A major spat has been orchestrated by campaigners for an independent Scotland. Aside from issues of national identity that may one day have to be resolved, the battleground chosen is gender identity, a subject that impinges directly on financial institutions, etc. and their ability to undertake effective Know Your Customer.


In the past year, authorities in Malaysia have rescued more than 200 victims lured by job scams where offers of lucrative work overseas led to various forms of victimisation, abuse and - even - slavery. That's just one country. In fact, there's an epidemic. But it's not new.


There's a lot of fuss about withdrawals from Binance. So let's clear something up.


I do weird research and one of the things I am looking into, to better understand one aspect of the challenges facing so-called AI and why both financial crime risk assessments and compliance fail, is the way in which popular culture in the form of American TV series has driven, over a period of some 60+ years, significant changes in the use (they would, today, often say "usage") of language. Last night, I was looking at the early episodes of "Scandal."


There are many comments in many places from many people about China's decision to reduce the demands placed on its people as a result of the Zero-Covid policy.


One evening in the 1990s, sitting by the fire in my cottage in Essex, England, I watched a documentary about the abuse visited on children by sex tourists to The Philippines and the work done by Fr. Shay Cullen in Manila. Today that trade still exists, the opportunities for child abuse being enhanced by communications and payments technology.


After 20 years living in the wonderful city of Kuala Lumpur, and wandering around the countryside, I have some recommendations for eating out in Malaysia.


It's rare for the European Court to have a hissy fit but in this case it has, albeit in gentlemanly, almost courtly, language.

It's even more rare for its target to be EU institutions. In a judgment that might best be described as "get your stuff together before you make law," the Court displays rare ire at poorly drawn law, law that is passed without thinking through the consequences and, particularly strongly, law that assumes that PR statements in the preamble will be read into the operational parts.

And yet, despite what many commentators are saying, the Court did not...


There are several "about" pages. This one is a bit different.


I've been described as "the philosopher of Financial Crime."

So that's nice.


How change happens and how we can learn from it to create an effective, low friction, compliance culture.


This project is making slow progress! The first in the series was in 2016 and I seem to have neglected it since 2017. Well, five years on, it's back...


While global media attention was paid to the removal of Pakistan from the FATF's Grey List, there is scant attention paid to the removal of Nicaragua.

Similarly, there is little attention paid to the FATF's decision with regard to Myanmar. That's a mistake.


Cryptowallet provider Ledger said that some of its users had trouble "withdrawing" their assets. At least that's what some correspondents have called it.

But this isn't like when a hedge fund says "we're freezing withdrawal" or when there's a run on a bank (or a crypto exchange). It's more akin to a DDOS attack, albeit in all innocence.


With the death of Queen Elizabeth II, questions arise as to The Commonwealth.


We need to stop using the term "enablers." It's stupid.


The term "plunder" is reminiscent of pirates or raiders: history is littered with stories of rape, pillage and plunder, usually in a military or quasi-military action. But there's more...

Here's how it relates to politically exposed persons.


Kong v Gulf International Bank - internal audit compared with whistleblowing.


Some years ago, the British Passport Office was in a mess. It took months to renew passports. It promised me compensation for delay. No surprise, the compensation never arrived. I was prepared: I had two passports.

Now I need to renew my second passport. The Passport Office, notwithstanding the fact that I have had two passports for many years, is being difficult. But what's even more ridiculous is that its own failures perfectly demonstrate why I need two passports.


I am very good at compartmentalising.


I often read that law enforcement is outgunned when it comes to money laundering, etc. I'm not sure that is completely true.

I think the problem is that there is a fundamentally misplaced focus of efforts.


Financial crime risk and compliance officers are necessarily managers of change. But they have suddenly become subject to the whims of management consultants in how they go about doing their job.

That might be fine if the management consultants didn't change their approach with the wind.


This post started as a comment in someone else's thread in social media and then grew into a post of my own and then, because space limitations undermined how the piece could be presented, I decided to produce a far more comprehensive version as a Blog . So here it is, edited and expanded.