This article is the second in a series of three articles about academic fraud. The first, "Diploma Mills and Counterfeit Operations, Part 1" by Allen Ezell College and University v94 n3 Sum 2019 described the history and growth of diploma mills and counterfeit operations. This article provides an in-depth look at the operations of the world's largest diploma mill, Axact, Ltd., a criminal enterprise with more than 8 million customers worldwide that has generated several billion dollars. The third article will detail how to identify diploma mills and Axact websites. [For "Diploma Mills and Counterfeit Operations, Part 1," see EJ1225180.]