Before regulators and the FATF 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.
That is just a small selection of the things that first appeared in the 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 has had an extraordinary influence on the development of counter-money laundering laws. And will continue to do so as the risks and approaches developed in it continue to be adopted.
That is just a small selection of the things that first appeared in the 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 has had an extraordinary influence on the development of counter-money laundering laws. And will continue to do so as the risks and approaches developed in it continue to be adopted.
