20210722 Hello world, all over again. Welcome to the new countermoneylaundering.com .

Nigel Morris-Cotterill

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.

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20210614 The place of unthought thoughts.


Today I’m writing about white holes, “The Place of Unthought Thoughts.”

This is not unknown unknowns, it’s about the things we know about but don’t want to know more about, where our quest for understanding reaches the end of our willingness to enquire.

If books, etc. can have “out-takes” this is one of mine, a section that ended up on the cutting room floor, so to speak.

This BLOG/cast includes part of my research into suspicion but didn’t find its way into the book or the courses. It is highly relevant as it explains some of the background to the research and some of the thinking that went into the final (for now) product.



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20210510 Virtual Crime is Real Crime

Hello and welcome to this blog (10 May 2021) which will be emailed as my newsletter and recorded as a BLOG / cast.

Today is the day that the United Nations Office on Drugs and Crime starts a meeting about what it terms “cybercrime.” The meeting will start with a discussion around what should be included within the definition of “cybercrime.”



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20210419 RegTech: Knowledge, Belief and Suspicion and the trap of Wilful Blindness.

I first wrote about wilful blindness in 1996 in my book “How not to be a money launderer” and I said then that it was destined to be the central point on which all counter-money laundering laws would hang. I wasn’t wrong then and I’m not wrong now.

To understand it, we’ll take a quick romp through knowledge, belief and suspicion and then why machines cannot and for the foreseeable future will not be able to identify suspicion.

Blog / cast: https://youtu.be/ImOZ7Uy8PF4



20210330 The big lie: Noo Finance and the confidence trick by FinTechs and regulators.

This is going to make a lot of people very angry.

Sadly, those that are going to be angry are those that have been found out.

Those that should be angry – the consumers who have been misled and the tax payers who have supported the rampant charge into FinTech support by regulators and, even, the banks who have had their business models and even management plans disrupted, in the true sense of the word, by the host of millennial-targeting banks that pretended they were not banks, supported in that subterfuge by regulators – are not going to be angry.



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20210321 – An inadvertent blog

I thought I had nothing current to say, as I’m busy readying myself for the relaunch of Quick To Learn more in a few days. But it was time to write a newsletter, in particular drawing attention to quicktolearnmore.com and a couple of things at financialcrimetraining.com

As I wrote the tailpiece, it turned into an inadvertent article that works as a blog. I’m not going to BLOG / cast it. Here, in its original form including the ads 🙂



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20210318 Case studies update, Quick to Learn More progress, BLOG / casts proving popular

Updates from Financial Crime Risk and Compliance Training and from Financial Crime Broadcasting.



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.

See https://learning.financialcrimeriskandcompliancetraining.com/courses/financial-crime-case-studies-criminal-cases

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20210224 What’s in a name?

Hello and welcome to The Financial Crime Risk and Compliance blogcast with me, Nigel Morris-Cotterill.

This episode is published the 24 February 2021

It is available in text on my blog at www.countermoneylaundering.com.


In this episode:

1. The impending global crisis for small businesses trading with EU customers and suppliers and a shedload of work for their bankers and others.

2. Transferwise becomes Wise. Is it a wise choice?

3. Revocation v repeal: a US crypto company has paid a penalty under a law that doesn’t exist because the US government said it had to.

4. Goodbye blogcast, hello BLOG/cast and the end of the line for our original graphic.

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20210211 Of Bulls and Bias.

Hello and welcome to The Financial Crime Risk and Compliance blogcast with me, Nigel Morris-Cotterill.

This episode is published the 11 February 2021.

It is available in text on my blog at www.countermoneylaundering.com and as a blogcast at financialcrimebroadcasting.com

In this episode:

1 Goodbye Rat. Hello Bull.

2. OFAC’s fuzzy logic

3. [un] conscious bias : it looks simple but it isn’t.

4. How to not make a fortune.

5. Corruption as explained to Sherlock Holmes.

6. The last word on rats and bulls.





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20210127 Radiogate.

Nigel Morris-Cotterill

This is the first blog of 2021 and the first I have released with a newsletter, this blog and the blogcast all on the same day.

