Understanding Suspicion in Financial Crime.

SUSPICIOUS ACTIVITY REPORTS DEPEND ON SUSPICION

In more than 30 years of law and regulation to combat money laundering, terrorist financing and as time goes by other crimes, one question haunts the industry.

"How do I know if I'm suspicious?"

The answer is as simple as the question, but the route to the answer is extraordinarily complex.

At the heart of everything to do with financial crime is knowledge, belief and suspicion and the greatest of these is suspicion,

Why and how people do, or do not, form suspicion and if they do form it, why do they, or why don't they, report it?

And the questions keep on coming.....

Why do some sectors of the regulated industry report more freely to the Financial Intelligence Unit than others?

How does culture - and "community" - affect the way people view the conduct of others?

Is the current vogue for the release of confidential or sensitive information by people who - mostly - mistakenly think they are whistle-blowers an indicator of a greater awareness of suspicion? If so, why are they not simply filing SARs?

Why do prosecutors and judges have so much difficulty explaining wilful blindness? Or "reasonable cause to know/believe/suspect"

This two day course is specifically for those who must make decisions as to whether others should have been suspicious. That's the "reasonable cause for suspicion" part of law and regulation.

It is to be emphasised that this course does not concentrate on law and regulation. It references laws, of course, but its primary purpose is to examine the cultural, societal, sociological, criminological, psychological issues and more so as to understand this most core of subjects.

Although the focus is on financial crime, the lessons learned will be of benefit in relation to other criminal investigations and trials

The forming, or not forming, suspicion is a product of a decision tree but whether suspicion arises is not a binary decision: it depends on factors that have nothing to do with law and regulation and often nothing to do with facts. This unique course by the author of the only book to explore the subject in detail will lead you through the complexities.

You might also benefit from our course "Introduction to the Risk Matrix and Algorithms"

Nigel Morris-Cotterill explained the basics of suspicion in his 1996 book "How not to be a money launderer". Then he explained how criminals avoid creating suspicion in a widely cited academic paper which grew into a book, "Cleaning up the 'net". He wrote the only book on "Understanding Suspicion in Financial Crime", now in its second edition, and most recently published SAFE WORD: NO, a book on fraud and internet safety for general readership.

Like the books, this seminar takes a practical view of law and regulation and the risks they present to businesses in the financial and commercial sectors and, even, to individuals who engage in transactions with an illegal element. He explains how that is much easier than you might think.

Who should attend - Understanding Suspicion in Financial Crime

Middle managers and above in all disciplines in all companies in relevant industries.

No industries are not relevant.

Investigation and intelligence agencies and such departments in other agencies.

MLROs, AMLOs and their support teams.

Sales teams

Introducers, including independent introducers.

Version A: for prosecutors, FIUs, investigators, customs and immigration officers, intelligence agencies, regulators and the judiciary concentrating on the reasons that suspicion is formed, is not formed and why people often deny that it is formed and a focus on explaining to a Court or Jury issues such as wilful blindness.

Version B: for financial crime risk and compliance officers concentrating on the reasons that suspicion is formed, is not formed and why people often deny that it is formed and a focus on explaining to staff how to recognise and act on suspicion.

Which industries should attend Understanding Suspicion in Financial Crime.

This course is of universal application across government and its departments and agencies and all fields of commerce and industry and the judiciary.

Suspicion of financial crime relates to corruption, environmental crime, fraud, money laundering and terrorist financing.

There are no industries that it does not touch.

There is a growing tendency to create liability for companies that benefit from fraud which broadens the need to understand suspicion beyond the so-called regulated sector.

And the "regulated sector", for financial crime purposes, has expanded well beyond its original targets of banking, insurance and securities.

Who should attend?

You should attend.

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