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)


It sounds like a letter on an agony aunt page, doesn’t it?

But no, it’s actually a series of sensible questions from someone who is bamboozled by the jargon in the financial sector.

Here it is, with my replies.

You can listen to this BLOG/cast at www.financialcrimebroadcasting.com


When Des Hellicar-Bowman referred to a 19th Century book, “The Theory of the Leisure Classes” by Thorstein Veblen, I knew it would be good because Mr Hellicar-Bowman and I take a similar view of financial crime in that it the only way to understand it and therefore to effectively counter it is to make a broad study of everything to do with it, including those things that appear to be only...


As the dust continues to swirl around the US presidential election much media mileage is being made of the USA’s “first black woman vice president.”

There’s just one issue: Kamala Harris isn’t “black.”


Good morning. I seem to be having some difficulty working out how long a month is, as it seems that my last monthly newsletter was on 25th August. That’s as close to two months ago as no matter.

In that two months, much has happened in the world and a lot of it has a direct, or indirect, impact on the world of financial crime risk and compliance.


We are, once more, seeing unprecedented times as country after country sets records for daily infections with CoVid-19.

But there’s a forgotten, perhaps unrecognised, group of people who are deserving of attention.

You can listen to this BLOG/cast at www.financialcrimebroadcasting.com


There is, at present, a state of excitement amongst the media, some financial crime consultants and some politicians in response to what they are being told is public opinion.

The so-called FinCEN Files were heavily telegraphed in a media blitz more akin to the launch of a Hollywood film that has cost a fortune but the result isn’t as good as was hoped.

In the USA and the UK, mainstream media outlets have published a series of articles that, they say, arise because of what it has found in documents obtained from the USA’s Financial Intelligence Unit, FinCEN.

Listen to...


Before almost every FATF meeting in the recent past there have been comments that Pakistan will be removed from the “Grey List”.

We’ve heard about legal and regulatory changes to make that happen.


It′s been a busy few weeks in financial crime.

One has to wonder how much of it is pent-up action that people have found ways to do since the world began working from its back-bedroom or the kitchen table and how much of it is people trying to keep busy so they look as if they are achieving something when they haven′t found ways to perform their normal duties effectively.

Listen to the BLOG/cast at www.financialcrimebroadcasting.com


In this newsletter:

Covid-19 won’t go away, why I gave up with podcasts in 1997 and how the number 8 is playing a huge part in the launch of a new course on correspondent banking, value transfer systems and remittances.

Listen to the BLOG/cast at www.financialcrimebroadcasting.com


Last week, I finished the Essentials: Correspondent Banking etc. course. Then I threw it away and wrote something completely different instead.

Here’s why and how I’ve ended up walking around like a bird with a broken wing.


The announcement without warning that the UK’s Financial Conduct Authority was freezing assets of German FinTech Wirecard has caused consternation.

But while the fall-out has been severe for many individuals, it was both temporary and fits the profile of interventions. There were also good and prudent reasons for it.

Here’s why.

Listen to the BLOG/cast at www.financialcrimebroadcasting.com


Good morning, good afternoon or good evening depending on where you are. Sitting at 101 degrees East, I’m roughly in the middle of the day for half of the world and in the tail end of the previous day for the other half.

That’s an example of how we tend to think in a very localised way, even when we are acting on a much bigger stage. But there’s more….


In the past week, we have learned that the 2020 F1 Grands Prix in Singapore, Suzuka, Sao Paulo, Austin and Baku will not, or probably will not, take place. take place. We have already lost the first half of the season including the much awaited Vietnamese Grand Prix. The underlying reason is that there remains great fear of the spread of the CoVid-19 virus and such fear is not misplaced.

But there is one place where ground can be made up quickly, easily and even cheaply.


It’s a thing. And you are not alone.


Good morning.

Last month’s newsletter was a round-up of lots of updates.

And it was long.

So now we’re all on the same page. This one 🙂

You can listen to this BLOG/cast at www.financialcrimebroadcasting.com