Why I want the Government to commission an independent review on the effectiveness of present drug policy

The present Government policies on the use and possession of illicit drugs have failed utterly.

As a former detective in the Metropolitan Police, I saw at first-hand how the policies of criminalising people for possessing and using proscribed drugs resulted in wholly discriminatory and socially-excluding enforcement, whereby the young, the marginalised and black communities were targeted, while the white middle-class users of illicit but socially-accepted narcotics were ignored and allowed to continue unmolested.

More to the point, as an active detective focusing on financial crime and money laundering, I realised that by insisting on enforcing the policy, drug criminalisation was helping to pour a torrent of raw cash into the pockets of organised criminals. The more we criminalised the problem, the more money the drug pushers made, while the resultant costs of crime escalated.

It was the most futile and ridiculous policy, but no-one had the courage to challenge it publicly, because politicians on both sides of the House of Commons were scared to engage in a real debate, for fear of alienating the opinion forming leader writers in the scaremongering media. The Home Office too had set its mind against any form of debate, and indeed, any informed person in a position of public authority who has dared to challenge the status-quo, finds themselves being marginalised. Professor David Nutt is a recent and classic example.

It was when I became actively involved in the issue of interdicting money laundering, and seeking to prevent the profit flows from the narco-trade, that I began to realise the real truth. The anti-money laundering laws were routinely flouted by the banks, because the flow of drug money was so important to their bottom line. Frankly, without the drug trade, many medium-sized banks around the globe would have gone out of business years ago.

in the UK drug cash is generally calculated by HMRC to be in the region of £6.5 billion, annually. It is only when you appreciate the size of the narco-cash flows that you begin to get a handle on just how big and how widely extended illicit drug taking is. Most children at our schools have experienced drug sales taking place in their grounds. Many of them have taken drugs during school time. At university, it is almost a sine-qua-non that drugs are routinely available in every hall of residence, depending on your narcotic of choice. Many young people prefer to drop Ecstasy prior to going out because pills are cheaper than the alcohol they would have to buy at the club.

This is one of many reasons why the so-called war on drugs is an abject failure and continuing along this road of criminalisation is a hugely expensive waste of valuable police time and resources.

That is one of the many reasons why we urgently need an evidence based health focussed approach to drug policy and for the decriminalisation of drug possession, and why I am proud to be associated with the efforts being made by Law Enforcement Against Prohibition (LEAP) to promote this outcome.

At last, a real role model for young women!

A remarkable piece in the 'Times' today by a schoolgirl called Aneesah Siddiqui.

Ms Siddiqui is 15 years old and a pupil at Elizabeth Garret Anderson School in North London, and she was one of the young women invited to go to Oxford University and meet Michelle Obama.

She says; '...before Wednesday, Oxford University was totally beyond my aspirations. I knew about its elite status, but I believed that, because of the expense, I would never get there...'

Mrs Obama has shown this young woman how wrong she was.

Michelle Obama captivated her young audience, speaking not with the voice of the wife of the most powerful man in the world, but as a high-achieving black woman from Chicago, who thinks that to be intellectually smart is to be cool, who believes that to aspire to the best that is within you is the way to achieve, and who believes that anyone can acquire the glittering prizes if they want them enough.

Ms Siddiqui says this; '...I finally met my role model...when she was delivering her speech, I was transfixed...I couldn't believe she cared so much about my school in Islington...'

This young woman has experienced her Damascene moment. '...As I asked my question, she made me feel so confident that I forget there were cameras in the room...she made me forget my fears...She said we were all future leaders and must start now...'

We should be truly grateful to Mrs Obama that she has this ability to connect so closely with young women standing on the verge of choosing their future direction in this world. This woman has managed to find a way to finally provide a real role model for young teenagers who could so easily be swayed in other directions and away from the hard path of acquiring education through real scholarship.

This is the real point - education is not easy to acquire, it involves hours of long, hard private study, and the time spent in the classroom should only be a beginning, an initial chance to observe a structure on which to build a greater edifice of self-imposed learning. Education for its own sake is worth investing in, Ms Siddiqui has already decided to choose the hardest 'A' levels she can undertake, maths, physics and biology, and what's more, she has inspired an existing student to mentor her in her university application.

