There is a growing movement - with which I wholeheartedly disagree - for the prioritisation of crimes for financial crime reporting purposes.

I understand and agree with governments and law enforcement having and adopting /internally/ such priorities which should be assessed without regard to fashion and hashtag-driven hysteria.

But it should not be for those working in reporting businesses to be that filter: it's expensive, it requires a deep understanding not of the criminal law, per se, but of what is actually criminal conduct and of that what is actually predicate crime and of that what law enforcement wants to hear.

This morning I came across a wonderful expression that has fallen out of favour: data swirl. Governments should deal with the data swirl, not demand that the private sector do it and then agitate the mix still further.

Counter-money laundering laws and regulation were predicated on the simple fact that everything is information and that that information goes through certain choke points, one of which is funds transfer - at the time primarily banks. At those choke points, information would be filtered for suspicion and only suspicion. It would not be filtered for suspicion of a particular offence (although in the US in particular, some judges went even further than that and demanded it relate to a specific act).

In Trade Based Money Laundering Vol 2, one of my topics is the lack of a clear definition of "organised crime." It is a term of art but it is not a specific offence in most countries, as the book makes clear. How, then, does one prioritise something that is not defined? And, more importantly, if governments are saying they want SARS to be more specific, how does an MLRO report something which is not a crime because it is not defined in legislation?