Monday, 20 July, 2020 – 05:46
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.
I’m sitting typing with pain in my forearm like a rat is gnawing away inside. I’ve spent several days with painkillers, exercises, massage and pretty much everything except sticking needles into my muscles to try to ease the discomfort and make my arm work properly. What started as a pain in one muscle has now spread from the back of my hand to my shoulder and part of my back. Why? It’s all the fault of Deutsche Bank, Jeffrey Epstein and the New York Department of Financial Services.
I have an extremely comfortable working environment – pretty much every ergonomic approach has been implemented. Except one: a failure to properly adjust the nut that sits in the chair.
It all started with the e-learning course Essentials: Correspondent Banking, Value Transfer Systems and Remittances. Correspondent banking is a very easy concept: it’s also the subject of a myriad forms of interference. By the time we add in the alternatives and the complications they both bring and face, it’s not a small subject. In fact, it’s enormous.
That brings its own special challenges. I can’t help it – I want the stuff we produce to be comprehensive. I don’t want to write about half-a-dozen pages and tell readers they are experts; I don’t want to set an examination and let those who get more than, say, 60% imagine they have learned enough. When people, when you get the certificates from FinancialCrimeRiskandComplianceTraining.com, I want everyone to know that it wasn’t easy. And I want them, you, to know they have learned what they could not have learned elsewhere and that you are better equipped to protect your organisation. But I don’t want it to be a marathon for them, for you, and I don’t want it to be difficult to read and understand.
Three weeks after the intended publication date, I looked at what I’d got. “F*** it”, I said to the only person who could hear me. That’s me, in case you are puzzled. “It’s not an e-learning course, it’s a f***ing book.”
And it wasn’t finished. So, I finished it. One of the good things about working on a computer is that adding material does not add physical weight. Another thirty or forty pages doesn’t add kilos to the hard disk in the way that it would if I were producing a manuscript on paper. One of the bad things is that as the document gets longer, you can’t flick through the pages as you would with a pile of paper, you have to scroll up and down. And if you have four, five, six or whatever long documents open at any one time, you have to scroll through them all.
I work fast. So I flick up and down all the time.
Having put the tome to one side, I decided a few days break from that would be good. So I started on a short course, we call them “Micro-Courses” but it’s still a two hour course, on that part of the case about Deutsche Bank’s troubles in New York that isn’t about correspondent banking (that’s in the, er, correspondent banking course, of course). It’s a single topic: what could possibly go wrong?
Shed loads, that’s what. But, of course, I had no inkling of that when I started.
But something else happened, too. The case, which falls naturally into two discrete parts – that of the Epstein situation and that related to two correspondent banking problems – is totally fascinating. That’s not because of the lurid stories nor even the panoply of the rich and/or famous that are implicated in one way or another but because of the novel legal approach that the New York Department of Financial Services adopted.
The risks it creates reach far beyond its own jurisdiction. In some respects, it’s the most important case in relation to suspicious transaction / activity reporting that there has been for a very long time. It applies to every business that must put financial crime risk and compliance measures in place, anywhere in the world.
Doing that analysis, looking over the horizon, considering the strategic implications of the Order took me back to my roots in this field, a quarter of a century ago. It’s very rare that anything new happens – the stuff you see people saying “I have discovered”: no, they haven’t. There is a handful of people like me: the real pioneers. I had a really good time. And I found that it’s not all bad news – in fact, there’s some very good news that simple reportage, like most people publish and pretend they’ve covered the case properly, won’t see. That’s why you need people like me. We are always looking for something new and while others think they’ve found something all the time, those with proper experience know that 99.9% of the time, it’s just a minor variation on a theme.
So it was exciting: there really is something new. And important. These are the all-too-rare nuggets that get me out of bed each day.
Which is why I’ve got the sensation of a rat eating my arm.