We need more women like Michelle Obama. Our children are surrounded by distractions that hold out the poisoned apple of the lure of celebrity with its tawdry moral values and its cheapened distorted images. It makes such a change to hear a woman throw down the challenge of the path of education, instead of peddling trashy stories of '...my mental torment because I have big boobs...' or "... 'I spend my waking hours thinking of Pete', says Jordan..."

This kind of junk, which overflows off the shelves of our newsagents, and fills the front pages of every web search engine with up-to-the-minute exposeés about Cheryl Cole, merely cheapens the world of young women and offers nothing in the way of motivating them to aspire to higher opportunities. These publications exploit their readers who do not realise that they are being encouraged into dumbing down, rather than searching for the best that is within them. There must still be more teachers and lecturers out there who have not forgotten what real study can do for a young enquiring mind!

One thing is certain. Mrs Obama has enthused a whole class of young women from an Islington school. She has fired up the imagination of Ms Aneesh Siddiqui, and her enthusiasm will not be tamed. Listen to her last words ;

'...Before I met Mrs Obama I thought that I would have an ordinary job. But now I want to be something that really makes a difference in the world...If I hadn't met Michelle Obama, you would probably have never heard (of me). But now - just watch this space..!'

Managing the new fraud risk - Towards a new Tower of Babel!

I was invited to a seminar at the London School of Economics this week. The Mannheim Centre had invited the new Commissioner of the City of London Police to address the issue of '...The role of the private sector in the future of national policing economic crime capability...'

Frankly, the content was unremarkable in many ways, I mean it's not as if it's the first time we have discussed the possibility that private sector assets could be used more effectively in providing fraud investigative services, the results of which could be handed to the national prosecuting agencies for further action.

At a time of dwindling resources and severe cut-backs in publicly-funded resourcing, I am firmly of the view that the investigation of most fraud perpetrated against the commercial sector should be the responsibility of the businesses themselves, and that the police should be used almost exclusively in cases where there is a major public interest at risk or where the investing public is being fleeced.

I say this because in so many cases, a significant amount of fraud in the commercial world takes place because those responsible for the prudential management of their business affairs either refuse to spend the money necessary to implement truly effective anti-fraud measures, such as computer system protection; or they simply fail to undertake normal precautionary measures designed to protect themselves.

One example is the simple precaution of ensuring that proper checks are carried out on the provenance and the solvency of their new customers. All businesses are required by law to demonstrate a high level of what is called 'Know Your Customer' due diligence, before taking on a new client, but very few of them do very much more than the most perfunctory checks before undertaking business transactions. If you don't believe me, look at the number of major financial services businesses which have been required to undertake hugely expensive KYC remedial reviews after a regulatory inspection, because their extant KYC information was insufficient.

The other reason of course is that the financial services industry is itself one of the greatest committers of wholesale fraud against the public. When the banks can calmly announce the setting aside of a sum not far short of £6 billion to recompense the victims of their latest so-called 'mis-selling' scam in PP insurance, an activity that would be called 'institutionalised fraud' in any other walk of life, but for the identity of those committing it, it seems reasonable that they should bear the financial responsibility for funding the means of investigating other frauds committed against them. But this was not my primary worry!

What did provide me with the greatest degree of concern however was the emphasis being placed on the direction in which the future investigation and prosecution of fraud will take. This should not be taken however to mean that there are no plans for component bodies or other agencies whose input will need to be considered, taken into consideration and consulted in the future.

The City of London police has become the ACPO (Association of Chief Police Officers) lead for economic crime with responsibility for setting what is called a national policing strategy in response to what the National Fraud Indicator Report assesses amounts to £38 billion annually. This report is published by another agency, the National Fraud Authority, which is an executive agency of the Home Office. The NFA transferred from the Attorney General's Office to the Home Office on 1 April 2011, and it apparently 'works with the counter-fraud community to make fraud more difficult to commit in and against the UK.'

