20170926: My newsletter – Improving Suspicious Activity Reporting – HKG, SYD, MEL, (CGK)JKT, DXB, LON

Wednesday, 27 September, 2017 – 09:03

You know the old joke – you know when you are travelling too much when you refer to cities by their airport codes?

Well, yes, that’s exactly what I’m reduced to. Having just got home to Kuala Lumpur after KUL, CAN, HRB and return (delayed a day because the otherwise excellent China Southern cancelled one of my flights and gave me a key-ring to make up for it), I’m now setting up the schedules for the final (so far as I know) legs of my seminar tour.

At the beginning of the year, it was called “Understanding Suspicion in Financial Crime” and feedback told us that that sounded too academic, too far removed from the daily grind. Of course, nothing could be further from the truth: it’s a look at the fundamentals of why suspicion based reporting fails.

Anyway, for the rest of its run, the seminar has been renamed: “Improving Suspicious Activity Reporting.” I could have called it “Why your staff don’t make reports when they should” or “Why your staff are trying to put you in jail for compliance and risk failures.”

Too blunt?

I think so, although that’s exactly what the course is about.

The course is based on my book “Understanding Suspicion in Financial Crime” for which the publicity says “320,000 words, none of them wasted.” It contains more than 20 years of experience and research into why financial crime risk management systems fail to produce the SARS that they should.

In the course, we look at the issues raised in the book and examine case studies drawn from all over the world. There are common factors in almost all the cases which have cost, in come examples, fines and penalties of hundreds of millions of USD, cost people jobs, in some cases freedom and has resulted in widespread adverse publicity for banks when the problems were localised.

We will look at de-risking and whether the processes for that are based in reality or are so superficial that they border on the discriminatory – and see why that superficial approach is obvious but flawed.

This seminar will help reporting entities improve their recognition of suspicious activity and internal and external reporting.

It will also help investigators, regulators, prosecutors and judges understand why suspicious activity is under-reported and to identify weak areas in internal systems in reporting entities.

An interactive event for

– financial crime risk officers, including MLROs, in banks, insurance companies, securities houses and all other businesses subject to laws requiring financial crime, including money laundering and terrorist financing, risk management.

– investigators and prosecutors – why do individuals and companies fail to make reports?

– defence lawyers – where are the boundaries of reasonable cause for suspicion?

– regulators – why do information flows within companies fail?

– judges – explaining to jurors issues of wilful blindness and reasonable cause for suspicion.