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 www.financialcrimebroadcasting.com

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?

I am outspoken and often wonder why I am not featured by the anti-establishment media that attack governments, “tax havens” and so on and so forth but, today, something I read brought it into focus:

Listen to this blog at Financial Crime Broadcasting Let’s start with a statement that will upset the bubble people who pay attention only to those of like mind and will be applauded by those who truly understand the issue of financial crime risk and compliance both from the point of view of practitioners and in legislatures and regulators.


Today, I’m going to look at a fascinating case that is progressing through the courts in India. We don’t yet have a judgment and are relying on media reports and the judgment in the lower court but it is so important that it’s worth being aware of it – and its implications.


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?