Wednesday, May 16, 2012


The widespread use of Internet  "advisers," who manipulate what appears on the first couple of pages of an Internet search of a compliance research target, by placing various and sundry extremely relevant  items into the www, have rendered most normal compliance searches useless. If you are one of those few people who thinks that you don't have to spend money on commercial off-the-shelf high risk databases, think again. Search engines are now being gamed to deny you the truth about your target.

I saw a good one last week; the hacker involved had placed a wide variety of Internet entities, including subscriptions to many social networking and business contact sites, stand-alone websites purportedly by the the drug trafficker, operating a news service or public service, or both. Hobby and recreational sites, and even sites for images, are also a good method of pushing the real damaging data way back to the end of the search engine results, where most compliance officers deign to tread. There was even a nasty swipe at articles written by yours truly. about the someone's  long criminal history*, for "attack the messenger" is a favourite tactic, designed to make you question the accuracy of negative news.

A word to the wise: Unless you couple your Internet search with the criminal acts, or civil transgressions linked to your target, these reputation damage control firms will keep you from discovering the sordid truth about your prospective client. Since we rarely know exactly what your new customer's crime du jour  actually is (narcotics, white collar, child pornography, arms trafficking, etc.), you cannot therefore specify, with any degree of accuracy, in your  search. The only way to evade all those bland/positive entries about your target is to zero in on his crime; otherwise,

The obvious answer is that you need to batch up the queries, and outsource them all, as due diligence, or enhanced due diligence, so that someone with broader access, and investigative experience, can supply accurate answers. Search engines, as primary sources of compliance information, are becoming a very  dangerous place to troll for that data; avoid them.

* I am sure that some of you may have articles critical of my information, or of me personally; this often happens when I expose career narco-criminals, dirty PEPs, or white-collar fraudsters. They do not like the public exposure.

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