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: https://www.financialcrimeriskandcompliance.com/elan/web/20230626_nazif…

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.

The past couple of weeks has seen some significant issues in financial crime but, sadly, many practitioners are far too busy to see their implications on their own. We’re here to help.

A decision by The Solicitors' Regulation Authority has provided the impetus for me to decide that I will formally leave the solicitors' profession. But the final catalyst was in a document from The Law Society of England and Wales.

There are increasing international security threats. While some are talking up the risk of a world war, others say that there are likely to be local, brutal, conflicts.

But the quiet and big money isn't on nuclear threats or chemical weapons. It's not even on attacks in overwhelming number. No, the big money is not on attacks on or by hardware or wetware: it's on software.

The issue of the sexual and other physical abuse of children is a live issue within financial crime, particularly because of the growth of live-streaming of abuse to order.

The victims are half-a-world away but the monsters to place their orders and watch are much closer to home. This is where we need to look.

Businesses of all types have compliance policies and procedures. Where should breaches stand in the degree of seriousness?

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.