In 2020, out of 303m GBP5 notes in circulation, 15 million were replaced due to damage. In the following year, the total in circulation was 296m and of those 44m were replaced.

It is, in some countries, a criminal offence to bounce a cheque. In others, it can lead to a refusal to allow a person to leave the country until the cheque has been, demonstrably, satisfied. It can be evidence of insolvency and, of course, potentially a source of social disgrace.

Two recent cases in English Criminal Courts demonstrate the difficulty that judges face when sentencing. Neither is a financial crime case but both turn on those most difficult of factors, intent and motive.

Hawalla and similar systems might not be as old as the hills but they are close. Yet there are frequent breathless articles, social media posts and even academic papers by people who have just found out about it and think they are the first to discover it and its use in crime. There has been material on the subject for decades. Why does it not stick in the collective, systemic, memory?

“We are not suggesting that Mr. Zhao is Sam Bankman-Fried and he is a monster, and we are not trying to kill the cryptocurrency industry,” said prosecutor Kevin Mosely, deputy chief of the U.S. Justice Department’s Bank Integrity Unit, reports say.

But, even so, does the sentence undermine efforts to counter-money laundering?

In "Understanding Suspicion in Financial Crime" there is much made of the lack of judicial determination of what constitutes "suspicion" and whether there are degrees of suspicion. I examine authorities from around the world and come to a conclusion. That conclusion has just been supported by a comment by a Judge in a libel case in an English court.

The case of CCP GRADUATE SCHOOL LIMITED v NATIONAL WESTMINSTER BANK PLC and SANTANDER UK PLC will make its way around financial crime risk and compliance circles all over the world because it's about Authorised Push Payment fraud. But, horses should be held because the decision handed down on 26th March and since published is not what many will assume from the headlines that are likely to say "APP fraud case dismissed." Was it? Yes. But not on the facts.

Everyone should by now know that I have had a long-held dislike for Microsoft, its practices and its products. But for once, colour me impressed by the potential for the company's latest WORM drive.

Australia passed its near incomprehensible second edition of its counter-money laundering laws, called "The Anti-Money Laundering and Counter-Terrorism Financing Act" in 2006. In that Act it divides regulated businesses into two classes for implementation purposes. Now, 18 years later, "Tranche 2" has still not bee brought into effect. It's time to abandon it.


I am delighted and a little bit proud to announce the publication of the second edition of "Understanding Suspicion in Financial Crime".

UK Gov continues to ride roughshod over the Courts. In this case in its response to the disgraceful Post Office abuse of process that it has failed to do anything about until there's a perceived PR advantage. There is a way to deal with it. Legislation is not required. But politicians want their names in the papers so they will, again, create Statute when the Common Law already has an ideal solution.

It was early in the evening on a Sunday but the support desk replied to Telegram messages instantly.

"Real businesses don't do that," I said to the woman sitting across from me at a dinner party in Jakarta. "You've lost your money."

There is a lot of fuss and even political capital being made over the successful prosecution and the sentencing of mobile telco LycaMobile and its former CEO.

Hold your horses: it's not the big deal that the uninitiated are claiming.

This article explains the background to the Uncommon Sense programme "Financial Crime Risk and Compliance - Generative AI - Epic Fails" on FinCrimeTV.

This article is about a trend in marketing RegTech products to compliance officers who are not, and cannot be expected to be, familiar with what lies behind techy / marketing terms.

The UK's Economic Crime and Corporate Transparency Bill is having a torrid time. Intended to introduce, for example, the offence of failing to prevent fraud, it arrived in the House of Lords and got mauled. When it was remitted to the House of Commons for what is usually a rubber-stamping of the Amendments, the Commons rejected almost all of them. Some of that was the right thing to do and some of it wasn't, but not for the reasons given.

We took a summer break from The Financial Crime Forum and we've used our time very productively. Read on to learn more.

I have a spam-scam. I'm not the only one: the scammer's latest batch has been reported across the 'net. But I might be the only one who bothered to find out where the spammer found the name he's using.

I've had several questions about the piece and surprisingly little criticism. Indeed, I have received many compliments. But some people asked some questions and so I'm happy to answer them here.

The original article is here:…

Yes, the headline is designed to shock. It could equally have mentioned Stalin, Mao, Pol Pot or any dictator or ultra-authoritarian figure from any side of politics or religion - or those who take the teachings of religious figures to extremes. Under the guise of protecting something, they all imposed flawed demands and policies to the detriment of those they claimed to be protecting, just as we are seeing in the unilateral imposition of a single - but wrong - approach to access to financial services as banks and others force users to use mobile apps under the fictitious premise that it...

Online crime works because a) people don't think "fraud first" and / or b) companies hold data that puts companies at risk.

There are many sayings that have stood the test of time with generations using them without change.

I'm changing some of them because the world is a different place, today.

Yesterday, in the US, an image, which some say was generated by "artificial Intelligence" or by a person using image manipulation software, began to circulate on social media. As it spread, rapidly, it took on a life of its own. We've been here before and it's not an IT problem. as many are claiming. It's a people problem.

I had an interesting discussion yesterday with a table filled with lawyers, academics and others about the conduct of litigation.

One particular aspect stood out: let's talk about ethics in the trial itself.

Financial services businesses are subject to an overwhelming amount of regulation which militates against the purpose of financial crime laws: that of catching criminals and confiscating the proceeds they have generated.