23 November 2011London and Hong Kong.

The first edition, published in 1996 sold out its entire print run in a matter of months with sales all over the world. The second edition (1988) sold out its print run in weeks. In 2010, an e-reprint was made available for Kindle and Kindle readers on other platforms.

The author, Nigel Morris-Cotterill has since worked on many projects and writes detailed analysis for e.g. Complinet / Thompson Reuters Accelus.

But that is a sideline: Morris-Cotterill is better known as Head, The Anti Money Laundering Network (www.antimoneylaundering.net) where he overseas a wide range of business units in addition to delivering high-level consultancy to a spectrum of sectors.

How Not To Be A Money Launderer was years ahead of the then thinking in relation to money laundering. It pioneered the idea that the primary focus of counter-money laundering strategies should be on risk management rather than compliance, that ticking compliance boxes was not enough. The book talks about auditing and monitoring risk and compliance systems and about hawala, trade based laundering and stored value cards. These, and many more examples have become flavour of the month (or longer).

To read the book where these issues were first brought together and explained, click here

<strong>Table of contents:</strong>

1. What is Money Laundering? 1What is Money? 2Comparing financial crime and other crime 4Counterfeit Currency 7Billy follows Willy 12

2. Who Launders Money? 18

3. What sort of money is laundered? 22USA Mob Rule 22The influence of drugs 24Incas of tiredness, chew one leaf 27Predicate Crime 29Prostitution 30Fraud 34Financial Crime 35Tax evasion 36Customs and Excise Frauds 37Benefit Fraud 41Prescription and Healthcare Fraud 41Housing Fraud 42Counterfeit goods 42

4. Fraud 46Directory fraud 54Employee Fraud 55The stationery scam 55The other stationery scam 57The Nigerian Scam 58Advance Fee Fraud 60If it looks too good….II 65Standby letters of credit 67Mortgage fraud 70Other lawyer fraud 73Fraud in Fiduciary Relationships 74Russians buying cars 75Representative Offices of oversea banks. 77Card Fraud 79Cheque Fraud 83Commercial Fraud 84Internet Fraud 88Other Computer Crime 91A very serious note. 91

5. The Commonalities of Fraud and Money Laundering 93Introduction to the problems of recovery. 94

6. Financial Sector Regulation in the UK 101Action plan for basic internal controls. 112on tracing proceeds of crime…. 114

7. Confidentiality and Secrecy in the Banking and Professional Sectors. 115

8. The Law 139Offences in England and Wales. 141The obligation to report a person suspected of money laundering 143s52 DTA94 144Tipping off 149s53 DTA94 149Drugs Trafficking 151S1 DTA94 151Concealing or transferring proceeds of drug trafficking 154s49DTA94 154Assisting another to retain the benefit of drug trafficking 155s50DTA94 155Constructive Trusts 164Use of proceeds of Drug Trafficking 167s51DTA94 167Penalties 170s54 DTA94 170Investigations into drug trafficking 171s55,56, 57, 58 and 59DTA94 171Terrorism 171The Prevention of Terrorism (Temporary Provisions)Act 1989 171The Criminal Justice Act, 1993, s51 171Offences not related to drugs or terrorism 172Criminal Justice Act 1993 172Jurisdiction (includes international effect) 173ss1-4 CJA93 173Confiscation Orders 174s71 CJA88 (s27 CJA93) 174Proceeds of Crime Act 1994 174Money laundering and other offences 174s93A CJA88 (s29 CJA93) 174Acquiring etc. proceeds of criminal conduct 176s93BCJA88 (s30CJA93) 176Concealing etc. proceeds of criminal conduct 176s93C CJA88 (s31CJA93) 176

