Hello

I’ve a round-up of some stories that haven’t made the news but which give
pause for thought.

The FBI’s embarrassing plea.
The strange case of municipal bonds fraud.
Will a case relating to a Royal Will at last give transparency to Deferred
Prosecution Agreements?
Training: a new package for compliance teams with CPD and a certification.


We hear a lot about ″threat assessments″ in relation to financial crime (that is crime for which the primary activity is dealing with money). We hear about the ″threat″ that various form of economic crime (that is crime for which the primary objective is to make money) pose.

But when someone focuses on the ″threat″, he has come late to the party.


2021 marks the 25th Anniversary of the publication of my first book, How not to be a money launderer.

I’ve been wedded to the first edition of the first book for what would, if it were a she, be our Silver Anniversary.

So, I thought, let’s do something about that.

This is what I’ve done…


I am sitting at home building things. The things I am building is websites. The past month has been a flurry of activity as I have built several interlocking sites that all serve a discrete purpose and one that, as a kind of Group site, also has an e-commerce back end.

That’s where, in the tone of a 19th Century maiden, I found myself undone.


We all have our heroes. Amongst mine is English judge Lord Denning.

But hero worship needs to be tempered with a realisation that even something good can lead to something bad when people who don’t understand what they have use it in the wrong way.


The essence of banking is that a bank is in a fiduciary position in relation to its customers and that deposits are, in effect if not in law, held on behalf of account holders in a form of trust.

In short, money in the bank belongs to the account holder.

What if it doesn’t?


You don’t need me to tell you that the cost-benefit equation of counter-money laundering laws and regulations is tipped way too far in the wrong direction, nor that the laws and regulations we have are onerous and infective, that the original plan, that ordinary people would watch out for dodgy activity and report it has been lost under a weight of bureaucracy.

You don’t need me to tell you that because you already know it.


I have written before about the cyclical nature of fraud and, in particular online spam.

I thought I’d let you in on some of the reasoning behind how I review fraudulent e-mails and identify the trends they indicate.

Listen to this blog at www.financialcrimebroadcasting.com


It’s taken a while to move my blog from countermoneylaundering.com to, er, countermoneylaundering.com.

You don’t need to know why – it’s all to do with the tech we’ve used for years becoming obsolete in a few months. But if you want to know, read on.

Like literally tens of thousands of website owners, I’ve held out, hoping that the developers will relent. They haven't.


Do you remember that Westpac found itself in trouble because, essentially, someone didn’t make sure that something was turned on properly?

It demonstrates the problems with piecemeal approaches to risk and compliance, indeed to management generally.

Too many companies don’t have someone who takes a holistic view of an entire system.


There are two discrete functions in relation to problems with systems and controls.


We always assume that facts are immutable: unable to be challenged and never changing. And we assume that this is a fact. Then we assume that suspicion is always based on fact. Well, no. It's not - as we can all readily spot from the things that happen in our daily lives.


Today I'm writing about white holes, "The Place of Unthought Thoughts."

This is not unknown unknowns, it's about the things we know about but don't want to know more about, where our quest for understanding reaches the end of our willingness to enquire.


Hello and welcome to this blog (10 May 2021) which will be emailed as my newsletter and recorded as a BLOG / cast.

Today is the day that the United Nations Office on Drugs and Crime starts a meeting about what it terms "cybercrime." The meeting will start with a discussion around what should be included within the definition of "cybercrime."


On 10th May, the United Nations Office on Drugs and Crime will convene a meeting relating to “cybercrime” at which it will discuss a range of topics.

I’ve been there, done that – and now I’m doing it again.


I first wrote about wilful blindness in 1996 in my book "How not to be a money launderer" and I said then that it was destined to be the central point on which all counter-money laundering laws would hang. I wasn't wrong then and I'm not wrong now.

To understand it, we'll take a quick romp through knowledge, belief and suspicion and then why machines cannot and for the foreseeable future will not be able to identify suspicion.


This is going to make a lot of people very angry. Sadly, those that are going to be angry are those that have been found out.

Those that should be angry - the consumers who have been misled and the tax payers who have supported the rampant charge into FinTech support by regulators and, even, the banks who have had their business models and even management plans disrupted, in the true sense of the word, by the host of millennial-targeting banks that pretended they were not banks, supported in that subterfuge by regulators - are not going to be angry.


I thought I had nothing current to say, as I'm busy readying myself for the relaunch of Quick To Learn more in a few days. But it was time to write a newsletter, in particular drawing attention to quicktolearnmore.com and a couple of things at financialcrimetraining.com

As I wrote the tailpiece, it turned into an article that, inadvertently, works as a blog. I'm not going to BLOG / cast it. Here, in its original form including the ads :)

Updates from Financial Crime Risk and Compliance Training and from Financial Crime Broadcasting.


The blogcast is at www.financialcrimebroadcasting.com.

Hello and welcome to The Financial Crime Risk and Compliance blogcast with me, Nigel Morris-Cotterill.

This episode is published the 24 February 2021

It is available in text on my blog at www.countermoneylaundering.com.


Hello and welcome to The Financial Crime Risk and Compliance blogcast with me, Nigel Morris-Cotterill.

This episode is published the 11 February 2021.

It is available in text on my blog at www.countermoneylaundering.com and as a blogcast at financialcrimebroadcasting.com

In this episode:

1 Goodbye Rat. Hello Bull.

2. OFAC’s fuzzy logic

3. [un] conscious bias : it looks simple but it isn’t.

4. How to not make a fortune.

5. Corruption as explained to Sherlock Holmes.

6. The last...


This is the first blog of 2021 and the first I have released with a newsletter, this blog and the blogcast all on the same day.

In this issue:

Out-going PoTUS and the time-bomb he left behind

The media myth about the USA’s latest legislation

Radiogate

Sherlock Holmes and the money launderers.

London’s financial crime kingpin in the 1700s.


I have a newsletter in preparation but there’s stuff still to do. But, sometimes, it’s worth jotting a few notes mainly for myself but perhaps of some interest or use to others.

In any case, there’s a thing about writing. If you can’t write what you want, write anything, no matter how random or rubbish, to get the “I’m a writer” part of the brain going.

So, here are meanderings (and that bit was written after the rest of the page so it’s worked. Ish). If you think it’s a waste of your time, stop reading. Or learn the technique because it might help you when…. Read on to...


This is the script for the BLOG/cast “The trouble with SARS” published 21 December 2021 which was also the last of my newsletters for 2020.

Listen at www.financialcrimebroadcasting.com


One of the most quoted sayings of Sun Tzu (“No plan survives the first contact with the enemy”) isn’t by Sun Tzu. But there is at least some evidence that an ear-biting, wife-beating boxer said “no plan survives the first punch in the face” (although even that is told in several different versions). So I feel entirely justified in coming up with my own variant on the original misquote.

"No plan survives the first contact with the Year of the Rat" (or 2020 – take your pick)