Publisher's Synopsis
As of 28 May 2021, this title will go out of print.
A revised and updated edition will be available after that date as an e-learning course at
learning.financialcrimeriskandcompliancetraining.com.
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Suspicion is the single central point of all counter-money laundering systems.
It is also the least understood.The Essential Guide to suspicion in financial crime.
Understanding Suspicion in Financial Crime
Every Financial Crime Risk Officer (FCRO) dreads being asked one, simple, question.
It's the same question every time: "How do I know if I'm suspicious?"
It's a simple question without a simple answer.
Until now.
In "Understanding Suspicion in Financial Crime" Nigel Morris-Cotterill, a former litigation lawyer who has been a counter-money laundering strategist for more than twenty years, analyses legal and regulatory regimes, psychology, social sciences, even metaphysics and pop culture. He draws on a huge range of material from academic studies to regulatory and legal findings, from movies to his own ability to identity and manage far-off risks. He identifies characteristics that encourage or discourage the recognition of suspicion and the filing of SAR / STR s.
The book is non-linear, in "phases" rather than chapters, as multiple approaches are examined in parallel rather than in sequence.
There are surprisingly few overlaps until the moment when a decision as to suspicion has to be made.
This, Morris-Cotterill, says is at the heart of why the question is so hard to answer. Simply, there are far too many and far too diverse starting points - and law and regulation are, more often than not, not among them.
The book is a serious book covering a serious subject but it is written in a simple way. Many readers will have English as a second or third language. And many do not want and do not have the time to dredge through academic terms and management-speak. "Understanding Suspicion in Financial Crime" is a jargon-free zone.
Morris-Cotterill hunts for that elusive answer, the one simple, single sentence that all staff can understand, the sentence that will give the beleaguered FCRO peace of mind, that will mean they do not stand, eyes wide open like a deer in the headlights, hoping for inspiration.
The answer to the question is as unexpected as it is simple, and easy to understand by staff at all levels.
Equally importantly, the book answers the hard questions asked by investigators, prosecutors, judges and regulators: what is suspicion, how is it formed, when it is acted upon (or not formed or not acted upon).
Across the world, cases report Judges lamenting the lack of guidance on these matters, and the lack of an effective definition of suspicion. Now, at last, there is one, drawing on cases and legislation from many jurisdictions, using non-legal sources to provide both context and explanation.
--------------- For more on this and other books by Nigel Morris-Cotterill, and his expertise, see www.countermoneylaundering.com
