International student recruitment remains a vital income stream for UK universities, particularly as financial pressures intensify and global competition increases. International agents play a significant role in helping institutions access overseas markets and broaden participation.

While agent-led recruitment is well established, the scale and complexity of current arrangements mean that weaknesses in governance and system controls can present material risks. Where oversight is insufficient, universities may face financial loss, reputational damage and regulatory scrutiny, particularly in relation to UK Visas and Immigration (‘UKVI’) compliance.

Recent investigations undertaken by our forensic team demonstrate how vulnerabilities within student information systems and commission processes can be exploited where controls are not operating as intended.

How international agent fraud and commission manipulation occurs

In one case, international students were incorrectly tagged within the university's student records system as having been introduced by an international agent, when no such introduction had taken place.

The tagging was performed by a university employee who had covertly established themselves as a sub-agent of an existing, approved international agent. By manipulating student records, the employee enabled commission payments to be generated and subsequently diverted via the agent to a personal bank account under their control.

The total value of payments in issue exceeded £100,000.

Case study: fraud in agent commission payments

Working to strict timescales, our forensic team conducted a focused but comprehensive review to establish the facts and quantify the university's exposure. This included:

• Process mapping of the end-to-end international student application journey and agent commission process to identify control gaps.
• Review of IT system access and controls within the student records system to identify unexpected users and unauthorised amendments to student records.
• Targeted data analytics across the employee's university email and chat accounts to identify potential collusion.
• Interviews with key stakeholders, including the employee under suspicion, international agents, and IT and finance teams in the UK and overseas.
• Assessment of findings against the university's internal control framework, including anti-fraud, anti-bribery, code of conduct and disciplinary policies.

This approach enabled our team to develop a clear chronology of events supported by contemporaneous evidence.

The outcome: evidence suggesting deliberate wrongdoing

Our investigation identified evidence to suggest deliberate wrongdoing involving both the employee and a student at the university. The issues identified included:

• Unauthorised manipulation of student records within university systems.
• Operation of an undeclared sub-agent relationship in breach of university policy.
• Diversion of agent commission payments to a personal bank account.

We delivered a factual report setting out the sequence of events and supporting evidence, enabling the university to take action against those involved and implement measures to prevent further financial exposure.

What can universities learn from this?

Based on our experience supporting higher education institutions, universities should consider whether the following controls are operating effectively:

• Access controls governing who can tag students as having been introduced by an international agent.
• Transparency over sub-agents, including approval, monitoring and ongoing oversight.
• Ongoing due diligence on agents and sub-agents, including identification of links to university staff or students.
• Segregation of duties between recruitment, system administration and commission approval.
• Audit trails and exception reporting for changes to student records and agent tagging.
• Training and awareness aligned to codes of conduct and anti-fraud policies.

Regular review of these areas can help identify issues early and act as a deterrent to misconduct.

How we can help universities with agent risk and compliance

If your institution relies on international agents and is not receiving regular assurance over the areas outlined above, or if concerns have already been identified, we can support you through:

• Proactive fraud risk reviews and walkthroughs of international agent commission and student tagging processes.
• Integrity due diligence reviews of agents and sub-agents to identify conflicts of interest or other red flags.
• Reactive forensic investigations where fraud or misconduct is suspected, delivering clear, defensible findings to support management action.

For more information please contact, Lisa Randall, Nick Gilbey or your usual RSM contact.

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