
Books are like buses: there'll be another one along in a minute.

People ask how it is that I am churning out so many books in such a short time. This is how, and why.
I started work in a law firm when I was 15, during my school holidays. I learned far more than the practice of law: I learned the power of knowing where to find information. As today's internet slides into chaotic mediocrity, search engines are rapidly becoming worse than useless: they are unfiltered repositories of recycled, superficial or incorrect information.
The danger is that knowledge becomes weakness.
Search engines and computer generated material (falsely called "Generative AI") are a significant part of the problem. So, sadly, are social media sites such as LinkedIn and media sites ranging from former broadsheets, through vertical market magazine sites to blogs where quality is secondary to gaining eyeballs.
When I moved from legal practice to my own dedicated financial crime risk strategy consulting and training company, I decided that I would make a break with industry norms: as I learned, I would make my notes into articles. Some would be sold, some would be free and some would be used in conference papers. And, of course, I would keep some in reserve for training and consultancy.
In addition to face to face training, I also launched, in 2002, Quick To Learn More, for online e-learning.
In 2024, I closed Quick to Learn More. The content had grown to the point where I could no longer reliably maintain it up to date. This had become impossible because of the pace of legal and regulatory changes in all jurisdictions. And sales were not keeping up with the cost that would be incurred if I created a team to do it. The domain name is one of the almost two dozen iconic domain names I put up for sale last week as part of an overhaul of my personal interests.
What all of this means is that I have an enormous volume of material, of knowledge, available. However, as most of my peers are finding out, ageism and superficiality, to say nothing of the regulator-driven obsession with compliance at the expense of risk (leading to a global de-skilling of those in e.g. money laundering reporting officer functions) is making it extremely difficult for those with the most knowledge and experience to find consultancy gigs and, even, short training contracts.
Mediocrity and tunnel vision are standard operating procedure. People who don't know what they don't know are making purchasing decisions based upon a knowledge-base that has been dwindling for more than a decade.
Many of my peers have simply given up. They are, mostly, resentful, because they know they have much to contribute, much that can guide and protect organisations, but the need for that is not recognised or, even worse, it is dismissed.
I haven't given up. I can't. I am too competitive. I don't know when I am beaten. I'm not thrashing a dead horse, I've changed horses: I'm determined to provide value by any means possible, be it through interviews for podcasts, through my own YouTube channel at FinCrimeTV, through World Money Laundering Report and through The Financial Crime Forum.
It's almost perverse: the more difficult it becomes, the more the need to educate, not merely train, becomes an imperative.
The more companies don't buy consultancy and training from the truly experienced and expert, the more I feel the need to bypass those decision makers who are buying the familiar and/or cheap and go direct to those who, perhaps, I can help shape the return to the question of financial crime risk and compliance to its roots, to remind everyone of the prime objective.
In the late 1980s and the early 1990s, there was a global mobilisation of a way of thinking: that the way to reduce crime committed for profit is to take away the profit. The way to do that, it was decided, was to identify those who may be involved in dealing with those profits, prosecute them and confiscate the profits and, even, anything those profits had been invested into.
A whole new vocabulary was created, or coopted from other areas of law. We got "proceeds of crime," "commingling" and "predicate crime" and, of course, the persistent despite being discredited "placement, layering and integration" which I replaced with "hiding, moving and investing", and which, I'm pleased to see is quite widely used. We also got "counter-money laundering" whichhas largely been replaced with "anti-money laundering" , no matter how linguistically inaccurate and therefore confusingk the latter is. But the world of financial crime doesn't respect language: there are "red flags" which are not and the bizarre "hawallas".
Nigel Morris-Cotterill is at www.countermoneylaundering.com and on LinkedIn.
The real problem is that the primary focus has been eradicated.
The original obligation placed on financial services businesses and others was to identify suspicious activity and to report it, a crime reduction strategy that makes perfect sense because it relies on information about customers and their money passing through choke points where identification and reaction to it is simple compared to trying to find the same information in the dust-storm of society's criminal activities.
People wanted to help. People wanted to prevent crime. Governments used drugs trafficking and organised crime as diversions when the press threatened to publish a negative story about policy or a politician.
There was a ground-swell of opinion that said "yes, let's all have a go. When we see something, we'll say something."
But that enthusiasm has been cancelled by ever more complicated, ever more expensive, ever more intrusive and micro-managing and ever more politically motivated requirements under the guise of compliance. It often seems as if the prime objective of the regulatory regime is to set up companies for failure so huge penalties can be imposed, in part at least to fund the very regulators that are deciding on those penalties.
It takes a special mindset to get up every morning and to go to work knowing that someone, somewhere, in a complex organisation will have done, or not done, something that could result in your own future being cancelled either by regulatory action or even criminal prosecution - and that there is nothing you can do to protect yourself because the bosses deny you the authority to make decisions in the best interests of the company because, if you do so, it will upset marketing and sales. So they get a seat at the big table while you get the office down the hall next to the toilets and the smoking room. They come out of meetings laughing and back-slapping on their way to a boozy lunch to which you are never invited. And the single most important thing you should have control over has been taken away from you.
