Friday, August 1, 2014


If you have ever attended one of my lectures, where I discuss my experiences as a compliance officer conducting enhanced due diligence investigations of high-risk clients, you may have heard me discuss a specific case, where I identified the beneficial owner of a front-man's assets through a photograph of the two of them, at an airport, standing next to a private jet. The prospective client was a Georgian, working for one of the Russian Oligarchs, and for that reason I denied the client the ability to make an investment with the firm, as the gatekeeper. Image searches are something I try to instill in every lecture attendee, as an important supplemental research tool. Who is your target associating with ? A photograph could establish that they are involved with individuals or entities that disqualify them as a potential client.

Images are always an important part of due diligence; we never limit ourselves to the written or spoken word, for criminals rarely know that their photograph has been taken, at a social or charitable event, that links them to the individuals seated next to them, be he a legitimate businessmen or government official, who you now know requires further inquiry.The reason I am mentioning this is the recent disclosure that the National Security Agency (NSA) is employing what it refers to as "Identity Intelligence," the use of images in support of its terrorist identification mission. Their use of this technique validates its usefulness as a compliance tool. 

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