Starting life as “The Money Laundering Compliance Website” it was hosted on a service run by Virgin Internet in the UK. After a while, we created the domain name “CounterMoneyLaundering.Com” – because that’s the correct expression.
Later we created names with “AntiMoneyLaundering” in the title – not because that’s correct (it isn’t) but because the rest of the world was following a linguistic mistake made by the Americans. And they shouted a lot so people did as they said.
Over the next twenty years or so, we built an international group of companies dealing with lots of different aspects of money laundering (etc.) risk management and compliance and we expanded into other areas, especially in our publishing business.
Gradually, consulting per se became a less important part of our business. But I continued to develop strategies and to identify future risks. And to understand failings in existing policies and procedures.
So the consulting and thought leader (I hate that expression but if anyone is entitled to use it, it’s me) parts of the business became increasingly my personal province.
And so here I am. Almost back where I started in April 1994: there’s me, a bank of computers, a (different) great view out of my windows, ludicrously loud music all around me, no telephones on my desk and the time and freedom to think and to communicate.
Someone else looks after the businesses and I have input where required. And that’s nice.
It’s in everyone’s best interests: I’m not an administrator. I’m an artist and a wordsmith, a tamer of flights of fancy where I look over the horizon and get a fix on things others won’t see for months or, even, years. When I’m tied down with the management of a business, or the grunt work, I don’t get to do what I do best.
In this blog, I’ll make occasional pithy comments. Unlike so many others, I’m not going to do the thing of simply reposting stuff I’ve found elsewhere. If it’s worth being here, it’s worth comment. What I write here will be proper thought, or at least original thought. It might make you think. It might make you angry and it might make you dismiss what I have to say.
If you do it’s up to you. But remember this example: in October 2001, I explained to bankers in London exactly how the USA would apply its laws to foreign banks transacting in US dollars and that if they had a footprint in the USA how they would be exposed to prosecution there.
My views were dismissed by lawyers, accountants and other advisers who had accompanied their clients to briefings or who were shown copies of my notes. But I was right. HSBC and Standard Chartered are amongst many banks subjected to substantial penalties in the USA which did precisely as I said it would.
Here’s the thing: I’d identified that risk, and the way it would be structured, not because it was set out in the USA PATRIOT ACT (which was the reason the briefings were held) but in 1996 when I had read a description of a process that had been considered in 1976 by a District Attorney in the USA. I extrapolated from that, joined it with other information and was warning clients of the risk of prosecution in the USA for activities conducted outside the USA fully 15 years before the prosecution of StanChart and HSBC and others.
Then again when, in 2006, I identified the approaching US financial crisis, no one listened; nor when, in 2007, one of my companies spent three months trying to find speakers (and delegates) for a conference called “When America Sneezes” to prepare for what I saw as an inevitable global financial crisis. We didn’t sell even one seat. A month after we cancelled it, Lehman Bros collapsed causing exactly what I had warned of. Yet I did not use rocket science to see it coming; I merely used lessons from history – a history that, (in)famously, Alan Greenspan told Congress his US Federal Reserve economists did not have access to.
Even though regulators have long argued (some are still arguing) that general insurance and similar policies are “low risk” for money laundering purposes, their use has been growing steadily. I’ve been nagging for a recognition of the risks, and explaining them, since the mid 1990s. And I’m still nagging….
When another commentator described my book “How not to be a money launderer” as “risible,” little did he know that it was destined to be used by enforcement agencies all over the world as a tool for understanding how to identify criminal behaviour – and how to build a prosecution case. Next year it will be 18 years since it was first published and it’s still selling steadily despite a fraudulent and libellous review under a false identity quoting false credentials that Amazon.Com peddle all over the world without giving equal prominence to my riposte.
So, I’m pleased to be back where I belong doing what I do best. The view from my window is to the horizon: I’m looking beyond that to see what issues are arising.
And when you need the best assistance to understand risks or to explain things to you or your colleagues, clients or readers in a way that is entertaining, memorable and highly informative, I’ll be here. Just look around at what I do and fill in the form.
I’ll be happy to help.