Critical thinking in financial crime risk management
Is there a brand of tinned cannelloni that has less salt, is the fabric that says “made in Bangladesh” made from cotton produced in Bangladesh, is the route I’m being told to use going to jam up because everyone else is being sent the same way?
The answers by the way are -
probably: the salt content varies greatly;
almost certainly not: Bangladesh grows less than 2% of the cotton its fabrics industry uses;
often. This is the one that troubles me most, because over the past 50 years or so, the world’s population has followed a path I belatedly warned about in a paper I gave in 1999 - people are conditioned to believe, or at least accept, what they read on a computer screen. It is a theme I returned to in 2015 in the book “Cleaning up the ‘Net, an action plan to combat the use and abuse of the internet for financial crime.”(www.vortexcentrum.com - personalised ebook only)
Academia sees “critical thinking” as a skill, something that can be taught, something that can be researched. I seriously doubt that but I do think it is something that can be learned and to learn it there must be demonstrations of how it is used. If you look up “critical thinking definition” and ignore the computer generated responses, you will find amid more definitions than you can shake a stick at two things that stand out:
1. Many people say that it has developed from philosophy but then refer to mid 20th century philosophers. I disagree, but then again, I would, wouldn’t I? If we see critical thinking as the challenging of orthodoxies, then surely in purely allegorical terms, that takes us back to the Garden of Eden and whether or not Adam should have eaten the apple.
2. Psychologists love talking about it. But the more you read the more you learn they are not actually very good at it. The more they cite a dwindling number of sources, or cite more sources that rely on the same dwindling number of sources, the more they reduce their own critical thinking.
There’s a lesson for you. In a world dominated by similar thinking, injected into your organisation by a handful of favoured training companies that tell you what the regulators want you to know and to do what the regulators want you to do, providing a drip-feed of acceptable, even required, thinking. Is that really increasing your ability to detect, deter and report suspicions of financial crime or is it really just creating a uniform compliance culture which is the equivalent of factory workers who arrive, screw knobs onto gear sticks all day and then go home without regard to quality? Is the job to comply or is it to identify suspicious activity and to respond in accordance with the compliance system?
So, you won’t find the term “critical thinking” appears much in this course because the entire course demonstrates it and invites you to adopt a similar approach, not because it’s an academic subject, not because you will be examined on it, but because it will improve the way that risk and compliance is done, how you approach the drafting of policies and procedures and, most of all, it will encourage wilful and thinking compliance, backed with alertness (that’s probably not a word) to the risks which will improve the incidence of both internal and external suspicious activity reports so that the number of cover-your-arse or even can’t-be-bothered-so-I’ll-fill-in-the-form reports that bung up the works at both the Money Laundering Reporting Officer’s and Financial Intelligence Unit’s operations.
Slogans, buzzwords and acronyms are specifically designed to reduce critical thinking. They are designed to channel the intellect of those who read or hear them in a particular direction, often the direction that someone seeking control wants people to be herded.
Critical thinking has been defined in many ways, some far more pompous than others and when they are distilled, they all come down to what I see as the basic explanation of a critical thinking approach.
More importantly, perhaps because academics have tried to teach it, it has become seen as an academic subject, removed from the daily lives of the rest of us. That has to change.
1. Critical thinking does not mean to be critical of everything but it does mean to question everything.
2. A critique (that word is a noun and should never be used as a verb) is not, necessarily, critical of something: it is a review of it from a critical thinking perspective. When a reviewer produces a critique of a book, that review is of the thesis, the use of vocabulary and grammar and of the ability of the author to communicate the thesis clearly. A critical thinking review can just as easily support the thesis as to reject it.
3. Critical thinking is not the enemy of order, it is not the principle tool of anarchy. Indeed, it is the opposite of those things because it teaches individual responsibility within a socially acceptable framework. But it is the enemy of authoritarianism: when someone says “do this”, it is essential to ask why and to what purpose and to argue against the imposition of arbitrary rules that impinge upon our ability to live our own lives in a manner that is both responsible and free. Critical thinking does not undermine the principles of individual responsibility to ourselves, to others and to society at large but it does undermine the idea that the world is shaped by a small number of persons who have been given, or who have taken, authority in one form or another. The power of the hashtag to drive the media to target a group, an idea or even an individual is an example of how small groups militate against free thinking and a herd instinct can take over.
