I have written before about the cyclical nature of fraud and, in particular online spam.
I thought I’d let you in on some of the reasoning behind how I review fraudulent e-mails and identify the trends they indicate.
22 July 2020
It’s taken a while to move my blog from countermoneylaundering.com to, er, countermoneylaundering.com.
You don’t need to know why – it’s all to do with the tech we’ve used for years becoming obsolete in a few months. But if you want to know, read on.
Like literally tens of thousands of website owners, I’ve held out, hoping that the developers will relent.
1996. Second edition 1998. Revised second edition 2010.
This is the book that established Nigel Morris-Cotterill as a critical thinker and long-term strategist, explaining a comprehensive approach to help create systems and controls that would be stable and to not require constant change which is both costly and militates against the effectiveness of systems up and down organisations.
Do you remember that Westpac found itself in trouble because, essentially, someone didn’t make sure that something was turned on properly?
It demonstrates the problems with piecemeal approaches to risk and compliance, indeed to management generally.
Too many companies don’t have someone who takes a holistic view of an entire system.
There are two discrete functions in relation to problems with systems and controls.
We always assume that facts are immutable: unable to be challenged and never changing. And we assume that this is a fact. Then we assume that suspicion is always based on fact. Well, no. It’s not – as we can all readily spot from the things that happen in our daily lives.
Case Studies: we’ve added two new case studies in the past week. One, an insurance fraud, is perhaps one of the most ridiculous cases – and the most tragic – in our collection.
Wednesday, 16 December, 2020 – 02:00
One of the most quoted sayings of Sun Tzu (“No plan survives the first contact with the enemy”) isn’t by Sun Tzu. But there is at least some evidence that an ear-biting, wife-beating boxer said “no plan survives the first punch in the face” (although even that is told in several different versions). So I feel entirely justified in coming up with my own variant on the original misquote.
No plan survives the first contact with the Year of the Rat (or 2020 – take your pick)
In this last newsletter before whatever Christmas will mean this year and, indeed the last newsletter for 2020, let’s have a look at just two of the several live issues in relation to financial crime risk and compliance.
But first, welcome to the several hundreds of new subscribers since my previous newsletter and to those joining us for the first time from our e-learning platform.
You, too, can sign up to receive this once a month (ish) newsletter in plain text (no html) in your inbox. Click to visit Financial Crime Broadcasting
Friday, 27 November, 2020 – 03:43
It sounds like a letter on an agony aunt page, doesn’t it? But no, it’s actually a series of sensible questions from someone who is bamboozled by the jargon in the financial sector. Here it is, with my replies.
When Des Hellicar-Bowman referred to a 19th Century book, “The Theory of the Leisure Classes” by Thorstein Veblen, I knew it would be good because Mr Hellicar-Bowman and I take a similar view of financial crime in that it the only way to understand it and therefore to effectively counter it is to make a broad study of everything to do with it, including those things that appear to be only peripherally relevant.
The book is obliquely applicable to financial crime but it is directly relevant to how we view assets and source of funds and source of wealth. Here’s what I found….
Sunday, 8 November, 2020 – 03:52
As the dust continues to swirl around the US presidential election much media mileage is being made of the USA’s “first black woman vice president.”
There’s just one issue: Kamala Harris isn’t “black.”
Tuesday, 20 October, 2020 – 06:31
Good morning. I seem to be having some difficulty working out how long a month is, as it seems that my last monthly newsletter was on 25th August. That’s as close to two months ago as no matter.
In that two months, much has happened in the world and a lot of it has a direct, or indirect, impact on the world of financial crime risk and compliance.
Monday, 19 October, 2020 – 09:44
We are, once more, seeing unprecedented times as country after country sets records for daily infections with CoVid-19. But there’s a forgotten, perhaps unrecognised, group of people who are deserving of attention.
Sunday, 27 September, 2020 – 06:34
The so-called FinCEN Files were heavily telegraphed in a media blitz more akin to the launch of a Hollywood film that has cost a fortune but the result isn’t as good as was hoped.
In the USA and the UK, mainstream media outlets have published a series of articles that, they say, arise because of what it has found in documents obtained from the USA’s Financial Intelligence Unit, FinCEN.
Friday, 18 September, 2020 – 06:09
Before almost every FATF meeting in the recent past there have been comments that Pakistan will be removed from the “Grey List”. We’ve heard about legal and regulatory changes to make that happen.
