Sunday, July 30, 2017


We hear a lot about new players in the marketplace for candidates to replace the old, now obsolete First Generation AMLCFT commercial-off-the-shelf databases, of high risk individuals. Having once worked for two of them, I believe that I have sufficient insight into confirming that their time has come and gone; static databases, even those that enter daily updates, are by their very nature limited.

It is the Second Generation that aims to serve the global financial community, by expanding the available data, but I am troubled by the fact that a number of those new contenders for the role previously occupied by World-Check are asserting that their product is "cloud-based," when, in truth and in fact, they are only partially correct.

To qualify as a truly cloud-based system, it must have a broad capability to access all the information that the Cloud offers. This means including, but not limited to:

(1)  Information sites behind a paywall.
(2)  Dark Web sites.
(3)  Federal, Provincial, State and local sites that contain massive amounts of data.
(4)  Legal sites, including both reported and unreported decisions, and dockets.
(5)  Photographs.
(6) Negative News sites.
(7) Social media sites.

It objectively appears that few, in the current compliance marketplace. actually are cloud-based. In your haste to upgrade your AML/CFT compliance program, make an educated choice, based solely upon the ability of the product, not marketing hype; Choose well, so that your enhanced due diligence inquiries bear fruit.

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