As well as the National Fraud Indicator Report, we have the annual UK Threat Assessment and the City of London Police responds to that through its Economic Crime Directorate. The ECD comprises over 200 staff split up into dedicated fraud investigation teams, a Cheque and Credit Card unit, a Money Laundering Unit, and Asset Recovery (Confiscation) Unit and an Overseas Anti Corruption Unit. At the same time the ECD provides officers to a multi-agency Dedicated Cheque and Plastic Card Unit (DCPCU) which is funded (ironically) by the banking sector.

The ECD has a remit to enforce, prevent, disrupt and investigate economic crime at all levels nationally. It claims to have close working relationships with all related agencies including the Serious Fraud Office, the Financial Services Authority and the Serious and Organised Crime Agency. How much longer these relationships will last is a matter of conjecture as we hear that the SFO is about to be split up, with its prosecuting arm being merged with the Crown Prosecution Service, although even this is not clear, coming after a stop-start plan by the Home Office to create a new National Crime Agency incorporating the UK's main economic crime agencies, into which the SFO's intelligence function would be merged.

However, other agencies have lobbied hard for exclusion. Last year the FSA's enforcement division was the first agency to escape incorporation into the new body. Earlier this year reports suggested the OFT's criminal enforcement division would not be included either. An increasing body of opinion is growing in support of the SFO remaining independent.

The City Police have also been commissioned and funded by Government as part of what we were informed was a '...Strategic Review of Fraud...' to create a National Fraud Intelligence Bureau, designed to record millions of records on fraud reported to the national call centre called 'Action Fraud', and the City Police are in discussions with Her Majesty's Revenue and Customs as well as the Department of Work and Pensions to record all public sector fraud intelligence.

The Commissioner acknowledged that there will have to be more discussions with Regional Asset Recovery Teams and Regional Intelligence Units to overcome regional jealousies.

Throughout the entire presentation, I never once heard the Commissioner utter the magic words, 'Arrest' 'Charge' or 'Prosecute'.

Oh there was lots of well-meaning and contemporary jargon about 'liaison', and 'consultation' and even 'multi-agency approach'. But, in the end, what came across so clearly was just the enormity of the project that, for whatever reason, this country has finally carved out for the investigation and prosecution of fraud.

Those of us who used to investigate and prosecute major fraud in the old days remember how hard it was just to persuade the old DPP's office to charge a foreign criminal. Talking to the Department of Trade and Industry was just a waste of time, and they were the only people we really had to share information with. Now, this new 'alphabet soup' of agencies, with competing agendas, and all needing to be consulted, means that even less will be achieved than before.

These new agencies will merely become even more hurdles to effective anti-fraud action, they will simply become a huge 'talk-shop', a massive, unwieldy 'Tower of Babel' , all competing with each other for resources, all struggling for primary status, jealous for promotions, keen for foreign travel to even more conferences, work-shops, and seminars, while all the time, the financial sector will continue to fleece its clients with even more mis-selling activity and other kinds of financial wrong-doing.

How do I know? Well I asked the Commissioner whether his new vision of the future involved taking on the biggest fraudsters in the Square Mile, and focusing attention on the major retail banking groups and their £6 billion set-asides to cover their fraudulent activities.

His answer was to shake his head and say that such work would continue to remain with the traditional City Regulators and that his new monolith did not anticipate taking on the banks or the other financial institutions..

Well, that's alright then!

“…Lies, Damned Lies and US Treasury Statements…”

Daniel Glaser is a deputy assistant secretary of the United States Treasury for terrorist financing and financial crimes. He also heads up the US delegation to the Financial Action Task Force.

On 28^th February 2008, Complinet reported the latest finding of the FATF regarding Iran. Complinet has reported how the new finding has not altered the world advisory situation with regard to Iran from the previous finding in October 2007. International banks are still encouraged to apply enhanced due diligence when dealing with Iranian institutions.

Nevertheless, the FATF went to great pains to acknowledge that;

“…Since its October 2007 Plenary meeting, the FATF has engaged with Iran and welcomes the commitment made by Iran to improve its AML/CFT regime… Iran is encouraged to continue its engagement with the FATF and the international community to address, on an urgent basis, its AML/CFT deficiencies...”