It′s been a busy few weeks in financial crime. One has to wonder how much of it is pent-up action that people have found ways to do since the world began working from its back-bedroom or the kitchen table and how much of it is people trying to keep busy so they look as if they are achieving something when they haven′t found ways to perform their normal duties effectively.
Saturday, 8 August, 2020 – 08:00
In this newsletter:
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.
But while the fall-out has been severe for many individuals, it was both temporary and fits the profile of interventions. There were also good and prudent reasons for it.
Thursday, 18 June, 2020 – 07:20
Good morning, good afternoon or good evening depending on where you are. Sitting at 101 degrees East, I’m roughly in the middle of the day for half of the world and in the tail end of the previous day for the other half.
That’s an example of how we tend to think in a very localised way, even when we are acting on a much bigger stage. But there’s more….
Sunday, 14 June, 2020 – 06:06
In the past week, we have learned that the 2020 F1 Grands Prix in Singapore, Suzuka, Sao Paulo, Austin and Baku will not, or probably will not, take place. take place. We have already lost the first half of the season including the much awaited Vietnamese Grand Prix. The underlying reason is that there remains great fear of the spread of the CoVid-19 virus and such fear is not misplaced.
But there is one place where ground can be made up quickly, easily and even cheaply.
Monday, 1 June, 2020 – 06:18
It’s a thing. And you are not alone.
Wednesday, 28 August, 2019 – 11:54
When I first started working in money laundering risk management in the early 1990s, reputational risk was something that greatly exercised my mind: surely customers would walk away from financial and professional service providers associated with laundering. That didn’t happen.
Something else did.
Tuesday, 19 February, 2019 – 01:41
I know. You read the headline, looked at the URL and thought “he’s lost it. Again.” But I haven’t.
It’s time that we stopped talking nonsense, stopped using lightweight buzz-wordy phrases and acronyms and got to grips with some basic truths.
Friday, 28 December, 2018 – 05:04
It’s more than four years since my son released his first album, “Stay.” And now, with “Lost and Found,” he’s back. “Stay” was good. “Lost and Found” is much, much better.
Tuesday, 20 November, 2018 – 05:38
The surprising news that Carlos Ghosn has been arrested on tax evasion charges in Japan and has already been turfed out of at least one of his senior positions in the Nissan-Mitsubishi-Renault triumvirate which he is widely regarded as having brought, in each case, back from the dead is worthy of comment, regardless of the eventual outcome of the investigation and charges.
Wednesday, 11 July, 2018 – 12:15
I’m preparing for a trip to Manilla 24 – 27 July 2018 and Taipei from 30 July – 4th August 2018 and if anyone would like to book me to present an in-house seminar or briefing session during those times, check out the list of topics and let me know ASAP.
Wednesday, 6 June, 2018 – 05:40
Late yesterday, I posted to LinkedIn a message about the way sound travels around the concrete canyons in Kuala Lumpur. I had tried to work out the location that a sound originated from but had fallen into helpless giggles when I realised that I could only calculate the position of the source if I had the location of the source. That, of course, was a circular argument and of no value to anyone.
Why, one might ask, would anyone bother?
Life’s funny and the world is tiny. And there is no such thing as no such thing as coincidences.
Thursday, 7 December, 2017 – 13:01
This blog was originally published as ” OK. Call me a contrarian if you want but you are wrong.” with “The falsely accused contrarian and the bubble people.” as a subtitle. In February 2021, this was reversed when the blog was recorded for a BLOG/cast.
Listen to the BLOG/cast free: at Financial Crime Broadcasting .com
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.
Wednesday, 30 August, 2017 – 05:55
When the Commonwealth Bank of Australia (CBA) story first appeared, I instructed World Money Laundering Report that we should not become involved in what would inevitably become a frenzy of speculation and ill-informed comment as consultants (of which I am, obviously, one) and media outlets vied to benefit their own profile, and to get website visits, while the story was hot. I wrote what amounted to a placeholder article .
Tuesday, 8 August, 2017 – 06:51
It’s been a long while since I did a personal newsletter to my 20,000 plus contacts. A lot’s been happening that isn’t work related and one of the things that got shoved aside has been this monthly note.
