FACIAL RECOGNITION SOFTWARE AS AN ESSENTIAL ELEMENT OF ENHANCED DUE DILIGENCE

The Boston Marathon Bomber

 There are serious concerns expressed recently about applicants for CBI programs who proffer legitimate proof of identity, including passports, birth certificates, and drivers' licenses, using aliases, thereby denying that any effective investigation will occur, since the true legal name of the applicant is never disclosed. The documents, which are generally obtained through bribes, from cooperating individuals at official government agencies, are real. 

Additionally, as we have again seen this week, in the case involving the arrest of individuals who allegedly have created counterfeit Antigua & Barbuda passports for clients, there are forms of identity in circulation, which appear to be completely legitimate, bearing aliases of the holders. How can the true identity of the holders of these bogus passports be ascertained ?

First, it is well-established that the traditional due diligence investigations are now obsolete, and it cannot solve the two problems mentioned above. Furthermore, any Enhanced Due Diligence program, to be completely effective, must contain a Facial Recognition Software component, capable of identifying or verifying an individual, from the images he or she presents. These programs compare the applicant's images to a database of digital images and video frames from video sources. 

When you have career criminals, corrupt Politically Exposed Persons (PEPs), international sanctions evaders, and even individuals named by OFAC, seeking CBI passports, it is necessary that effective Facial Recognition Software be an integral component of the vetting process. Additionally, it is advisable that a look-back be performed in all existing CBI passports holders, to identify those who managed to gain a passport using documents that do not contain their legal names.