The finding reflects the fact that the Iranians have taken significant steps to cooperate with the FATF, they have attended a meeting in Paris in January 2008 when they presented their AML programme to the representatives of the FATF, and answered a wide range of questions; that they have subsequently passed their first law dealing with AML issues, and that they have continued to liaise with the FATF, as requested.

The stated finding of the FATF is clear, unequivocal, and makes an open statement of their deliberations.

So, it is legitimate to ask why it is that Daniel Glaser, one of the delegates to the FATF, when asked to comment upon the latest findings of the FATF Committee, of which he was a constituent member, did not report the findings in an equally clear, unequivocal and open manner.

In responding to a question posed by the New York Sun, Mr Glaser is reported as having given answers that put a wholly different slant to the story. The Sun writer states;

“…American officials saw the FATF's statement as a victory in their financial war against Iran. "It was a great result," America's chief envoy to the task force, Daniel Glaser, said in a phone interview from Paris. "What this action does is call upon all countries in the world to inform their financial institutions of the significant anti-money-laundering financial risk Iran represents. As a result of this action, financial authorities around the world will be requiring their financial institutions to conduct enhanced scrutiny on Iran-related transactions."

Mr. Glaser, who is a deputy assistant secretary of the Treasury for terrorist financing and financial crimes, said the FATF's action was more robust than a warning…”

Daniel Glaser has made no secret of his support for the policies of his US Treasury boss, Stuart Levey, whose openly-stated ambitions are to cripple the Iranian economy and to bring the Iranian nation to its knees by fomenting a popular revolution in that country. Mr Glaser’s telephone conversation with the New York newspaper clearly enabled it to observe;

“…In a move that could cripple Iran's banking sector, the world's premier anti-money-laundering body warned its 34 member states yesterday to advise their banks of the risks of doing business with Iranian banks, citing worries about the Islamic nation's financing of terrorism…while the Paris-based Financial Action Task Force suggests only a warning, the seriousness with which the world's banks will respond to its official statement has the potential to starve Iran of much of its legitimate capital…”

An FATF official who has asked not to be named has confirmed that It is a convention of the FATF that all members of any committee are jointly bound by the agreed statements which are published in their name.

It is not considered to be a proper course of action to make any other statement which might give a different interpretation of what is reported in their name. Individual members are expected to report findings fairly, giving full status to the reported communiques issued by the FATF.

In light of this statement, it is legitimate to ask why Daniel Glaser has found it necessary to be so outspoken, indeed, so triumphalist in his comments. Why did he deliberately choose to ignore any of the positive comments made by the FATF, why has he continued to seek to damage Iran by his comments? He is a co-chair of the committee which is sitting in judgement on Iran and it may be thought that it is entirely improper for him to behave in this way.

His actions could have a significant impact upon the due process within which the FATF itself is seeking to engage. It could conceivably lead the Iranian delegation to legitimately ask whether they are likely to receive a fair hearing, when the co-chairman behaves in this manner, a situation which would paint the FATF in a very bad light indeed.

It is also legitimate to ask which masters Mr Glaser is seeking to serve by behaving in this egregious manner. His actions can not serve the long-term interests of the US, after all, the Bush administration has literally only months left to run. The US Presidential hopeful, Barack Obama has already said that if elected, he will engage in diplomatic discussions with Iran.

It is beginning to look as if Mr Glaser realizes that time is running out for his poisonous policies towards Iran, and those who command his real loyalties, and that his actions betray his true allegiances. It may also be felt, more importantly, that such a realization could bring the FATF itself into disrepute, if it became more widely perceived that influential committee members were intent on serving their own agenda, and not the agreed agenda of the Financial Action Task Force, to which end they have been appointed.

Even more disinformation from the US Treasury

The FATF announced today (28^th February 2008) that it does not intend to take any further AML/CTF interventionist action against Iran, following the publication of its earlier notice in October 2007.

