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20200202 At last - Quick, the next generation of money laundering training
20200202 At last - Quick, the next generation of money laundering training
Look, I could drone on, pretending that I've written something new but here's a secret - I wrote the "about" page for FinancialCrimeRiskAndComplianceTraining.com. So why re-invent the wheel, or re-write a long document when I could just pretend I'm one of those people who claim to be an expert in my field when most of what they do is copy and paste, or slightly modify, stuff I did more than 20 years ago?
Here it is!
Our story began on 1 April 1994 when a bundle of papers arrived on the desk of Nigel Morris-Cotterill, a solicitor (attorney) in the City of London. It was a public holiday, coincidentally April Fools' Day, but what was in the package was no joke. It contained a copy of The Anti Money Laundering Regulations 1993, an extract from the Criminal Justice Act 1993 which made huge amendments to the Criminal Justice Act 1988 and other important matters and other documents. In his office, with the dome of St Paul's Cathedral peeping through the trees, one thing seemed immediately clear: that day would change the way that the financial system operated - and that most people would find it difficult to navigate the complex requirements of both the law and regulations made under it.
Morris-Cotterill had begun working in a law firm in the early 1970s during his school holidays when he was just 15 years old. What started as a mild interest became a passion. Within weeks, he was appearing in court hearings in Chambers and made his first appearance in open court at just 16, with the permission of the Judge. Over the years he worked in transactional areas including property and corporate work, civil litigation, criminal defence, wills and trusts, family (divorce and children cases), business advisory and financial services compliance. He appeared as an advocate in tribunals, magistrates' and county courts and in the High Court in London. In addition, he was at the leading edge of the use of technology in law firms and became a writer for a number of technology magazines and legal publications which somehow led to a sideline doing PR for tech companies.
The second thing that the bundle of papers showed was that all of those areas of work would give Morris-Cotterill a high level of understanding and provide a unique background for advising on the risk and compliance issues that the contents of that bundle would raise.
Within months, he had, with the consent of his firm, launched a specialist consultancy through which he delivered advice and assistance and training. In 1996, he wrote his first book, "How not to be a money launderer." It addressed things like Trade-Based Money Laundering (which didn't have a name at that time) and explained that businesses should adopt a Risk-Based Approach (which, also, didn't gain traction until someone gave it a name, several years later). You can find out more about Morris-Cotterill and his books at www.countermoneylaundering.com.
In 1997, he launched the "Dirty Cash" lecture series on audio cassette putting education into cars and devices in pockets, long before podcasts became a thing.
At the same time, using the brand "Click To Learn More" which we still own, he wrote content for two e-learning providers and recorded audio for one of them so that lectures could be streamed over the internet.
In 1999 Morris-Cotterill wrote the e-learning content for a company that became part of one of the largest financial services information groups in the world.
In 2002, he designed Quick To Learn More, a name that was created when someone mispronounced Click To Learn More. Quick to Learn More an e-learning system with several unique features:
- it was built around a tri-modular approach with users first taking a course containing an overview of the subject, a module containing the law and regulation for their jurisdiction and a module dealing with risks in a particular business area;
- it was designed specifically for deployment over the internet with very low bandwidth requirements particularly to allow delivery in developing countries. At that time, many businesses - even bank branches in some countries - had only dial-up internet. Morris-Cotterill's design brief was that the system had to run smoothly and quickly even on internet connections as slow as 14.4kb/s. That's unthinkably slow these days but then it was very common, even though systems were rated faster.
- it had to run on older browsers, While travelling for consultancy and lecturing, Morris-Cotterill did a survey of what equipment was available in banks, in particular. Even in advanced countries, the technology at the point of delivery was far, far below that which was in place at head offices. While HR departments were busy specifying products that ran on their new, fast, high resolution equipment, Morris-Cotterill found that many users were using older versions of Windows, older versions of processors, PCs with very little RAM and monitors with 256 colour VGA with a very dotty dot pitch. The end result was that graphics and animations slowed down delivery to the point of frustration and, even worse, where graphics and/or e.g. Flash animations were concerned, small text was impossible to read when incorporated into graphics. The solution was clear: Quick To Learn More would deliver almost exclusively text with lots of white space and tiny, tiny packets to travel the internet. In fact, during the whole life of the platform. the largest packet we ever delivered was one illustration - a graphic of 75kb - the next biggest was our logo at 15kb; and
- it could not have sound - in open plan offices, it irritated people at the next desk or in the next cubicle. The recorded lectures were not incorporated: before podcasts, so far as Morris-Cotterill was concerned, the technology was, for most purposes, dead.
This design ethos meant that, as our competitors scrambled to keep up with the latest tech and fashions, we never had to do that. Except for modifications forced on us by the changes in the scripting language, updates in database systems and server security, we did not have to modify the platform until we retired it in 2018. It ran and displayed properly on every screen and device development without modification, for almost 16 years. That's not strictly true but the failure wasn't our fault: for a few months because of their failure to adhere to standards, Google Chrome and, therefore, Apple's Safari were not compatible with our system, a problem that those two companies resolved with a subsequent, standards compliant, version.
