THE USE OF SOCIAL MEDIA RESOURCES IN EFFECTIVE ENHANCED DUE DILIGENCE INVESTIGATIONS

 While we have previously written several articles on this blog, detailing how important the utility of social media resources in routine inquiries made by bank compiance officers, prior to account opening, as well as its usefulness in successful law enforcement investigations, social media searches have also become an integral part of all Enhanced Due Diligence procedures. The widespread use of Internet reputation management companies, and the artful placement of so-called "fake news" articles in the media, has eliminated the ability to rely upon much that is posted to the world wide web, even if it sems to come from authoritative sources.

Social media searches are valuable source of negative information that your target may have worked very hard to keep from the Internet, but which artful and focused inquiries on social media will reveal. For example, a photograph documenting the presence of what you thought was a successful businessman-client at birthdays, holiday observances, charitable events, or simple gatherings, will often show close links to his more disreputable (i.e. organized crime) associations. Individuals may reveal interesting aspects of their lives when they as off-duty, or they think they are participating in private moments.

Another example is information ,which can often be gleaned only from social media sites, about your target's close friends' relationship with criminal elements. Is he the covert intermediary between your target and individuals who will disqualify him from any serious consideration for a directorship, large commercial loan, or investment in a joint venture ?  Often you can find evidence of such a relationship hiding in plain sight in a social media source.

When conducting an effective Enhanced Due Diligence investigation, Social media resources have become as important as your reliance upon facial recognition software, and of Second Generation, cloud-based information. Do not neglect to make it a mandatory element of all your EDD inquiries, lest you miss an important discovery which could affect your recommendations about the target's suitability, or lack thereof.