The FATF notice states;

“…Since its October 2007 Plenary meeting, the FATF has engaged with Iran and welcomes the commitment made by Iran to improve its AML/CFT regime. Consistent with its Statement on Iran, dated 11 October 2007, the FATF confirms its call to its members and urges all jurisdictions to advise their financial institutions to take the risk arising from the deficiencies in Iran’s AML/CFT regime into account for enhanced due diligence. Iran is encouraged to continue its engagement with the FATF and the international community to address, on an urgent basis, its AML/CFT deficiencies...”

The FATF specifically recognizes therefore the commitment made by Iran to improve its AML regime and encourages it to continue the same. The FATF had the power to impose other sanctions against Iran, but because of its open and transparent cooperation with the FATF, it has chosen not to alter the existing situation, and will continue to work with Iran to remedy all deficiencies.

However, this has not satisfied those officials in the US Government whose ambitions are to harm Iran at every possible opportunity.

Complinet has published a number of articles recently dealing with the impact of US Treasury behaviour on the Iranian banking community, both in the UK and elsewhere.

To recap, the US is deliberately engaged in actions designed to bring significant pressure on other banks and financial institutions, to encourage them to cease any form of financial activity with or for Iranian banks, anywhere in the world.

The source for this policy decision emanates from an office within the US Treasury called the Division of Terrorism and Intelligence, which is headed by Under Secretary Stuart Levey.

Levey has made no secret of his ambitions to bring Iran to its knees, financially and to destabilise its internal economy to such an extent that it will force a popular revolution to overthrow the present government in Iran. A recent quote from the Kansas City Star states;

‘…Washington has boasted that the US and existing UN sanctions, have taken a significant toll on Iran’s economy, particularly on its unemployment and inflation rates and raised pressure on the Government…’

To facilitate his ambitions, Levey and his satraps are always willing to spin news stories and put false and misleading interpretations on any reports which thus enable Iran to be cast in a bad light.

Complinet last reported on the way in which the meeting between the FATF and an Iranian delegation in Paris, in January of this year, was reported in the world media, as the result of a deliberately misleading story issued by the US Treasury.

Now, Levey has issued his own interpretation of the FATF announcement of 28^th February 2008. Ignoring the fact that the latest FATF report means that nothing has changed with regard to the Iranian situation, speaking from Dubai where he is openly engaged in seeking to stir up anti-Iranian sentiments in the Gulf region, he deliberately fails to report the fact the FATF noted its recognition of its recent engagement with Iran, and the commitment shown by Iran to improving its AML/CTF position.

However, despite the increasingly bizarre attempts being made by Levey and his subordinates, including Daniel Glaser, to cast Iran in an unfavourable light, in the hope that by so doing, it will influence the UN to impose even further sanctions on Iran, the Iranians will continue to engage with the main body of the FATF in all attempts to ensure that their AML/CTF regime is fully in accordance with FATF requirements.

Daniel Glaser presently leads the US delegation to the FATF, and his name figured prominently in the previous misleading story which sought to undermine the real reason for the Iranian January meetings with the FATF in Paris. Like Levey, Glaser has been widely quoted as saying that his office is part of the engagement to deter foreign banks from doing business with Iran, and seeking to undermine the Iranian economy. In view of this obvious conflict of interests, Complinet has already questioned his suitability to be a co-chair of the FATF committee which sits in judgement on Iran’s compliance with the FATF requirements.

By adopting these measures of continually attacking Iran publicly, measures which are increasingly being disseminated in the Middle East, the US is painting itself into a corner and is being perceived in much the same light as the boy who cried ‘wolf’ once too often. It has become apparent that many will begin to think that they have protested too much!

More disinformation from the US Treasury

On Saturday 16^th February 2008, the International Press Agencies all began carrying reports of a ‘secret’ meeting held between US and Iranian officals in Paris earlier in January.

Depending upon which agency you read determined what story you received, but suffice it to say that the majority of the articles carried by the US agencies all placed a major US ‘spin’ on the piece.

