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.

I was replying to a post on LinkedIn and my note turned into a bit more than allowed. Here it is.

During the CoVid-19 pandemic, many risk and compliance topics gained fresh momentum. Amongst them was the (internet-) age old topic of identity, something I first drew attention to in the late 1990s.

It's what I call a "Guinness Topic": there's lot of froth to get through before you reach the beer or, in this case, the stuff that really matters.

Post-Pandemic, I've been out and about and finding out what's been going on while people have been working in their own little silos. I expected that most things I would find would be as I had moaned about before: the increasingly restrictive law, regulations and rules that have appeared during the pandemic but no, even that landslide is not the most surprising. This is ....

One of the fascinating aspects of having the longevity that I have had in relation to financial crime risk and compliance, coupled with my previous career as a lawyer, is that things come around again and again.

What is now called "RegTech" has been around, in one form or another, since the 1990s. But underpinning all KYC and transaction monitoring decisions, be they by people or machines, is the Risk Matrix.

Looking back over the past 20 or so years of seminar tours, one of the most popular was Building a Risk Matrix. Time, methinks, to produce a new version of that...

This week, we tried something interesting: we released almost our entire e-learning catalogue -- here -- for the discounted price of just GBP15 per course for April Fool's Day. At least, that was what we thought would be the interesting thing.

We were wrong: the interesting thing was something else entirely.


This month's newsletter is not going to be about international conflict, global warming or the pandemic.

It's going to be a celebration of some kind of normality, at least for most of us.

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

This episode is published the 10th March 2022

You can listen at

I am fed up with the broad left media crowing about the decision in an English court to acquit a group of vandals who caused extensive damage to public property and cost to the public purse all because they claimed their actions were in support of a fight in which they have no dog. There is much wrong with the decision - and its consequences can be immense.

Listen to this blog at Financial Crime Broadcasting

In Russia, for example, there is no Santa Claus but today, 6th January, there is Father Frost who, except that he wears blue, is a Santa Clone. In Christian-based societies, today is Twelfth Night and that's the day that all the festive decorations must be taken down.

For us, it's the day we launch the first e-learning package of 2022 for risk and compliance teams. Details are here. Individuals can buy it, too.

Following the package will take users to full certification for the Certificate...

There are differences in approaches to risk and compliance.

This article was first published by Complinet / Thompson Reuters on 29 April 2012.


Well, that didn't go so well, did it?