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.


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.


The UK has published new Regulations relating to the treatment of politically exposed persons (PEPs as they call them). The Regulations are stupid. The Money Laundering and Terrorist Financing (Amendment)
Regulations 2023 were passed on 14th December 2023 and come into force on 10th January 2024 - effectively on two weeks' notice.


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.