20140924 Of NY DFS, ISIS and much more

From Nigel Morris-Cotterill – LinkedIn contacts newsletter September 2014


The monthly newsletter has slipped a bit behind schedule because other things have slipped, too. So this is a long newsletter, covering two months.

A big chunk of August was taken up with the surprise chance to undertake a post-publication edit of “How does that make you feel?” Usually, the errors that are found after publication cannot be corrected until a new edition comes out – even second production runs contain the errors. The traditional way of dealing with this is by putting an “errata” slip in each copy.

When we published “How not to be a money launderer” in 1996, we were, again, at the bleeding edge of industry: we found a printer who was able to produce high quality, perfect bound (that’s a technical term, and it’s not the same as “perfectly bound”) books and so we were able to produce a small number of books. We could make corrections to the second run because, and this was seriously advanced at the time, the books were printed from our electronic files and no printing plates were made for the interior. Covers were still printed in the traditional fashion.

Today, this method of publishing is commonplace and it’s even gone a step further with some printers having a print run of as few one one copy of a book, largely because, now, the technology is such that even single covers can be printed. This means that bookshops can supply, to order, millions of books that previously they could not list because the cost of production, shipping and even shelf-space was too great.

Now, my books are available in many countries, some from bookshops which do keep small stocks but also from shops that order it for customers. It might take a couple of weeks for the book to reach the bookshop from its printing base in the USA but that’s OK, I think.

The upshot of all of this is that when an error in the layout of the cover was noticed in hard copy, we were able to change it. And that change opened the door to a letter-by-letter, punctuation mark-by-punctuation mark review of the book. We were also able to make some minor changes to layout which kept the book the same length but reduced the number of pages. So we’ve saved some trees!

So, all of this means that when you buy a copy of the book, you get the one with the typos corrected. And the back cover layout fixed. Me? I’ve got a few of the old ones, with mistakes: do you think they will achieve rare book status and become immensely valuable?

Probably not!

“How does that make you feel” is probably not going to be released for Kindle, etc. The reason for this is that we appear to be under siege from organised criminals who have bought copies of my other books, and World Money Laundering Report, and then shortly afterwards returned them. The pattern is far to obvious to be coincidence.

Now I am finding, around the internet, illegal copies of the book and WMLR. We are shutting them down as quickly as we can – and we have reported an anonymous proxy service based in the USA to the FBI for investigation as to possible complicity in this copyright theft and, of course, profiting from the actions of the criminals by taking a fee. The criminals may, also, be using the destination site as a distribution point for malware or for phishing.

While they could argue that they did not know or suspect, once we put them on notice that the site had no authority to provide copies of the material, by continuing to facilitate access, it seems to me pretty open and shut that their continued actions are culpable.

As they take place across both state and international borders, it’s Federal jurisdiction. I told them that if they continued to provide the links to my product I wouldn’t play nice but they chose to hide behind some bureaucratic process. So I didn’t play nice.

Issue 4 of the 13th Volume of World Money Laundering Report took a while to appear largely because of its subject matter: published on 24th September, we had to wait until certain developments played out in relation to ISIS so that we could use the dots we had to show a likely development of the situation. We were able to produce that picture on 23rd September and put the issue to bed. On 24th September, the primary prediction we made came true. The dots we found will surprise you and the picture it draws will worry you.

There are some other things:

++ The hidden dangers of Islamic State (ISIS/ISIL/IS): coming to a screen – and a street – near you.

The adoption of the name “Islamic State” by the terrorist group formerly known as ISIS or ISIL is another demonstration of how the group is tech savvy – and able to manipulate even the mighty Google for its own ends. And that’s just one small part of a much bigger range of problems.

++ Standard Chartered’s USD300 million fine is a lesson in relations with a deviant regulator.

The decision by New York state’s banking regulator to impose a further penalty on Standard Chartered shows a willingness, on the part of the regulator, to deviate from tradition. It is clear: in the hands of Benjamin Lawsky, regulation is a hostile tool, not a means of co-operative management of the financial sector. Not for the NY Department of Financial Services the approach of calling in senior bankers and pointing out the error of their ways and inviting them to fix it, failing which there will be trouble. Instead, he has placed one of his own people into a bank, monitored its actions, identified failures in a brand new system and, instead of allowing an opportunity to remedy those failures, demanded another large financial penalty and even measures that cause substantial harm to continuing and future business. Worse, he has done it in relation to unpublished criteria.

++ England and Wales: further evidence – money laundering is not a priority for The Law Society.

It’s almost funny: we look at how The Law Society of England and Wales treats research into money laundering cases

++ New York’s DFS takes welcome step against advisers with action against PricewaterhouseCoopers and Deloitte.

In August 2014, the New York Department of Financial Services again broke ranks with other regulators. This time it got its target right.

++ The fall and possible rise of Arthur Andersen

A phoenix might rise from.. well, the shredding if not ashes.

It was good to see that enough Scots came to their senses and voted against Alex Salmond’s half-baked plan for independence. In my blog I wrote that we were seeing signs of capital flight from Scotland to England before the vote and that, if independence followed, on a wide range of risk management criteria, including legislative, regulatory and policing shortfalls, Scotland would have to feature on blacklists as a non-compliant, high-risk country. If the Scots want to vote for independence based on a credible and sustainable plan, then let them. But Salmond did not present one. And had he won, the country would almost certainly have fallen into some kind of chaos.

We’ve listed the dates for the course explaining suspicion. Bangkok, London, Dublin, Dubai and Bahrain in November. At the end of October, I’m booked to speak at an event in Singapore, then it’s back to London via Bangkok, then back to Singapore again to speak on 13th and 14th and then straight back to London again.

Back to publications: there are two schemes under which Amazon grants “library book” access to e-books. While “How does that make you feel” is only available in paperback, the other books and World Money Laundering Report are ebook format and subscribers to Amazon Prime / Premium and to Amazon Unlimited can read them as part of their subscriptions. Unfortunately, these schemes are not available globally.

Finally, by way of a bit of sideways comment, my friend Jefferson Galt wrote a novel in which the interlinking of terrorist groups, especially in relation to hostages, plays a part. Given what we seem to be learning of how ISIS is operating, it seems to be well timed. His website is at www.jeffersongalt.com. I suppose that we should issue a notice explaining that we handle all his tech so he’s a client as well as a friend.

For details of the books and the courses, please see www.countermoneylaundering.com
For details of World Money Laundering Report Volume 13 Number 4 and purchase links, please see www.worldmoneylaunderingreport.com.

Best wishes

Nigel Morris-Cotterill

© 2014 Nigel Morris-Cotterill
All rights reserved.