Good morning.

I'm sending a brief note because it's been a while since the last one but there is good reason for that.

There have been several developments at www.financialcrimeriskandcompliancetraining.com.

** We've two new courses that are on very hot topics.

These are

Essentials: Value Added Tax including Missing Trader / Carousel Fraud.

Micro-course: Non-fungible tokens (NSTs)

** We've added several cases to the Criminal Case Book including a remarkable case in which a murderer has been charged with insurance fraud.

** We are almost ready to launch the first batch of modules in the new iteration of Quick To Learn More. Primarily aimed that the corporate market, we have returned to our 2002 roots with the tri-modular approach of a compulsory Key Concepts module followed by a jurisdiction module and a module for business areas, which we call "market segmentation." Every page is new and bringing Quick To Learn More back to its former glory as a pioneer in the field of remote learning has not been easy. As time goes by more jurisdictions and more market segmentation modules will be added, with the order to a degree being set by demand.

Quick To Learn More is aimed at front-liners to managers for whom it goes from beginner to intermediate level. It also provides the framework upon which compliance officers, senior managers, owners and directors can build with additional courses from our wider range.

** We've got a new logo for the BLOG / casts (that's new, too!). There are some snatches on YouTube but we don't like the quality after our original has gone through a series of three conversions before it YouTube releases it. Even so, if you want a teaser rather than listening at www.financialcrimebroadcasting.com, feel free to look them out.

Across the world, in almost every country that this newsletter reaches, there is either another wave of the Coronavirus pandemic or some natural disaster.

So it's a reasonably fair bet that, in some way, something is having a negative impact on you.

This is manifesting itself in all manner of strange ways as people within companies seem to be making decisions based on trending hashtags rather than genuine commercial decisions, with the risk that conclusions will alienate existing customers and/ or be short-lived. One of the things I have noticed is the speed with which a new fad spreads - and that is slow compared to the speed with which variations in language are spreading. The pace of superficial change that can have significant consequences is worrying (not, note "concerning" which is one of the rapidly adopted variations and it's terrible English).

There seems to be very little detailed study before changes are implemented: "fail fast" is not a culture that financial services businesses can afford to adopt in relation to financial crime risk and compliance - and yet regulators appear to be encouraging that with a push, by people who often have little real world experience of the things they are regulating, to adopt unproven technology at breakneck speed.

So, please stand back and take stock before implementing changes that can have serious consequences. Don't let tech evangelists push your company into adopting what amount to beta-test programs. Remember that large consultancies trying to sell you integration services are struggling to find contracts: you must be careful that you are being sold what you need rather than what they need to sell.

I say that from the point of view of a technophile. But I'm an old technophile: I don't believe what it says on the packaging just because it claims to be "new." The truth is that there really is almost nothing that is new, only that which is a development of what we had in the 1980s and 1990s. So the cautionary lesson is to set what you are being told against what you already know. And if you don't already know, go and find someone who worked in your IT department 20 odd years ago and find his (or her but that's statistically unlikely) opinion of what you are now being told will be your saviour.

Learn to push back when sales people are pushing you. Ask every question you can think of and refuse to move on until you get an answer that satisfies you. But also listen because we need tech and we need to improve the way we use it. Tech will, in many ways, protect the financial sector provided that it's set up properly. As we know, all too often, the people who design the algorithms and even the basic switches often understand their product but not the customer's business. That's the central message I have for you: look at the tech from the perspective of your business, not look at your business from the perspective of the tech.

Maybe 15 years ago, I said at a banking technology conference that banks must move away from multiple data formats, even from multiple operating systems and databases. I said that banks needed to adopt a common data format and structure under which all parts of the data banks were accessible, even if they were in discrete databases. The tech companies were angry. Most of the banks couldn't see the point. But there is a slow move towards common databases within companies. But it's not a move away from proprietary databases -it's largely driven by companies promoting "big data" - and, of course, promoting their own hardware and operating systems and data formats as the system banks should use, thereby creating a monopoly within a bank instead of an open standard which drives down costs.

These are the things that concern me in our abnormal versions of normal and which, as huge parts of the world return to one form of lockdown or other.

Be safe and well, look after yourselves and those around and you be cautious in your decision making.

Nigel Morris-Cotterill.