain a minimum level of personal
information from a customer including date of birth and home address. For applicants/students KYC
requirements is already completed as being part of the admissions process. For third parties’ letters
or documents proving name, address and relationship should be obtained. If an organisation is not
known to the University then Letter Headed documents, website and credit checks should be

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undertaken as appropriate. This is usually covered in either the CAF process or onboarding a new
supplier via the ‘new supplier’ process. The University must be clear on the purpose and the intended
nature of the business relationship i.e. knowing what you are doing with them and why. In most cases
the University’s exposure to money laundering is likely to be low. Financial due diligence is already
considered as part of bidding for research, consultancy and collaborative provision. However, in
certain instances if the University is considering establishing a business relationship in a high-risk
country or with a politically exposed person, then appropriate advice should be taken from the
Money Laundering Reporting officer (MLRO) pre entering the arrangement.
6.9 Processing Refunds:
The University will undertake appropriate checks before processing any refunds and funds can only
be refunded back to the original payer and cannot be refunded to a third party. Where the original
payment has been received from abroad the refund will be to the foreign bank account and not to a
UK bank account. Normally refunds would be processed by the same payment method in which the
original payment was received – for example, when a customer paid by Debit/Credit card, the refund
would also be via the same debit/credit card. For Flywire, likewise, if an overseas payment has been
received via Flywire, if refund is appropriate, we will refund via Flywire. Overseas students paying
tuition or accommodation fees must be discouraged from making international bank transfers to BU,
they should use Flywire.

6.10 Financial Sanctions Targets

The UK government publishes frequently updated guidance on financial sanctions targets, which
includes a list of all targets. This guidance can be found at:
https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets. If
the University is planning to undertake any research or consultancy activities with countries, entities
and/or individuals on the financial sanctions consolidated list then please consult with either the
MLRO or his/her deputy so that the University can review the register and ensure that the proposed
activity is not with a embargoed country, individual or organisation.

6.11 Roles and Responsibilities

The Finance Director has responsibility for the Cash Handling and Anti- Money Laundering Policy,
which is a subset of the BU Financial Regulations. The BU Financial Regulations are reviewed and
approved annually but the Board.

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6.12 Money Laundering Reporting officer (MLRO)

The MLRO is the primary contact for any further information or to report any suspicious activity. The
MLRO is:
Andrew Wright Financial Operations Manager awright@bournemouth.ac.uk
And the second contact is:
Kevin Welford Financial Accounting and Compliance Manager kwelford@bournemouth.ac.uk

The MLRO is responsible for:

• receiving reports of suspicious activity from any employee in the business;
• considering all reports and evaluating whether there is – or seems to be, any evidence of
money laundering or terrorist financing;
• reporting any suspicious activity or transaction to the Serious Organised Crime Agency
(SOCA) by completing and submitting a Suspicious Activity Report;
• asking SOCA for consent to continue with any transactions that must be reported and making
sure that no transactions are continued illegally.
• Escalating suspicious activity to the Finance Director where necessary for any further action
required e.g. under BU Fraud Policy

6.13 All staff members of the University – Reporting Suspicious Activity

A member of staff the University who needs to report suspicious activity must complete the
Suspicious Activity Report (SAR) which is detailed in Annex A. They should provide as much detail
as possible and the report must be made in the strictest confidence, being careful to avoid “tipping
off” those who may be involved. Money laundering legislation applies to all staff members of the
University. Staff members of the University could be committing an offence if they suspect money
laundering (or if they become involved in some way) and do nothing about it. Potential Red flags are
highlighted in Section 3. The MLRO will report any findings to the Finance Director who will carry
out any investigation.

6.14 Communication and Training

Finance and Performance will ensure that members of staff with financial responsibility receive
appropriate money laundering communication and training on an annual basis. Refresher
communication will take place at each revision of the policy.

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6.15 Review, Approval and Publication

The Cash Handling and Anti- Money Laundering Policy is subject to review every 2 years by the
Finance Director or following a change to relevant UK legislation. Updates to the Cash Handling and
Anti- Money Laundering Policy will be cross referenced in the annual review of the BU Financial
Regulations by the Board.

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Annex A:
Suspicious Activity Report

CONFIDENTIAL – Suspicious Activity Report Please complete and send this to the MLRO using the
details below:-
From: …………………………………………………..
Faculty/Professional Service: …………………………………………………..
Contact Details: …………………………………………………..

DETAILS OF SUSPICIOUS ACTIVITY [Please continue on a separate sheet if necessary] Name(s) and
address(es) of person(s) involved, including relationship with the University:
…………………………………………………..
Nature, value and timing of activity involved:
…………………………………………………..
Nature of suspicions regarding such activity:
…………………………………………………..
Details of any enquiries you may have undertaken to date:
…………………………………………………..
Have you discussed you suspicions with anyone? And if so, on what basis?
…………………………………………………..
Is any aspect of the transaction(s) outstanding and requiring consent to progress?
…………………………………………………..
Any other relevant information that may be useful?
…………………………………………………..

Signed: …………………………………………………..
Date: …………………………………………………..

Please do not discuss the content of this report with anyone you believe to be involved in the
suspected money laundering activity described.

MLRO Report (to be completed by MLRO)

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Date Report Received …………………………………………………..

Date Report acknowledged: …………………………………………………..
Consideration of Disclosure: …………………………………………………..
Outcome of consideration of Disclosure:
…………………………………………………..
Are there reasonable grounds for suspecting money laundering activity? YES / NO
Does the matter need to be reported to the National Crime Agency? YES / NO
If YES record the date reported to NCA……………………………………………..
If consent required from the NCA to proceed with a potentially suspicious transaction? YES / NO
If YES please confirm full details below:
…………………………………………………..
If Suspicious Activity Report is not reportable to National Crime Agency, set out below the reasons
for non-disclosure. …………………………………………………..
Signed: …………………………………………………..
Date …………………………………………………..
6. FURTHER INFORMATION

Please refer to the latest ‘University’s Financial Regulations’ for further information or contact one
of the following members of staff as below.

Senior Cashier: Hayley Bell

Email hbell@bournemouth.ac.uk
Finance Operations Manager Andrew Wright
Email awright@bournemouth.ac.uk

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