20150901 The Importance of Being Precise.

20150901 The Importance of Being Precise.

Nigel Morris-Cotterill

There's a serious problem in Financial Crime Risk Management and Compliance: the lack of precision in language means no one knows where they stand.

We can demonstrate it with reference to how a Hillary Clinton supporter, a prosecutor no less, by failing to use precise and correct language, has in fact shown, if her version of events is correct, Clinton's malfeasance and culpability.

From http://abc30.com/news/over-7000-pages-of-clinton-emails-released/964565/

"Anne Tompkin describes herself as the former US attorney for the Western district of North Carolina and said she oversaw the prosecution [of then CIA Director,] Gen. David Petraeus. "The key element that distinguishes Secretary Clinton's email retention practices from Petraeus' sharing of classified information is that Petraeus knowingly engaged in unlawful conduct, and that was the basis of his criminal liability."

This is not sufficiently precise: first, it is diversionary - the issue facing Hillary Clinton is not that she "retained" emails but that she ran a private e-mail server, "clintonemail.com," in breach of US Government rules which require those in her position to ensure that all official (i.e. work related) e-mail is sent and received exclusively from and by government servers.

Secondly, Clinton clearly knew she was using her own mail server, not that provided by the government. So her conduct was wilful. Did she know it was illegal? It doesn't matter because Clinton makes much of her background as a lawyer. It therefore ill-becomes either her or her prosecutor-supporter to argue ignorance of the law as a defence. There is a difference between "unlawful" and "illegal." Unlawful is a breach of a third party's civil rights; illegal is criminal conduct. A prosecutor should know the difference and use the correct word.


Some people have asked why I raise such issues. I could answer truthfully but that would seem arrogant.

Sod it, I'll answer truthfully: it's because I'm extremely good at my job. Scratch that, in the argot of today, I'm f***ing awesome.

This is why: I understand what goes wrong more than I understand what goes right. I do my job by looking for the potential for failure. I ask the one basic question: what can go wrong? I don't expect to be patted on the back, I don't expect people to even understand the risks I am pointing out, just to accept that I'm almost never wrong. I might be ten, fifteen or more years ahead of the risk developing but I'm not wrong.

I'm troubled by the attitudes of those who proudly display this or that certification yet lack even the most basic skills. I don't care if you can recite the law: any Tom, Dick or Monkey can do that. What matters to me is that you take exceptional care in every aspect of your work, that you are willing to stand and fight sales, HR and even the board for what is right. I care that you read, learn, comprehend and act appropriately.

But too many don't. Too many think that it's OK to be sloppy in thought and word. One person posted on LinkedIn that if someone misunderstood her message it was not her fault. She proudly displays her "professional qualification" from a commercial body on her profile name.

Someone posted a message asking for people to say, in one word, what others hoped their customers would first see in them. Most managed to follow the instructions. Several did not. One said "I underpromise and always overdeliver." She might have added "and I ignore instructions and grammar, too."

So let's make it easy: in computer support, there is a term "RTFM." It means "Read the F***ing Manual." If the person writing the manual thinks that it doesn't matter if they understand the stuff they are writing about, and it doesn't matter if the people that are reading it don't get exactly the message the writer intends, then it is not surprising that things go wrong.

Some people accuse me of being a "grammar Nazi." I like that. Why? For the contrary position that I like the idea that "Nazis" are ridiculed: one should always puncture the self-importance of extremists by laughing at, and then ignoring, them. But do I think that effective risk management and compliance starts with excellent comprehension and communication skills? Absolutely.

In World Money Laundering Report Volume 14 Number 3, I discuss how demonstrating a lack of basic skills seems to be a trend on LinkedIn.

I'll be blunt: when clients ask me if a person is or might be suitable for a position, I look at their social media postings. Of course, I look to see what they do and say, but also I look to see how they say it. If you show a disregard for simple instructions, a lack of attention while reading, poor communications skills, then I'm going to say you display traits that will, ultimately, undermine your ability to do the job.

It's that simple.

But I will also identify and dismiss professionally written CVs and profiles: I'm not interested in your window dressing - I want to know what you are really like. Faking it in order to get attention will work: but the attention won't be what you want it to be.

If you use slack business jargon "in this space," "transitioning," "going forward" and so on, I'm going to presume that you have just learned to parrot stuff and don't really understand what you are saying enough to communicate it clearly.

If English is not your first language, I applaud you for your achievements. I will dismiss you if you have learned buzzwords but not correct, clear terms.

I'm going to ignore hyperbole and rote self-aggrandisement: I don't need you to tell me you are "hard working" or "motivated." And I certainly do not want to know that you are currently employed with company A but are "looking for an exciting opportunity." Do you really think that my clients are going to want to engage someone who implies criticism of them to the whole world?

I expect that, in an international organisation, you will have learned improved English. I cringe when I read "usage" when the writer means "use." It's an easy distinction to learn. As I say in the WMLR piece - adding suffixes to words changes their meaning and in English, shorter is usually better.

So you see, I'm not arrogant. I'm frustrated. I was one of the people who developed the counter-money laundering industry. I have a right, indeed a duty, to tell it, as it comes of age some 21 years on, "you've not done well." You've become lazy, sloppy and too easily satisfied with your own poor performance. You think you know stuff because you've learned the law or you have a checklist or a certificate from one of a number of commercial companies that have set themselves up as quasi professions.

No. You don't. The danger is that you think you know far more than you do. You think you can communicate with those within your organisation and you think you can protect the company you all work for.

No. You can't.

If your next employer asks me to give an opinion on your capability, if you fail the basic communication tests, for information in and information out, and if you fail the basic test of following simple instructions, then my answer will be simple and brutal.

"This person does not have the skills and attitudes necessary to protect you or your staff. Do not engage."

So what do you do? Do you get angry at me for writing this piece? Most will. That's fine. You are the very people that this industry does not need.

A small number will say "I didn't realise this. I will work hard to correct these issues." To the second group I say welcome to the world I was instrumental in creating and have fought to protect and nurture for more than two decades. You are the people we need, without regard to some arbitrary pieces of paper. You stand a chance of achieving the ideals of protecting your colleagues, employer and, ultimately, society.

The rest? You embarrass me.