Software and Systems : critical review

It was in "How not to be a money launderer" that Nigel Morris-Cotterill said that all counter-money laundering systems should be subject to audit. He made it clear: this was a systems audit, not a financial audit; it was an audit that focussed on the awareness and assessment of, and responses to, financial crime risk. And he was equally clear that this was an activity better suited to the minds of lawyers than the minds of accountants. That was in 1996.

Regulators have mandated audits. Accountants have done them. Companies get fined millions of dollars, euros and whatever other currency happens to apply.

Why? Because companies install tech based on the limited information and the representations of vendors who are not specialists in financial crime matters.

This course is not really a course: it's a collaborative review of your policies, systems and controls and the tech that supports them. It's critical thinking, designed to find fault. It's not an audit, it's teaching compliance officers to make sure, as a routine part of their job, that the machines are in fact doing what you think they are, and should, be doing.

External consultants and vendors are not invited: in this course we will equip you to assess the representations and even the findings they make. Why? Because fines and penalties running to millions of dollars are often imposed on companies whose systems did not work as required for periods of years and no one, auditors, advisers or vendors noticed.

A message from Nigel Morris-Cotterill:

Across decades, continents and cultures, I have worked with companies who are setting up or reviewing their financial crime compliance systems. It's tedious. You hear about the "tick box mentality" and why it is undesirable. So here's what you don't hear: compliance is all about ticking boxes. Did we do it, did we do it on time, did we consider the results and change the compliance parameters if necessary? If the answer to all of those is "yes", then there is compliance. It's binary, yes or no, on or off. That's why computers are good at policing compliance: they don't have to make decisions, only to record and act on a fact: one or zero.

And it's why the entire RegTech industry exists - and why things go wrong when tech is deployed to assess risk.

Quite simply, as we see in our course Introduction to the Risk Matrix and Algorithms "There's no big secret: we will show that machines are brilliant at assessing the fact of compliance - does the company do this/does it not. We will also show that algorithmic analysis can never do better than provide a statistical probability that the data it has generates a score that says "look at this.""

With that as a starting point, this seminar will work with your own staff, not vendors or consultants, to do a root and branch review of your approach to financial crime risk and how your systems and technology integrate to protect you or, as too often happens, to put you at risk.

Why?

This is why

Risk is not compliance, but inadequate risk awareness, assessment and response systems are a compliance failure.

This seminar is unique. It bridges the divide between training and consultancy and puts you and your staff firmly in the middle, where you should be.

As a series of cases has shown, when systems, be they human or computerised, are not set up properly, they often remain faulty for year after year, despite statutory audits and periodic reviews by vendors.

Why does this happen? Here's an oblique hint: think of The Bankers' Evidence Acts 1876 and 1879 (England and Wales), the latter being an Act which was replicated across the Empire and even today can be found, amended but not repealed, in the laws of many former colonies and territories.

This seminar can be run over two or five days, depending on the level of involvement and specific structure agreed. It is not an audit of your systems: think of it as assisted learning leading to self-diagnosis.

Together, without any barriers, examine your policies and procedures and how your tech interfaces with them, whether the tech is doing what you think it's doing or what you think it should do and what happens when the tech produces an exception report.

And yes, we'll even look to see if, metaphorically, it's been plugged in and turned on.

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.

Who should attend - Industries: Software and Systems Review (Jobs)

Senior financial crime risk and compliance officers, the tech teams they work with and their own support staff in all affected industries.

Sales teams in regulated businesses and commercial concerns

Relationship managers

Directors

Contract negotiators in commercial concerns

Regulators

Policy makers

Investigators and enforcement officers.

Who should attend - Industries: Software and Systems Review

Which Industries should attend

Senior financial crime risk and compliance officers, the tech teams they work with and their own support staff in all affected industries.

A non-exhaustive list :

Banking

FinTech

Crypto

Insurance

Aid

Construction

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