Understanding Suspicion in Financial Crime:

Second edition: 2024. First edition 2014, republished under the current title 2015.

The Essential Guide to suspicion in financial crime: Understanding Suspicion in Financial Crime

It is impossible to over-state the importance of suspicion in relation to financial crime. It is at the heart of protecting against fraud, bribery and other offences and, of course, it is an essential element of all financial crime risk and control systems for money laundering and terrorist financing systems.

First published in 2014 and now reviewed, updated and expanded "Understanding Suspicion in Financial Crime" remains the only comprehensive study of how, why and when people become, or do not become, suspicious and why they do, or do not, report those suspicions.

Highly regarded in intelligence agencies and law enforcement, the book is essential reading across the entire financial sector and in commercial enterprises.

Now including topics such as how changing attitudes amongst customers, rapid changes in the use of language and the use of "artificial intelligence" in a risk-assessment environment are affecting the question of suspicion, the book adds to its previously wide range of topics, taking lawyers, judges and legislators into the world of financial crime risk officers, law enforcement and intelligence operations in an easy-to-read, informal style that belies the seriousness of the subject and its treatment.

Every Financial Crime Risk Officer dreads being asked one, simple, question. It's the same question every time: "How do I know if I'm suspicious?"

It's a simple question without a simple answer. Until now.

In "Understanding Suspicion in Financial Crime" Nigel Morris-Cotterill, a former litigation lawyer who has been a counter-money laundering strategist for more than twenty years, analyses legal and regulatory regimes, psychology, social sciences, even metaphysics and pop culture.

He draws on a huge range of material from academic studies to regulatory and legal findings, from movies to his own ability to identity and manage far-off risks. He identifies characteristics that encourage or discourage the recognition of suspicion and the filing of SAR / STR s.

The book is non-linear, in "phases" rather than chapters, as multiple approaches are examined in parallel rather than in sequence. There are surprisingly few overlaps until the moment when a decision as to suspicion has to be made. This, Morris-Cotterill, says is at the heart of why the question is so hard to answer. Simply, there are far too many and far too diverse starting points - and law and regulation are, more often than not, not among them.

The book is a serious book covering a serious subject but it is written in a simple way. Many readers will have English as a second or third language. And many do not want and do not have the time to dredge through academic terms and management-speak. "Understanding Suspicion in Financial Crime" is a jargon-free zone. Morris-Cotterill hunts for that elusive answer, the one simple, single sentence that all staff can understand, the sentence that will give the beleaguered Financial Crime Risk Officer peace of mind, that will mean they do not stand, eyes wide open like a deer in the headlights, hoping for inspiration.

The answer to the question is as unexpected as it is simple, and easy to understand by staff at all levels.

Equally importantly, the book answers the hard questions asked by investigators, prosecutors, judges and regulators: what is suspicion, how is it formed, when it is acted upon (or not formed or not acted upon). Across the world, cases report Judges lamenting the lack of guidance on these matters, and the lack of an effective definition of suspicion.

Now, at last, there is one, drawing on cases and legislation from many jurisdictions, using non-legal sources to provide both context and explanation.

Note: This work was previously available under the following title:

How does that make you feel?
Understanding suspicion in money laundering and terrorist financing

It was relaunched under the title "Understanding Suspicion in Financial Crime" with correction of typos, etc. and no material content changes, with a publication date the same as the original so as to avoid confusion as to the effective date of the work.