9. Money Laundering Regulations 1993 (UK) 178Reg. 2 Interpretation 178Reg. 3 Business Relationships 179Reg. 4 Relevant Financial Business 179Reg. 5 Systems and Training 180Reg. 6 Offences by bodies corporate, etc. 182Reg. 7 Identification in business relationships and transactions 182Reg. 8 Postal Business 184Reg. 9 Identifying third party transactions 186Reg. 10 Exemptions from identification procedures 186Reg. 11 Identifying the applicant for business 188Reg. 12 Record Retention 190Reg. 13 Additional record keeping measures. 192Reg. 14 Internal Reporting Procedures. 192Regs. 15 & 16: Supervisory powers. 193Reg. 17 - Transitional provisions: 194Record Keeping: a practical note 194

10. Creating systems 195Risk Avoidance 196Risk Management 199Awareness Campaign 200Training 202Updates 203Systems design 204Corporate Culture Change 204Systems implementation 206Systems monitoring 208Corrective action. 209

11. Compliance with the UK Regulations 210How do you go about setting up a compliance system? 211Train relevant staff to identify money laundering and in the steps to take if they make an identification 212Create and implement a system for identifying every applicant for business to whom The Regulations apply 213Create a system for retaining the records of identification 214Create and maintain a system for the making of reports to a nominated person within the organisation 215Appoint a nominated person to receive reports and to consider those reports and decide upon appropriate action to take with regard thereto. 215Monitoring 216

12. Money Laundering Techniques 217Airline Tickets 217Gift Vouchers 218Shop returns 218Cheque Cashing 218Lottery/gaming tickets 219Goods 219Cigarettes and spirits 219Anonymous Bank Accounts 220Owning a bank 221Parallel Banking 224Internet Banking 227e-money. 229

13. Recognising the money launderer. 233The “Jeanetic” Theory of Financial Crime. 233Wilful Blindness 241The case of Bank Leu 241Wilful Blindness, part one 242International effect of laws 250Global planning for risk management 252Wilful Blindness, part two 253The rôle of the expert witness 254The Characteristics of the money launderer 255

14 Laundering and the Euro. 258

15. AT RISK GROUPS 270Accountants 270Antiques, Art and Stamp dealers 274Auditors 274Bankers / finance houses/ Building Societies. 276Bureaux de change 279Car dealers 280Doctors / other medical staff 282Private Health Care 283Drugs Counselling. 285Estate Agents 285Insolvency practitioners / Receivers 286Insurance Brokers 291Journalists 293Pawnbrokers 298Priests 298Printers / bookshops 299Publicans 300Regulatory Body Employees. 301School teachers / Matrons 301Solicitors 302Stockbrokers / money dealers 308Trading Standards Officers 309

16 Other Jurisdictions 310Belize 310The Money Laundering Prevention Act, 1996. 310Penalties 311Seizure and Confiscation of Assets: 312The Republic of Ireland 313The Law. in the Republic of Ireland 315Niue 326Slovenia 328United States of America. 330Jurisdiction over the Currency. 330Currency and Foreign Transaction Reporting Act of 1970 334The Bank Secrecy Act 1982. 334Definitions: 335Exceptions to Currency Transaction Reporting 336International movement of currency or monetary instruments 337Identifying the Customer 338Drug Abuse Act 1988 338Record Keeping. 338Loans 338Customer Identification 338The Anti-Money Laundering Act 1993 340Money Laundering and Financial Crimes Strategy Act of 1998 340New York State, Banking Department 342PROPOSED AMENDMENTS TO PART 8 OF THE GENERAL REGULATIONS OF THE BANKING BOARD: 342The Money Laundering Control Act 1986 342United Nations. 344Common Law model. 344Definitions 344Financial institutions and cash dealers to verify customers identity 345

17. Money-laundering offences 346

18.Related Offences 348The Civil Law Model 350Article 2 350Article 6 351Article 9 353Article 18 355

Appendix A: Suspicious E-mail Messages. 358

1. Investment Touting. China Continental. 359Result of InterNic search: China Continental 364Result of InterNic search: StockDepot 3642. Invitation to take part in unspecified business. 3663. Use of third party domain name to give message credibility. 3714. A bundle of messages. 376

Case Studies 457