It's more than 25 years since HR departments gained control over training budgets and the decisions over what training would be allowed. And for many staff, their training allowances are soaked up by gaining certificates from a tiny number of dominant companies that have a policy of presenting only conformist training because their own commercial interests depend on close relationships with regulators. Low grade internal trainers collect material from paid-for courses, extract what they think is relevant and reduce carefully constructed two-days courses to, maybe, two hours for the bulk of the staff. They do not have the knowledge required to answer questions from those attending.
Critical thinking and original thought are not only discouraged, they are counter-productive as certifications depend on demonstrating an ability to come to the approved conclusion. An entire industry exists to provide courses or cheat-sheets to cram for those formulaic tests.
So, to my books.
It is clear to me that all the above factors have resulted in a situation where I, and those like me, will never again get the volume and price of training that allows us to earn a respectable living from our efforts. Many of us also recognise that our days as consultants are numbered or, even, behind us.
The plethora of podcasts militates against quality - I recently heard one featuring someone who was, basically, reciting things I have written about Trade Based Financial Crime and why we should not talk about Trade-Based Money Laundering - that was a person who, launching a consultancy only a few months previously, included the phrase "I know more about Trade Based Money Laundering than anyone else out there". Contrary to the old saw, imitation is not, in today's world where everything is available to everyone all the time, a sincere form of flattery: it's an insincere form of commercial underhandedness.
My books bypass that, for those that are interested in gaining knowledge and skills without having to go to HR to get approval for training, or through a board that buys in consultancy to improve marketing but does not invest in financial crime. They usually fit within the "no approval" expenses limit and even if they don't approval for books is usually signed off by a line manager, not by HR. In this way, they also bypass the current problem that financial crime budgets - including staff and consultancy time - are diverted to the perennial hunt for automation of the compliance function and the snipe of automation for financial crime risk.
Books are not quick to write but they are a lot quicker when there is a wealth of research, previous writing and a capacious memory as a starting point.
And that's my advantage and it's why I am able to produce books at a rate that surprises many: I already have the concepts, the structure and the essential elements - those can be reviewed and updated quickly. Some, like Cutthroats and Brigands, are completely new but apply the knowledge going back into my days of legal practice to be able to look at a solution for one of the causes of stock market crashes and the resulting crises. Others, like Cleaning up the Net, the second edition of which will, hopefully, appear later this year, originate in and bring up to date the work I did in writing computer programs, working on expert systems and on crime committed over the internet in the 1980s and 90s. The Trade Based Financial Crime books, Volume 2 of which will appear within the next few weeks, are helped by the fact that, in legal practice, I advised businesses on creating some of the activities that are now (but were not then) illegal, spending my time in grey areas of commerce.
SAFE WORD: NO strips away all the buzzwords and eye-catching names, such as pig butchering, a name which is extraordinarily inappropriate and should never be used. It is designed to encourage conversations within families, friends and colleagues to help identify fraud before it happens, because I disagree with the ex post facto approach of making banks pay for the losses by customers who have no moral hazard if they do not pay attention.
Yet I am not simply repeating information and approaches that are 30 years old; what I write is material accumulated, revised and rethought over 30 years, laden with context and nuance and approached from multiple perspectives. And when it comes to context, I am often as much a historian and philisopher, to say nothing of futuroligist, as I am a financial crime specialist.
It's why I can see through the noise and adopt what is, basically, an engineering approach to the problems we face: while others are, figuratively, fussing about the colour of the car I'm taking it apart and using the minimum number of parts to produce something simple and effective. I suppose that's because my heroes include my father and Colin Chapman. To be fast, add lightness, to paraphrase Chapman.
And it's why the final words of Ayrton Senna to Prof. Sid Watkins resonate so strongly with me: "there are certain things over which we have no control. I cannot quit, I have to go on.”
The books are my way of making good on the promise I made to myself when I first started in law: it's not about me, it's about helping people.
So, while I wil take consultancy and training contracts if asked, and if the fee is enough, I will no longer be spending time seeking out such contracts. If the world wants to once more beat a path to my door, that would be nice but I'm done with the passive rejection that characterises the results of marketing efforts of me and my peers.
The books are there to help, if people want it, even if their route to knowledge is blocked by companies or internet searches. They are there for people who want knowledge to be power, not a weakness. For those who want to think, to understand, not to unthinkingly repeat.
There are four or five books left to be produced before the end of this year. And then my work will be done, except, perhaps, for World Money Laundering Report, FinCrimeTV and The Financial Crime Forum. But they don't take up much time.
What will I do then?
There is, of course, a plan. As usual, it's flying in the face of current convention, but you'll have to wait to find out what it is. A handful of people know and they are sworn to secrecy. In the words of Monty Python, "now for something completely different".
There will still be time - and the passion - to work with those who remember why we do what we do, to remember the prime objective and to work towards it, be they in governent, regulators or in regulated businesses.
The prime objective is reduce financial crime, not simply to spend our lives stressed over a compliance regime that actively obstructs attempts to achieve the prime objective.
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