One of the frustrating things about being me is that I have an excellent memory, for some things. I don't remember names of faces but I do remember facts and where to look them up. The frustration is that I see patterns, some going back over decades, where almost everyone I come across thinks everything is new.

Like the case of Mark McCabe (reported in World Money Laundering Report this week. It looks like a novel sort of crime.

And there's FTX and the emerging story of...

Hello and welcome to my newsletter for 17 March, 2023

There's an outfit that is gaining attention hand-over-fist, growing its LinkedIn followers very rapidly.

That would be fine if they were doing it honestly.

But they aren't and I'm seriously cross.

There are news reports that some USD58,000 million was "wiped off" the share value of the USA's four biggest banks as soon as trading started today.

This matters to you.

Let's start from the point that "artificial intelligence" is a consumer-friendly name for "algorithmic analysis" because that is what it is.

Who defines those algorithms? Humans do. So when "artificial intelligence" fails, it's because humans have failed.

The quality of the algorithms depends entirely on the capability and the discriminations of those who build them, whether those discriminations be deliberate or "unconscious."

With the publication this week of the sixth part of the Imaginary Friends series at The Yuan, delayed past its original, Chinese New Year, publication date, I'll let you in on some of the background to the series about "artificial intelligence" and its place in the world and in financial crime risk and compliance as RegTech.

US Republicans plan to blow up .. well pretty much everything.

If the OECD thought it was dealing with tax competition before, it ain't seen nuthin' yet.

Some people think money means tokens by which they almost always mean coins and, later, notes.

No. Money is a philosophical construct. Or to put it another way, it's all in your imagination.

There is little doubt that there is a growing interest in the creation of "failure to prevent" laws. Broad Left pressure groups such as Transparency International and the UK's All-Party Parliamentary Group on Anti-Corruption and Responsible Tax (which has a number of Conservative MPs in its ranks) are agitating strongly in favour of one or more "failure to prevent" provisions to be added to existing laws relating to money laundering and more. The UK's Law Commission thinks there is a discussion to be had.

PerpetualKYC, or pKYC, is a recently adopted term amongst RegTech companies.

Let's debunk it.

I've always been known for my over-the-horizon thinking.

But, good grief, the horizon is moving fast when it comes to developments in so-called "Artificial Intelligence" and things are going to get interesting in RegTech.

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.

#Tuesdays always used to be slow #news days.

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.