4. Critical thinking is the enemy of circular thinking: governments and religions say “we need more people” and then say “we have so many people that we need more control.” It is also the enemy of a lack of communication, or the presence of miscommunication, by e.g. government. It also allows us to draw attention to the inadequacies in communication, and even knowledge and understanding, of those who exercise control. For example, in mid October 2025, the UK’s Financial Services regulator, the Financial Conduct Authority, criticised banks saying they do not do enough to prevent fraud. This can only be based on ignorance, produced for political purposes. Banks cannot prevent fraud, they can only interrupt the consequences of fraud. The payment of money is not the fraud: that’s already happened and the bank had no way of knowing it was happening. The payment of moneys is not a phase in the fraud – even that muddles up the distinction between fraudster and victim – it is the result, or consequence, of the fraud. That the regulator does not understand and/or express that shows that even within the Authority, no one is thinking critically.
5. Critical thinking teaches us to find out who is actually in control: this is political, of course, but it is also central to the reason this course exists – compliance. It is ironic that the more managed compliance systems become, the more opportunities exist to circumvent them. For 30 years, I have been arguing in favour of principles-based compliance rather than micromanagement of how compliance is done and in this I mean both internal (i.e. the policies and procedures you set and police within your organisation) and external (the policies and procedures set and enforced by authorities in relation to your interactions with those outside your organisation).
6. Critical thinking is the enemy of authoritarianism: all authoritarian regimes, be they government or driven by groups of agitators or even religions, be they global, national or within small groups, rely on a compulsion to do as you are told. Pol Pot’s regime would kill people if they looked to left or right as they walked in the street. Mao’s regime sent the Red Guard into homes all over the country to search for material deemed subversive. For two years, until Mao concluded that their actions exceeded acceptable conduct, they destroyed books and other written materials, music and even musical instruments. They were armed youth, possessed of a fervour that only ignorance, immaturity and manipulation can produce.
7. Critical thinking does not originate in books but that is where the knowledge and context that are required by critical thinkers is to be found. Increasingly, as the ability to find facts and considered opinion on the internet is systematically destroyed by the use of generative software such as ChatGPT, the world is being split into those that believe what they read on a computer screen and those who have the knowledge and wit to question it.
It is important that you understand that this course does not follow orthodoxies, we do not have any taboos, we will piss some people off because we deny them their dogmas and we will unnerve many who will ask themselves “why didn’t I think of that?” We will please some who will say to themselves "Thank you: I thought I was alone." We will unsettle some who think that the compulsion of fine-grained compliance is the only way that organisations can function and that teaching people to question risk and compliance systems will make them unworkable.
I disagree: if we effectively crowdsource risk and compliance policies and procedures internally, we get a compliance system that everyone accepts and a risk based approach that works effectively, organically and far more cheaply and - something regulators etc. try to prevent - a sustainable system that people can get used to and build into their thought processes and daily activity without it feeling alien.
Often in this course, we will refer you to external resources most of which support our viewpoint or take you back to source material so you can read it for yourself without the filters of guidance notes and regulatory provisions. We don’t aim to be balanced: we aim to redress existing imbalance.
And I answer the question “what is critical thinking” like this:
Critical Thinking is the ability and willingness to think for yourself and to trust your own judgement.”
It is important that you understand that this course does not follow orthodoxies, we do not have any taboos, we will piss some people off because we deny them their dogmas and we will unnerve many who will ask themselves “why didn’t I think of that?” We will please some who will say to themselves "Thank you: I thought I was alone." We will unsettle some who think that the compulsion of fine-grained compliance is the only way that organisations can function and that teaching people to question risk and compliance systems will make them unworkable (I disagree: if we effectively crowdsource risk and compliance policies and procedures internally, we get a compliance system that everyone accepts and a risk based approach that works effectively, organically and far more cheaply and which - something regulators etc. try to prevent - a sustainable system that people can get used to and build into their thought processes and daily activity without it feeling alien).
Often in this course, we will refer you to external resources most of which support our viewpoint or take you back to source material so you can read it for yourself without the filters of guidance notes and regulatory provisions. We don’t aim to be balanced: we aim to redress existing imbalance.
And I answer the question “what is critical thinking” like this:
Critical Thinking is the ability and willingness to think for yourself and to trust your own judgement.”
Nigel Morris-Cotterill is a pioneer in financial crime risk strategies with decades of experience and a raft of papers, books and articles as well as innumerable training courses all over the world. He is the author of the seminal How not to be a money launderer which, in 1996, introduced the concepts of trade-based financial crime, the risk based approach and many more.
This course runs for two days and by its nature it can only be held in-house. You can run it onsite, offsite or at a residential retreat. The course is in English. Delegates will be provided with reading material in advance and on the day a workbook for taking notes. The format is part-lecture and part workshop. Fill in the enquiry form for more information.


