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?

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

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

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.

I published the following article on Mondaq in 2003.

It demonstrates why currency transaction monitoring is only a fragment of the risk and compliance strategies that are needed to be effective.

It shows how, in 2003, financial institutions were under pressure to change what information they watched for, collected and responded to.

Today, 18 years on, have any of those changes made a lasting impression?

Has the rush of "new" technologies actually taken us any further than that available in 2003?

Or has the industry, especially in the light of...

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.