Risk Management

There is a world of difference between training and education.

Right from the beginning of counter-money laundering requirements being placed on banks in relation to drugs trafficking, regulators placed an emphasis on both training and awareness.

There is a different approach: risk strategies arise not from individual circumstances but from an overview of a wide range of topics from economies through politics, from geo-political issues to organised crime masquerading as terrorism.

While the vast majority of training concentrates on a narrow aspect of money laundering compliance, our approach, particularly in-house, has always been "risk first."

Adopting a risk-first approach is at the heart of awareness - and of keeping your staff alert to how the company - and your staff - may be targeted by money launderers.

But training is the end result of what we do.

We will examine your business and the environment in which it operates. We will identify risk areas and propose ways of addressing that risk.


In 2001, before the USA PATRIOT Act was in force, Nigel Morris-Cotterill explained in a seminar how ss311 and 312 would affect foreign banks doing business in New York. He understood this because the principles had been discussed in a book published in the 1970s and by a representative of the New York District Attorney's Office in 1999. However, representatives of large law firms and accountancy/consulting combines told the audience that Morris-Cotterill was wrong. UK banks alone have paid fines of hundreds of millions of dollars because they discounted Morris-Cotterill's explanation.

CITES has recently become interested in the financial crime aspect of its work: Morris-Cotterill tried to engage them on this very topic in 2006. They were not interested.

These are just two examples of how Morris-Cotterill's forward thinking can help your company to plan its risk and compliance policies and procedures far into the future which reduces cost and disruption and, of course, both staff resistance to change and the likelihood of change fatigue.

Next Step

Complete the Enquiry Form to find out how Nigel Morris-Cotterill can help you improve risk awareness and reduce compliance complexity and cost.