Tuesday, June 18, 2013


There has been an explosion of articles exposing the sordid world of "reputation management," non-transparent companies that seek to conceal negative information, through polluting the web with bogus sites and articles, extolling the virtues of their dirty clients, thereby moving the true story to the back end of an Internet search engine query, where lazy searchers do not tread.

Are search engines now to be ignored by compliance officers ? Given that any of your targets can easily retain a company to post what amounts to disinformation to the www, I am afraid that, with limited exceptions regarding official records available online, the answer has to be in the affirmative.

Here's why:

(1) The sheer imagination displayed by the reputation restoration firms will outwit the search engines every time. They use social media, bogus press releases, fictitious business arrangements, charitable and nonprofit information that is often untrue, bogus relationships with prominent individuals or entities, and other tradecraft to ensure that their entries get top billing on searches.

(2) Add to this the fact that some negative information comes from obscure or unofficial sources, meaning that the sites are not highly ranked, and are displayed, if at all, so far down on the order of results that that it might as well not be there at all. After all, who want to look at the last pages of 500 entries, when you know they are (supposedly) ranked by relevance ?

(3) Arrests, investigations, regulatory enquiries, which are only the first step in the adjudication of guilt, are often only given a lesser ranking by search engines, especially when they appear only as a short note, or as part of an article covering a lot of content not relevant to your target.

(4) Positive information, generated by your target himself, or his associates, separate from the reputation management efforts, further dilutes the true picture of the target's activities that you are searching for.

When you add it up, these issues form a perfect storm of disinformation, clogging your search results, and hiding the real truth. For that reason, a prudent compliance officer relies, first, last and always, upon resources that focus solely on all available negative information, and that update the information on a real-time, and not periodic, basis. Use those resources if you want accurate and completely relevant results, both to save time and to finish your query, so that you can go only the next one, in a timely manner.

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