The past few weeks have seen quite a few developments at Financial Crime Risk and Compliance Training (link below) Working with a training services provider, we planned a face to face course backed with a full e-learning presentation, examination and certificate.
That has had to be postponed because of increased restrictions following a significant increase in CoVid-19 infections. En passant, my blog (link below) has a new article about the hidden victims of the pandemic in “The Loneliness of the Long Distance Manager.”
Also, one of the reasons there was no newsletter in September was that I wrote a long blog about the FinCEN Files. I am hugely critical of many aspects of the reporting.
We launched the course Essentials: The financial crime risks of Offshore Financial Services, Private Banking and Family Offices, then almost immediately added a dozen pages looking at several important cases that set the tone for the entire sector – and the treatment it has received.
Today, we’ve added a new section about a huge offshore banking scandal in which the undercurrent is that of regulatory capture.
Next week will see the launch of another new course: Essentials: The financial crime risks of corporate vehicles, trusts and other structures.
This includes a fascinating study of how financial scandals starting 400 years ago not only demonstrated a range of financial crimes but also produced regulatory and enforcement techniques that were rarely used until the past 30 years or so and which now form the backbone of freezing and confiscation by the state.
The course examines various legal concepts and, of course, the expected KYC/CDD on corporate vehicles, trusts and other structures.
We have several more courses in preparation for release before the end of this year and we are already building our 2021 release schedule. Each course is carefully researched and written in a style similar to a lecture, so that it’s chatty and not overly formal. But, of course, we are dealing with formal and legal topics so the language used must reflect that.
When I’m writing, I do not shy away from being contentious: there is no point in presenting you with a list of things plundered from government and quasi-government material and presenting them as fact. In truth, those documents are the result of endless filtering through what their proposers want you to think. I see it as my job to point out the things that were left out and to get you to think about those.
If we are to be effective against financial crime, which ranges from paid-for child abuse to paying constituents to vote for a particular party, we have to think about the things that we don’t want to think about. We have to challenge orthodoxies.
As I’ve said in training courses for more than two decades “those required to detect and deter financial crime are taught to think in straight lines; criminals think around corners.”
We need to test and challenge everything we are told, never to accept blindly what we read, no matter where we read it. Fake news and mis-information did not start with the internet. “Authority” is often not what it seems.
I take it as my role in this industry, as one if its founders, to raise that challenge and to at least tell you where valid challenges lie. Whether you take it up is entirely your decision but.. don’t you think you owe it to yourself and more to think about it?
Stay well, stay safe – and visit the blog and the training site.
Regards — Nigel Morris-Cotterill
Counter Money Laundering Strategist
Financial Crime Risk and Compliance Training e-learning at
© 2016 Nigel Morris-Cotterill
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