In 2011, Morris-Cotterill produced a specification for a completely new version of Quick To Learn More. Quick 2.0 as it was called never saw the light of day because Quick 1.x continued to meet all requirements. But the 2.0 version was dusted off in 2017 when it was decided that a major update would be needed to take account of changing approaches. Further major modifications were made and Quick 3.0 entered development and testing ready for a 2018 launch. It didn't work as well as we'd hoped : there were both technical and structural challenges that we worked to overcome. Over that time, in addition to developing our own platform, we tested a number of platforms from a wide range of providers but none of them did what we wanted. In December 2019, while still working on Quick 3.who-knows, we found a development that was, coincidentally, almost identical to the work we had been doing but where most of the technical challenges had been solved. With a little bit of fiddling about and a little bit of compromise, within two weeks we had a working product.
That only left content which, because of the long delay, required not only updating but entirely new content on areas that, when focussed on front-line training, Quick had not covered. These were the areas that Morris-Cotterill had delivered lectures and seminars on during the past 25 years but which had not been part of the e-learning system.
That only left one question - when to launch? With something as momentous as what we were by now calling Quick 4.0, a very special date hove into view.
The second of February 2020 doesn't look much - until it's written in numbers. 02.02.2020 reads the same backwards and forwards. If it was a word, it would be a palindrome. Such dates, using so many zeros, come around once in a little over 1000 years. 01.01.1010 was the last one - more than 50 years before the Battle of Hastings - and the next one will be 03.03.3030 - a date that many say will be the other side of a climate change-driven catastrophe. Or in the middle of it.
As always, we aim to make the platform as inconspicuous as possible, to make the entire system usable with only a mouse after users log-in to a course. Within the platform, we are still ultra-light on graphics so that we are not eating bandwidth for those who use mobile networks or, even, flaky wifi and we have stayed away, in the main body of training, from large graphics, animations, streaming sound and video for the same reason. When we do, in due course, produce sound and/or video content, it will be for individual, stand-alone, purposes not part of the main training service. Maybe streamed or podcast content isn't entirely dead, then, but it will never cause a bandwidth problem for users of the primary learning system.
There was one more big change. While the training domain antimoneylaunderingtraining.com had served us well (after all, it does what it says it does) the name is, to a degree, out of date. So we've rebranded it, as you can see, to FinancialCrimeRiskandComplianceTraining.com. It's a bit of mouthful but, again, it does exactly what it says it does.
There were some other quite big things: we decided that the new course structure, including high level courses we call "Master" level, would take us into the area where those who had taken courses would want to announce their achievements. We don't talk about "graduating" because we think that relates to degrees; we don't offer degrees but we can see the attraction of a designation for those that achieve good results across a range of modules. So we are creating the designation Certificate in Financial Crime Risk and Compliance and, when achieved, those who reach and maintain that level will be able to use the letters "cFCRC" after their name.
Lastly there was the question of what to charge for and even whether we should place obstacles to entry. Some training companies like to give the appearance of being a professional body but they aren't - they are, like us, simply businesses.
Unlike us, they choose to use a fancy name* and they also like to layer bills one on top of another. They charge a registration fee (we don't), they charge a course fee (we do, too), they charge an exam fee (we don't), they charge a fee for the issue of a certificate (we don't), they charge a subscription or membership fee (we don't).
Some require that to join their scheme and to take their courses, you must satisfy a pre-test. That is absolutely not the case with us. So far as we are concerned we want you to know and understand what we know and understand - whatever you know, or think you know, before coming to us, there's a place for you on our Learning Ladder. You choose. If you think you've started too high, then just take a lower level course to bring you up to speed. What you learn, when you learn and how you learn it is up to you.
Nigel Morris-Cotterill has presented education and training to all from the most junior staff in small businesses to main board directors of major financial institutions and regulators, in many parts of the world. Now it's your turn to benefit and to do it from the comfort of your own chair.
* What's in a name? Our company name is Vortex Centrum Limited. It's Latin (you'll find quite a few bits of Latin as you read our courses but don't worry - we'll explain it for you). In 1999, we decided to use Latin for the name of our publishing company because it can be understood in many countries whereas as English name would only work in English-speaking countries. There is no direct translation of the name from the Latin to English or anything else. We coined it for our information services business because it's where we and our readers most often find ourselves - Vortex Centrum, the centre of the vortex or, as we intend it to be interpreted, the Eye of the Storm. We've been the online publisher of Nigel Morris-Cotterill's work including Quick to Learn More, since 1999, before the term "New Media" was in vogue.
And with the launch of the new platform and services on 02.02.2020, or if you prefer 20200202, we are proud to be putting ourselves right up at the pointy end, where Morris-Cotterill has always been, leading from the front.
You are very welcome to join us.