Sunday, March 13, 2016


Readers of my thousands of financial crime articles, when I was the Financial Crime Consultant for World-Check, may not know that, previously, I was a contributor of articles to Complinet. During that time, I was a compliance officer, working on enhanced due diligence matters, for a major American investment firm.

One prospective client, who wished to invest $500,000, was himself a financial adviser, claiming to invest his own funds. I proceeded to conduct my inquiries; He was an Anglo-Uruguayan, with offices in Montevideo. Outside of his business website, I could not any Internet footprint, which was a red flag of the highest order.

I have been trolling the Internet for evidence of client business or social activity, since it became a useful resource, around the year 1993 or 1994. Clients with significant amounts of money to invest must also be spending their money on business or pleasure. find it online:

I always ask myself these questions:

(1) Is there evidence that he is involved in other businesses ?
(2) Does he contribute to charities or non-profits, and show up on the party circuit for those events ?
(3) Does he have an interest in sports or hobbies, and does he sponsor any of these avocations ?
(4) Does he have an interest, no matter how small, in social media ?
(5) Is he a collector, whether of arts & antiques, fine art, classic cars, yachts, aircraft, or something else ?
(6) Are there any articles about him, his company, or his accomplishments ?

If an Internet search fails to reveal any of the above, and he is a ghost online, there something you are missing ? Is he merely a front for someone or something more sinister ? Is he a career criminal ? The lack of any information, such as appears generally for any affluent individual in legitimate business, means you have a major problem.

In the present case, when the Internet failed to return any information, I searched the databases of the world's major newspapers, and found an entry where the target had offered to post an estate, to obtain a bond for a fugitive Mexican drug trafficker in Australia. He was obviously unsuitable as a client, and I rejected him, but the takeaway here is that everyone has an Internet footprint, we all do, and the lack of one speaks volumes about your target.

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