Study Across the Pond Settlement: Recruiting Contracts, Bonus Formulas and Federal Student Loans

In the Study Across the Pond settlement, the recruiting company and its co-founder agreed to pay $1.3 million to resolve allegations that prohibited recruiting compensation caused false claims for federal student loans. The company admitted paying recruiters for applications and enrollments, billing schools separately for recruitment, and proposing flat fees based on expected or past commissions. If you know how a recruiting contract or bonus was calculated, those are familiar places to look beneath the label.

Study Across the Pond was a Massachusetts business recruiting Americans for undergraduate and graduate programs at United Kingdom universities. Some of those students borrowed through the federal Direct Loan Program to pay tuition. The Justice Department announced the settlement on February 24, 2026, following a qui tam case brought by a whistleblower entity whose principal had worked as a client school’s lead North American recruiter.

This page follows the company’s recruiting contracts and employee pay into the schools’ federal student-loan claims. Our page on financial aid fraud evidence follows the wider connections among school offices, institutional promises and public payments.

The Tuition Share Behind the Recruiting Service

Study Across the Pond admitted that its partner-school contracts paid it a percentage of the tuition paid by an American student it recruited. Often, the percentage increased when the company recruited more students than a contractual threshold. More enrollments could therefore change both the tuition generating the commission and the share the company received.

The company generally received no tuition share when an American attended a school outside its partner network. It also admitted generally not disclosing its tuition share to American students. The financial difference between a partner school and another university sat inside the recruiting business, while the student was choosing where to study.

The universities retained admissions decisions. Study Across the Pond supplied the recruitment, and the co-founder admitted managing and knowing the company’s operations. For someone working in international admissions, that division identifies the records worth connecting: the university’s decision to admit a student, the recruiter’s claim to a commission and the tuition used to calculate it.

Recruitment Had Its Own Invoice

The company admitted that, from at least 2014, it invoiced certain partner schools separately for recruiting services and received payment for them. It priced recruitment using a different measure from its other services. Those other charges included flat fees for website and promotional listings, digital marketing campaigns, and attendance at recruitment events, along with travel reimbursements.

That distinction gives an insider something more useful than a contract’s service heading. We compare the calculation behind the recruiting invoice with the calculation behind the marketing or event bill. In Study Across the Pond’s admitted arrangements, the company sold several services while keeping a separate price for the recruitment itself.

When the Commission Became a Flat Fee

Study Across the Pond sometimes answered partner schools’ questions by proposing an annual flat fee based on expected or past recruiting commissions. The company and its co-founder admitted that schools raised those questions at various times between 2013 and 2024. They also admitted advising the schools that the compensation arrangements were permissible.

The proposed annual fee was equivalent to the commission based on the number of students the company expected to recruit or had recruited in the past. The amount could be presented as a flat fee while its calculation still came from student recruitment.

For an employee who worked on those proposals, the expected enrollment count, previous commission and school correspondence belong in the same conversation. We see the same commission beneath the company’s proposed annual fee. The label did the changing.

Application Bonuses and Conversion Bonuses

Study Across the Pond admitted paying its recruiters an annual salary and two kinds of bonus. The application bonus depended on applications the recruiters caused American students to submit to partner schools. The conversion bonus depended on how many applicants went on to attend those schools.

Those formulas connected employee compensation to different stages of the same recruitment effort. One rewarded getting the application submitted. The other rewarded turning an applicant into an enrolled student. The company admitted using these bonuses from at least 2013, alongside the partner-school contracts that paid the business a tuition share.

For a recruiter or payroll employee, the formula and the event that triggered payment are the useful detail. An application count and an enrollment count can show why a bonus appeared on a pay statement. For someone reviewing the school contract, that employee-pay information answers a question the university’s invoice alone cannot answer.

The business had compensation moving in both directions: schools paid the vendor, and the vendor paid its recruiters. The Education Department’s bundled-services guidance addressed both. That is why the agreement’s admissions about separate recruiting invoices and employee bonuses belong together.