In this issue:

Out-going PoTUS and the time-bomb he left behind
The media myth about the USA’s latest legislation
Sherlock Holmes and the money launderers.
London’s financial crime kingpin in the 1700s.



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20210123 I miss gai mai bau…..

I have a newsletter in preparation but there’s stuff still to do. But, sometimes, it’s worth jotting a few notes mainly for myself but perhaps of some interest or use to others. In any case, there’s a thing about writing. If you can’t write what you want, write anything, no matter how random or rubbish, to get the “I’m a writer” part of the brain going. So, here are meanderings (and that bit was written after the rest of the page so it’s worked. Ish). And if you think it’s a waste of your time, stop reading. Or learn the technique because it might help you when…. Read on to find out when.

It all started when I was looking at the visitors’ logs for this website.

Actually, it all started when I got up this morning and wanted something in particular for lunch. That was impossible, and that’s why I was looking at the visitors’ logs.

(There will be no blogcast of this article because it’s got nothing to do with financial crime!)

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20201216 Morris-Cotterill: GOAT – and I can prove it.

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)

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20201221 My end-of-year newsletter : suspicious activity reports; failure to regulate lawyers and more

NMC big beard 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

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20201118 Source of funds, source of wealth and unexplained wealth.

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….

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20201020 Seizures and confiscations.

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.

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202020200927 The FinCEN Files – misleading the public and benefiting from criminal conduct

Sunday, 27 September, 2020 – 06:34

Financial Crime Broadcasting dot com blog casts There is, at present, a state of excitement amongst the media, some financial crime consultants and some politicians in response to what they are being told is public opinion.

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.

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20200825 Busy Bees or Busy Work?

Financial Crime Broadcasting dot com blog casts 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.

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20200701 Wirecard : the FCA’s freezing of assets.

Financial Crime Broadcasting dot com blog casts The announcement without warning that the UK’s Financial Conduct Authority was freezing assets of German FinTech Wirecard has caused consternation.

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.

Here’s why.

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20200618 Of unlocking lockdowns and nasty people: My Newsletter

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….

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20200614 Malaysia can rescue Formula One’s 2020 season. This is how.

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.

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20190828 Reputational risk – first it’s one thing, then it’s another and now it’s both.

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.

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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.
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20180711 On the way to Manila and Taipei, something arises.

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.
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20180606 Rough data is good enough to decide if there is suspicion.

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?

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20171207 The falsely accused contrarian and the bubble people.

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

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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.
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20170830 The Commonwealth Bank of Australia – sickness or symptom?

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 .

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20170808 Nigel’s August 2017 Newsletter

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…

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20170529 The power of auto-suggestion

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…

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20170712 If it’s mundane, it’s mundane. Get over it.

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.

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20160526 Brexit: the young should register to vote – but they should vote “Leave”

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.
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20160115 How DailyMotion.Com profits from criminal enterprise and may be helping terrorists.

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.
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20150821 Recognising when you are clever, and when you are just a smart-arse

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.
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20150804 Putting Hayes where the sun won’t shine doesn’t help Compliance and Risk Officers

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.

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20150710 Geeks for Greeks – solving the Greek Debt Crisis

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.

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20150316 I booked a flight with Etihad Airways. This is what happened next…

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.

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20141126 I just love being right – my new book – Cleaning up the ‘Net – covers Facebook, terrorist threats and profit nicely.

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.

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20140917 Scottish Independence. I’d vote “yes” but the Scots should not.

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.

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20140912 Theft of Sun Tzu and the Art of Litigation

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.

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20140409 On the road, again

Sitting at home doing all kinds of things – including researching and writing both “Sun Tzu and the Art of Litigation” and “How does that make you feel” as well as other work that kept me locked to my desktop for, in total more than a year, I’ve just been re-introduced to the delights of long distance travel.

I was looking forward to it: I used to spend as much as 200 nights a year away from home, often sleeping on a plane between leaving a meeting at the end of one day and just getting to the next early in the morning.

There was even a plan, just for the hell of it, to present a breakfast briefing in Singapore, an evening briefing in Hong Kong, the next morning a breakfast briefing in London and an evening briefing in New York. It didn’t happen. I think I’m pleased.

