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You are not my friend. You are a risk.

For decades we have been told that we should address everyone by their Christian or first name, even if we have never met. In the past ten years or so, we have been subjected to the constant diminishing of the term "Friend." It's time to stop this and to return to a world where there are boundaries and where everyone knows where they are. And more, it's time to return to formality in business correspondence and, most importantly, to start to show respect for each other instead of a presumption of homogenisation. Why? Because we need healthy scepticism not blind acceptance of everyone and everything.

Have you ever wondered why targeted junk mail starts with "Dear Peter" or whatever? It's simple: it makes you feel wanted, it softens you up, it makes it feel like you belong.

One of the biggest areas of risk in any financial crime business is "culture."

In this context, "culture" means any sense of belonging be it to a club, a common interest in e.g. opera or hip hop, a religion, a political viewpoint .. anything that makes us feel that we are not alone.

Paul Simon contradicted John Donne, albeit in a song he intended (one assumes) to be ironic: he sang "I am a rock, I am an Island." Of course, the thing about irony is that you don't know it's irony until the statement is proved wrong. Irony is, by definition, retroactive, proved by being retrospective. Arguably, then, Simon was merely being sarcastic.

The fact is that as much as we might want to be that rock, that island, Donne was right: no man is an island.

Donne talked of the inter-connectedness of man, that the death of one diminishes all others and that none is more important than any other. But that does not mean to say that we are all friends, it does not mean to say that we are in some way homogenised. It says we should respect each other, as we are, even if we do not actually know each other.

It is that respect that is diminished by the degree of informality that we are pressed into accepting. It is also that which undermines the basic human courtesies that allow us to keep our distance from others until we feel comfortable with them. Yes, it is that which is the building blocks of financial crime risk management because we should not assume all is good, we should assume all is neutral unless and until proof of good or ill is demonstrated.

We have taken informality into business communication to the point where almost every communication includes a disarming statement, but a statement that is a trap.

"Hello, Jennifer, are you free to talk?" is a common start to a cold call.

The correct answer is usually "who the **** are you and what do you want?" but social convention tells us that this is wrong and so we allow ourselves to be chatted up by strangers who are using our time for their advantage and, worse, doing it at a time that is convenient to them and not to us.

In fact, any message from someone you don't know that starts with your first name and a question is almost bound to be someone who thinks your time is less important than theirs and that your tasks are less urgent than their desire to hit their targets - and who, from the start, has their own specific objective which, usually, they do not disclose until they have drawn us in.

So let's take that into the risk management arena: you know from the beginning that that person is using devices that are tools of persuasion, making you feel connected to them and metaphorically drawing you towards the conclusion he wants. To persuade your people to let down their guard in relation to the possibility of financial crime risk is a seduction albeit one in which, if the correct buttons are pushed, the target is often at least a passive if not willing participant.

The simple fact is that excessive informality, the equivalent of air-kissing people we barely, if at all, know, damages our ability to assess risk.

That's just one tiny factor in the enormous challenges that face those who have a duty to identify and manage financial crime risk. The big ones are elephants that don't fit in the room.


Nigel Morris-Cotterill is a financial crime risk strategist who is not afraid to be blunt. His series of seminars "Understanding Suspicion in Financial Crime Risk Management tours the UK in June 2017. Bookings close 23 May. www.financialcrimeforum.com

Morris-Cotterill can be reached via www.countermoneylaundering.com. He doesn't have a phone on his desk.

Further reading:

John Donne: Devotions upon Emergent Occasions, Meditation 17, 1624.

"No man is an iland, intire of it selfe; every man is a peece of the Continent, a part of the maine; if a clod bee washed away by the Sea, Europe is the lesse, as well as if a Promontorie were, as well as if a Mannor of thy friends or of thine owne were; any mans death diminishes me, because I am involved in Mankinde; And therefore never send to know for whom the bell tolls; It tolls for thee...



Nigel Morris-Co...



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