How Did the Recruiting Contracts Reach Federal Student Loans?

The recruiting contracts reached federal student loans through the participating universities’ promises and claims to the Education Department. The Direct Loan Program lets eligible students and their parents borrow directly from the department. A foreign university’s Program Participation Agreement carries the commitments required for the school to participate.

One of those commitments is the incentive-compensation ban. The school promises not to pay commissions, bonuses or other incentives based directly or indirectly on success in securing enrollments or financial aid to people or businesses performing covered recruiting, admissions or aid-award work. The settlement agreement identifies that promise as a condition of the foreign school’s initial and continuing participation.

The Justice Department alleged that Study Across the Pond and its co-founder caused partner schools to make false statements and submit false Direct Loan claims. That puts the vendor’s contracts beside the institution’s federal commitments and its student-aid payment records. The person who knows the recruitment arrangement and the person who handles aid can hold different parts of the same payment story.

How Did the Bundled-Services Guidance Apply to These Contracts?

The settlement agreement describes two conditions in the Education Department’s 2011 bundled-services guidance that bear directly on Study Across the Pond’s arrangements. The school could not pay the unaffiliated provider separately for student recruitment, and the provider could not make prohibited incentive payments to its own employees.

The distinction is concrete in this case. The company admitted both separately priced recruitment and application and conversion bonuses. We examine what the school bought, how each service was billed and how individual recruiters earned their pay, because the bundle’s name answers none of those questions.

The Audit File and the School’s Promise

The Justice Department’s complaint in partial intervention connected the contracts to the independent audits used to review foreign schools’ compliance. The complaint alleged:

That allegation gives the school correspondence another purpose. It can connect what people knew about a recruiting arrangement with what they supplied to the auditor or federal agency. The complaint described foreign schools reporting compliance-audit results to the Education Department, so information withheld from the audit could also affect the account reaching the public payer.

The company and its co-founder admitted familiarity with the ban and the guidance by at least 2013. Their settlement admissions also covered the school questions, their assurances, the separate invoices and the bonus arrangements. The Justice Department alleged that the conduct covered by the settlement, from January 1, 2015 through April 26, 2024, caused false student-aid claims.

The agreement also records a concrete change in 2024: the company closed its United States offices, laid off its U.S.-based employees and recruiters, and stopped seeking tuition shares for recruited Americans who paid tuition using Direct Loans. That gives an insider a specific connection to examine between the recruited student, the tuition payment and the vendor’s commission.

The Settlement Obligation and Whistleblower Share

The agreement makes Study Across the Pond and its co-founder each responsible for the full settlement amount. It separately provides $184,250 for the whistleblower’s attorneys’ fees.

The agreement provides a whistleblower share of 19% of the government’s recovery. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

What a Recruiting or School Insider Can Show

An insider can connect the recruiting contract, the calculation used to bill the school and the formula used to pay the employee. In this case, those records addressed tuition percentages, recruitment thresholds, separate service charges and application or enrollment bonuses. The school questions and management’s response added what the people responsible knew about those arrangements.

We work from the part of that business you know. A recruiter may understand the bonus trigger, a finance employee may know why the invoice changed, and a school employee may know what was disclosed during a compliance review. Putting those accounts beside the participation agreement and affected federal-aid claims connects the commercial arrangement to taxpayers’ money.

Someone outside the vendor’s own workforce can matter too. Your view of the contract, the school correspondence or the payment calculation can connect the recruiting business to the school’s federal claims. We assess how that knowledge fits the government’s claim with you.

You Know How the Recruiting Pay Was Calculated

If you worked with a tuition-share contract, a conversion bonus or a fee rewritten after a school’s questions, tell our whistleblower experts what drove the payment. We build the case with you around the recruiting business you understand and bring in education fraud whistleblower lawyers who know federal student-aid cases. You gain partners who can follow the contract into the public-money claim and stay with you through the case.