How not to be a money launderer

How not to be a money launderer

Essential Reading for money laundering and financial crime practitioners

The avoidance of fraud and money laundering in your organisation

Nigel Morris-Cotterill

First edition: 1996

Second edition: 1998

Second edition reprint ebook: 2010

Second edition reprint paperback: 2011

The seminal work on money laundering, written from a risk management perspective before it was fashionable, written in clear and plain English for a non-technical audience but dealing with all relevant technical matters and much, much more.

"How not to be a money launderer" was the book that blazed the trail for easy to understand textbooks, in this case dealing with law and risk management so that it could be understood by lawyers, bankers and car dealers, amongst many more.

Before regulators and the Financial Action Task Force cared about hawala, Morris-Cotterill highlighted its risks; before anyone coined the buzzword "trade-based laundering," Morris-Cotterill explained the concepts and abuses; long before countries expressly criminalised sex tourism, Morris-Cotterill explained how to attack the money flows to reduce the incidence of fly-in child abuse; before the concept of a "risk approach" was on any regulator's agenda, Morris-Cotterill presented all money laundering related compliance and avoidance as a risk management issue. And he introduced and explained the risks of laundering through dealers in high-value goods. Right from the outset, he explained that counter-money laundering laws apply to all businesses and beyond, not only those required to maintain risk management systems under various Regulations, etc.

That is just a small selection of the things that first appeared in this book but have since become recognised as norms or standards. Morris-Cotterill wrote the book for a general business readership, not just lawyers and high-level staff in financial institutions: he dealt with compliance in, for example, car dealers and other dealers in high-value goods. So he eschewed complex terms such as "Placement, Layering and Integration" instead creating the alternatives "hiding, moving and investing" - terms which have recently found their way into US government documents.

How Not To Be A Money Launderer was a ground-breaking book that had an extraordinary ability to predate the development of counter-money laundering laws around the world the book emphasised the development of wilful blindness which as "reasonable cause" is now at the heart of counter money laundering laws around the world. The book will continue to do so as the risks and approaches developed in it continue to be adopted.

"The most obvious lesson to be learned is one which goes against the grain of all manner of institutions who think they are too big, too old, to wise to be taken by a fraudster, a money launderer or a negligent employee. No-one is that good." "If I see copies of this book on desks in banks, travel agents and second hand car dealers, I will feel a little more confident that I achieved an objective: to make a complex and worrying subject one which can be understood not just by lawyers and senior managers in large organisations, but also by all those who, but for the understanding they gain, might end up in gaol because they did not realise what the law could do to them. "If you are in any way involved in the ownership or management of any business, this book will show you what aspects of your business need to be addressed."

"A lot of information here" - The Daily Telegraph
"A book everyone in business should read" - Legal Abacus


Where to buy the book


1. What is Money Laundering?

What is Money?

Comparing financial crime and other crime

Counterfeit Currency

Billy follows Willy

2. Who Launders Money?

3. What sort of money is laundered?

USA Mob Rule

The influence of drugs

Incas of tiredness, chew one leaf

Predicate Crime



Financial Crime

Tax evasion

Customs and Excise Frauds

Benefit Fraud

Prescription and Healthcare Fraud

Housing Fraud

Counterfeit goods

4. Fraud

Directory fraud

Employee Fraud

The stationery scam

The other stationery scam

The Nigerian Scam

Advance Fee Fraud

If it looks too good....II

Standby letters of credit

Mortgage fraud

Other lawyer fraud

Fraud in Fiduciary Relationships

Russians buying cars

Representative Offices of oversea banks.

Card Fraud

Cheque Fraud

Commercial Fraud

Internet Fraud

Other Computer Crime

A very serious note.

5. The Commonalities of Fraud and Money Laundering

Introduction to the problems of recovery

6. Financial Sector Regulation in the UK

Action plan for basic internal controls

on tracing proceeds of crime...

7. Confidentiality and Secrecy in the Banking and Professional Sectors

8. The Law

Offences in England and Wales

The obligation to report a person suspected of money laundering

Tipping off

Drugs Trafficking

Concealing or transferring proceeds of drug trafficking

Assisting another to retain the benefit of drug trafficking

Constructive Trusts

Use of proceeds of Drug Trafficking


Investigations into drug trafficking


The Prevention of Terrorism (Temporary Provisions)Act 1989

The Criminal Justice Act, 1993

Offences not related to drugs or terrorism

Criminal Justice Act 1993

Jurisdiction (includes international effect)

Confiscation Orders

Money laundering and other offences

Acquiring etc. proceeds of criminal conduct

Concealing etc. proceeds of criminal conduct

9. Money Laundering Regulations 1993 (UK)

Record Keeping: a practical note

10. Creating systems

Risk Avoidance

Risk Management

Awareness Campaign



Systems design

Corporate Culture Change

Systems implementation

Systems monitoring

Corrective action

11. Compliance with the UK Regulations

How do you go about setting up a compliance system?

Train relevant staff to identify money laundering and in the steps to take if they make an identification

Create and implement a system for identifying every applicant for business to whom The Regulations apply

Create a system for retaining the records of identification

Create and maintain a system for the making of reports to a nominated person within the organisation

Appoint a nominated person to receive reports and to consider those
reports and decide upon appropriate action to take with regard thereto


12. Money Laundering Techniques

Airline Tickets

Gift Vouchers

Shop returns

Cheque Cashing

Lottery/gaming tickets


Cigarettes and spirits

Anonymous Bank Accounts

Owning a bank

Parallel Banking

Internet Banking


13. Recognising the money launderer

The "Jeanetic" Theory of Financial Crime

Wilful Blindness

The case of Bank Leu

Wilful Blindness, part one

International effect of laws

Global planning for risk management

Wilful Blindness, part two

The rôle of the expert witness

The Characteristics of the money launderer

14 Laundering and the Euro



Antiques, Art and Stamp dealers


Bankers / finance houses/ Building Societies

Bureaux de change

Car dealers

Doctors / other medical staff

Private Health Care

Drugs Counselling

Estate Agents

Insolvency practitioners / Receivers

Insurance Brokers




Printers / bookshops


Regulatory Body Employees

School teachers / Matrons


Stockbrokers / money dealers

Trading Standards Officers

16 Other Jurisdictions


The Republic of Ireland



United States of America

- Jurisdiction over the Currency

United Nations.

- Common Law model.

- The Civil Law model

Case Studies



Where to buy

As always: when buying from Amazon.Com beware of Amazon scalpers - companies that advertise on Amazon's own system to sell books for vastly inflated prices. Buy direct from Amazon not from third parties advertising on Amazon's platform.

Nigel Morris-Cotterill's books are available from on-line and bricks and mortar bookshops in paperback and via Amazon group sites in e-book.



© 2014 Nigel Morris-Cotterill
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