DO NOT PERFORM CURSORY INTERNET SEARCHES DURING DUE DILIGENCE INVESTIGATIONS

For those readers who have not read any of my early articles on the subject, when using search engines to make due diligence enquiries about a prospective bank client, remember this: never perform searches based solely upon relevance. To put it another way, do not limit yourself to the first couple of pages, when examining results.

Internet manipulation has gone mainstream; firms now advertise that they can minimise, or even delete, adverse information of the world wide web. It is not new; criminal organisations have been doing it for years. Here's how it is done.

Let's say that you are a career fraudster, with a number of articles about your recent arrest, for securities fraud, in an Asian country. You go to a skilled operative, because you want then off the Internet, as it is frightening away prospective victims.

Since the search engines operate under the relevance of a query, the trick is to put up, in front of the offending material, favourable and positive postings, web pages, news items and the like, to push the
negative articles about the client further and further back. Some of the tactics employed:

(1) Have the "client" sponsor a local sports team and/or event. The Internet site of the team, local media, and a self-serving posting, will all end up on the Internet, ahead of the unfavourable articles, when a search for the target is made.

(2) Charitable contributions, donations to non-profits, and social and fraternal organisations, generally result in Internet entries, all of which keep pushing the negative material to the rear.

(3) Blogs, letters to the editor, and other web entries, all of which are indexed by Google and the other major search engines, all contribute further to filling the first couple of pages of a search result with positive information.

So, what does a compliance officer do when conducting due diligence or enhanced due diligence investigations ?  

(A) NEVER stop looking at search engine enquiry results, until you get the last entry on the absolutely last page. That way, if there is something negative, and it has been cleverly shunted to the back of the query, you will still retrieve it.

(B) ALWAYS access multiple search engines when performing Internet searches of a client, including regional, local, language-specific, and lesser-known sites, to ensure that you do not become a victim of Internet manipulation. Whilst search engines are helpful to the compliance officer, guard against the techniques discussed here by performing a very complete search, and go all the way to the end of the line on search results.