Let’s get started…
Monday, 29 May, 2017 – 05:58
I could go on for hours, days even, about how easy it is to use various techniques to manipulate the thoughts of a person who is targeted as a vehicle for financial crime. Hell, I do go on for hours, days even, about it when people pay me to present seminars that show them how their companies can avoid being a victim of such offences. But some of the most fun lessons are found when I, me, the one who knows, understands and communicates this stuff, falls victim…
Some people might argue that I’m a Luddite but nothing could be further from the truth. I have long been an early adopter of new technology. What I am not is a follower of fashion. And after a few days with what may be the worst car Mercedes have ever made, I’m even more convinced we need to stop the constant revision of things just so someone can put a “new” sticker on it.
Sunday, 25 June, 2017 – 11:28
As readers of my Tropical City Discs column will know, my family moved around a lot when I was young.
I decided that I’d celebrate that – with a seminar tour taking in some of the places that formed me…
My father, Roy, died on 11 June 2016 after a sudden decline in his general condition.
This is my tribute to him.
Thursday, 26 May, 2016 – 04:53
David Cameron, speaking in Japan where he is attending the G7 Summit, has said that the young, in Britain, should register to vote. He says it may be the most important vote of their lives and it is for them to decide what kind of country they want to live in. He’s exactly right.
And when they do, they should vote to leave the EU. This is why. And as someone who supported the “yes” vote in 1975, I start with a mea culpa.
Friday, 15 January, 2016 – 00:00
I woke this morning expecting to pack for a trip, do a few bits and pieces at work, put the data I need for travel onto a portable drive and clean the house so I don’t come back to a dump, all after enjoying the first cup of tar-like coffee that starts my day.
As usual, while the espresso machine was heating up, I turned looked at the overnight e-mails. There, right in plain view, was another example of why the internet needs a major clean up.
Friday, 23 October, 2015 – 04:18
After a few days in the UK, I’m back in Kuala Lumpur. It’s been an interesting trip.
First, there was the immense contrast between service levels of different airlines.
Thursday, 8 October, 2015 – 11:15
A report in The Guardian says that the leader of the “eBible Fellowship” has announced that the world will end on 7th October.
Thursday, 8 October, 2015 – 00:00
There is no doubt that strong action is needed against Da’esh / ISIS / ISIL. But have we lost sight of the fact that the brutality of Syrian President Assad against Syrians was the catalyst for the current conflict and foreign intervention?
Tuesday, 1 September, 2015 – 05:58
There’s a serious problem in Financial Crime Risk Management and Compliance: the lack of precision in language means no one knows where they stand.
Friday, 28 August, 2015 – 02:09
I’m amused by the social media campaigns for Corbyn as an icon of socialism in the UK.
It seems that he’s the man for everyone – so long as you are from a minority that he can claim to support or a self-interest group that can garner votes from its members.
Friday, 21 August, 2015 – 00:00
We all make mistakes and often for the best of reasons. Often, it’s difficult to make the judgement to correct them, partly because of ego, partly because we don’t know what’s gone wrong and therefore a fix is nothing more than a shot in the dark, or sometimes it’s because we know what has gone wrong but we don’t understand why it has gone wrong.
Tuesday, 4 August, 2015 – 00:00
In terms of sentencing in English law, there is, in effect, an upper figure. Murder is generally subject to a life term, but convicts are released “on licence” – some earlier than later but, if they are going to be released at all, rarely more than 14 years. The maximum sentence for theft, robbery, money laundering, terrorist financing is, in each case, 14 years per count.
Thursday, 30 July, 2015 – 00:00
I am constantly amazed by the utter rubbish spouted by so many so called experts in the field of counter-money laundering, including many who proudly add various letters after their names.
Monday, 20 July, 2015 – 03:33
We don’t have to argue for or against the macro effects of global warming. Just look out of the window, or count the number of showers you need each day.
Friday, 10 July, 2015 – 10:27
Yanis Varoufakis, has resigned. In one of his last pronouncements as Greek Finance Minister, Varoufakis said the idea that Greece could print Drachmas was a fallacy. He is reported as having said “we destroyed all the presses.”
While he might be right in one respect, that of printing actual Drachma notes, he’s fundamentally wrong in another. There is an option that would fix much of the crisis – although it’s one that would cause the EU to have a major fit.
We’ve been here before and if it wasn’t so serious, at least part of it would be funny.
Instead, MLROs across Europe have a nightmare in the making.