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20140718 A dark day for Malaysia and her people as lies and counter-lies fill the air.

I was woken in the early hours of this morning by a message from a close friend, who works for an airline and was in Europe getting ready for a flight. “Check out MH17” was all it said. I checked. MH17, a Boeing 777, had been shot down while overflying territory controlled by Russian backed, Russian armed, Russian funded and Russian encouraged terrorists in the Ukraine.


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20140401 Don’t be an April Fool – recognise that coincidences are real.

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.

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20140321 Shhh. I’m sleeping. But not until I’ve said this….

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.

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20140311 How does that make you feel? Tired.

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.

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20140214 Why I love my job.

I’m feeling all loved up this morning and it’s not just because it’s Valentine’s Day. Sitting in my study, looking out across the rooftops of Kuala Lumpur to the Petronas Twin Towers glinting in the early morning sun, the birds chirping (there are no trees so they nest high in the building – about 10 metres away from me) and, because most of the heavy work has been done, the air is clear of both noise and dust from the construction that has turned my part of the city something reminiscent of Hong Kong in the 1980s. Far below me, there’s a Chinese Temple and today is the 15th day of New Year. So far this morning, the glorious melting pot that is central KL has given me the call for prayer from the nearby mosque, the call to mass from the nearby church and the drums and fireworks that are designed not to call but to repel evil spirits as the New Year finally gets underway after two weeks of festival. I’m one of, in global terms, the lucky few who gets to live where he loves to live.

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20140118 Same old smile, same old shit

I have just watched the entire speech by US President Obama given at the US Department of Justice. I watched it with my friend in Paris : both of us watching the BBC until they cut away with only a few minutes to go so they could interview one of their own journalists standing in the cold of a Washington winter. Then we switched to CNN where, fortunately, they didn’t discuss it in their usual banal fashion. Which is good because we were discussing it over an internet phone connection as it was going. He and I have concocted a note together intending that it would appear on both our websites simultaneously. .

20140104 The dangers of “internet-spread”

The recent example of a satirical article ascribing comments to the Pope, and the editorialising that surrounded those comments, is thought provoking and funny – but only if you know it’s a joke. Regrettably, the internet, due to the lack of ethics and honesty, to say nothing of in some cases downright malicious or self-promoting actions, of some users, means that the story has spread far and wide – without the warning that it’s satire.

20131202 Flattery mai non plus

Google flatters me.

Apparently I have a Google + account. I assume some marketing person somewhere, sometime, somehow set it up. I don’t remember anything about it. Nor, incidentally, do I remember actually posting anything to it.

Anyway, in the way of marketing messages, that nebulous body (are they in “the cloud”?) “The Google+ (oh, no space before the + sign?) has sent me what passes for a personalised e-mail (I know it’s not because it starts “Dear” and has my full name).

20131213 Dodgy Due Diligence in Social Media

We, as an industry, are increasingly sold the idea that social media is the first reliable port of call for due diligence: basically, the idea is that if a person doesn’t have, for example, a Facebook or a LinkedIn profile, they don’t exist, that they are inherently somehow lacking in credibility.

The argument is that the opposite is true: that an effective social media presence confirms that person’s existence and presents corroboration of what they are saying.

It’s not as reliable as it seems. And worse, it’s causing a credibility issue for companies.

20131212 – why I’m starting a monthly newsletter for my LinkedIn Contacts

Good morning

I’m Nigel Morris-Cotterill, one of your contacts at LinkedIn. I’m Head, The
Anti Money Laundering Network and I find LinkedIn to be full of “noise”
from hundreds of “likes” of jobs, magazine articles, puzzles and games.

20131129 Hello world! Again

It’s the most basic of tests for IT people: can they make the machine they are working on produce the words “Hello World!” on the monitor or a printer?

And so, as today is the first day of the rest of the life of this website (countermoneylaundering.com), which was the first website we built even before we owned the domain name, it’s fitting that the first words on this blog should be that test.

But it’s not the first time we’ve said “Hello World!” So we’re saying it again.