Take this as a typical example from the Kansas City Star;

“US secretly met Iran banking officials”

‘…A US official met secretly with Iranian banking officials and senior government aides who oppose punishing the Islamic nation for not doing enough to stop money laundering and terrorism funding…

The United States was represented by Daniel Glaser, the Treasury Department’s deputy assistant secretary for terrorist financing and financial crimes…The meeting was part of the Bush administratiuon’s attempts to ramp up international pressure on Iran to halt atomic activities that could lead to the development of nuclear weapons…’

The way this story is reported places a wholly inaccurate interpretation on the events, and attempts to portray the US’s part in these events in a fictitious light. It is yet another example of the way that the US Treasury continues to disseminate a stream of disinformation about Iranian affairs, particularly Iranian banking and financial affairs, as part of a deliberate US policy to destabilise the Iranian state and its internal economic policies. As the Kansas City Star states quite openly;

‘…Wsahington has boasted that the US and existing UN sanctions, have taken a significant toll on Iran’s economy, particularly on its unemployment and inflation rates and raised pressure on the Government…’

For the record and in the interests of fairness and accuracy, the meeting which took place in Paris at the HQ of the Financial Action Task Force, did so as the result of a specific request from the FATF, in a notice it published in October 2007, in which it expressed its concern over the apparent absence of Iranian laws dealing with anti-money laundering and in which it invited Iran to engage with the FATF, advising that ‘…The FATF looks forward to engaging with Iran to address these deficiencies...’

As a result of this notice, the Iranian Government accepted the FATF request and agreed to attend the meeting in Paris in January to discuss a whole range of issues regarding the state of the development of laws and regulations within Iran for the interdiction of money laundering and terrorist financing.

The meeting was co-chaired by the Italian representative and the US representative, Daniel Glaser. Quite why the US representative was chosen to chair this delicate meeting is not clear, but in light of recent events it may be thought more prudent that he will be replaced at future meetings.

The meeting was reported to be cordial, focused and covered a wide range of issues. The Americans it is reported, played no particularly significant part over any other participant, nor was the meeting anything to do with any policy initiatives on their part, either in Paris or elsewhere. They were merely present at the meeting in the same way as the other FATF representatives, all of whom would have expected the meetings to be kept confidential.

Complinet has recently reported some of the activities being undertaken by agents of the US Treasury in seeking to bring significant economic pressure on the Iranian banking community by threatening other banks and international businesses who have business with Iran that the US will seek to impose draconian penalties on those entities if they continue to do business with Iran.

Complinet has previously identified how the pressure for these unlawful activities has been directed from and by agents of the office of Stuart Levey, US Under Secretary for Terrorism and Financial Intelligence. By focusing on the tactics of pressurizing foreign companies who trade or deal with Iran to drop their business activities, Levey and his team engage in a wide range of activities designed to bring financial and commercial pressure on Iran. The aim is to bring about a revolution from within Iran by so destabilizing the economy of the country that regime change will be effected through a popular revolution.

In view of the proximity of Mr Glaser to Mr Levey, it may be thought reasonable to assert that Mr Glaser is guilty of a significant conflict of interests, and that the Iranians might not unreasonably feel that their own transparent deliberations with the FATF are being undermined by Mr Glaser’s position as co-chair of the meetings, as he is a direct satrap of the very official who is doing everything he can to unfairly undermine the Iranian economy.

It is surely no accident that having observed the willing acceptance by Iran of the FATF invitation to enter multilateral discussions, followed by an even more recent announcement of the passing of the Iranian law outlawing money laundering, that the Americans could easily see that their widely trumpeted allegations of Iranian regulatory non-compliance would now begin to ring a bit hollow.

Hence, the sudden outburst of articles all claiming US initiative for engaging in these recent meetings, and playing up their involvement.

The FATF are engaging in a perfectly proper exercise of their function in encouraging Iran to share with FATF full details of her legislation and other proposed initiatives to engage in a full AML and CTF regime of compliance. In her turn, Iran is complying with the legitimate requests from the FATF, and will be engaging in other meetings when invited in the future.

It would be attractive if the Americans would cease their deliberate attempts to subvert the due process which is taking place, and allow those better-placed to judge the bona-fides of the Iranian procedures, to get on with their work. No-one suggests that the US should not be a party to these deliberations, but in the present circumstances it would be better, and it would certainly look a whole lot fairer to other countries, if Mr Glaser took a back seat.