Monday, 16 March, 2015 – 00:00
Imagine that you need to book a flight at short notice from London to Kuala Lumpur and back. There aren’t many options but you find one with a transit in Abu Dhabi and, even better, it only takes about an hour longer than a direct flight. So you book it on-line through a reputable on-line service but, because the flight is at short notice, it’s necessary to do some of the paperwork by phone.
Wednesday, 26 November, 2014 – 00:00
When I began writing my new book, there was one primary focal point: big companies providing internet services profit from the crimes of others. That profit can be tracked and traced and internet companies can be made culpable in just the same way as banks, etc. who deal with criminals.
One of the great things about having been, albeit briefly, a criminal defence lawyer is that I’ve heard some pretty stupid defences.
Friday, 10 October, 2014 – 00:00
Sometimes we find that we have made superb decisions because, when we have to make similar decisions, it turns out that we assess all the latest data and do the same as before.
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.
Wednesday, 17 September, 2014 – 00:00
I’m English. I don’t have a vote in tomorrow’s Independence for Scotland vote. If I did, I’d vote that they are thrown out of the Union, that all Scots are sent back across the border, unable to benefit from continued residence in the rest of the UK. I’d revoke the damage including fundamental constitutional change done to England by the Scottish combine of Blair/Brown and Darling.
Friday, 12 September, 2014 – 00:00
Not the best start to Friday to discover that some bastard is promoting illegal copies of my book “Sun Tzu and the Art of Litigation” hosted by Cloudflare on a domain released by Public Domain Registry (PDR) – a company we are already looking at because it is heavily featured, along with GoDaddy, in the latest wave of domain registrations for spamming – all with a .eu address. More in the imminent issue of World Money Laundering Report.
Wednesday, 3 September, 2014 – 00:00
This week: a crazy month when it’s supposed to be the silly season, why e-book sales via Amazon.com are beginning to look like a bad idea and how pop culture makes our lives more difficult by spreading rubbish under the guise of knowledge.
Monday, 18 August, 2014 – 00:00
Is social media turning us into a species akin to goldfish?
It’s taken far longer than expected but as of two minutes ago, “How does that make you feel? Identifying suspicion in money laundering and terrorist financing” with all errata in the body of the book instead of on the more usual scrap of paper is available.
Friday, 4 July, 2014 – 00:00
A few days ago, I started writing a blog called “Taking a punt on ISIS.” The title is a pun (I like headlines that twist language much more than those that scream “Top Ten Ways To…” and then say something utterly banal like “mess up your job application”).
It is often said that there are no coincidences. But unless one believes in some kind of grand-master who manages the minutiae of the lives of all creatures and things on Earth, and beyond, sometimes it is clear coincidences do exist.
Here’s an example.
Friday, 21 March, 2014 – 00:00
Shhhh. “How does that make you feel – identifying suspicion in money laundering and terrorist financing”(1) has gone through final editing and pre-press and is now in proofing (which is a bit of a technicality because it’s been proofed in its final print format several times during production). Looking good to pop out of this final stage later today (tomorrow in the USA) Why “shhhhh?” Now it’s all in someone else’s hands and I’m going to sleep for three days.
Tuesday, 11 March, 2014 – 00:00
Much to my shock, the book has now grown to the point where it has to be reformatted to take account of its new thickness (that is in the number of pages, not the stupidity of the author).
So all the graphics that were carefully sized are now in the process of being resized as part of the pre-production process. Oh, and we’ve got the ISBN numbers but I’m not sure if that means it can be pre-ordered. I’m a bit hazy on the practicalities, partly because I’ve reached the point of doing nothing except writing. If I could have Nescafe’s Blend 37 on a drip, I would. (1)
Ten days ago, I had two chapters outstanding. After writing one of those, now I have three outstanding. Each piece of research seems to spawn at least one more.
Sunday, 2 March, 2014 – 00:00
28 February 2014 – a day I’ll remember – it’s the day my son’s first album was released and immediately (i.e. that day) went to number 3 in the Taiwan music charts.
Looking into suspicion for the new book “How does that make you feel?” with the subtitle of “Understanding Suspicion in Financial Crime”, an important source of material is in relation to stop and search. Add in profiling and predictive policing and it all starts to look a bit like the Tom Cruise film “Minority Report.”
I’m grateful to NatWest for telling me of a possible security breach relating to my “Credit Card Online Service” but there are a couple of factors that don’t quite hang true – aside from the basic one that, like most recipients of phishing mails, I don’t have an account with the target bank.