Tuesday, September 18, 2018


If you think that the utility of facial recognition software platforms for AML compliance is limited to searching social media and social networking sites, you are misinformed. Facepoint, the Paris-based firm that combines facial recognition technology with Artificial Intelligence, has its own extensive proprietary database of what it calls Heightened Risk Individuals, and also extracts image data from a wide variety of sources, including those in the Cloud, behind paywalls, and on government sites.

  Additionally, a good compliance officer knows that one's image searches may return positive results from resources accross the information spectrum, and he does not ignore any of them as a possible source of new intelligence about his target:

(1) Images from corporate websites can identify your target's true identity, his work associates (who may now be his partners in crime), and the source of any special skills or technical expertise, which may bear upon present criminal activity.

(2) Evidence that your client, though claiming to be a private businessman, may actually be a military officer, government executive, director of NGO or nonprofit or even a PEP, could be adduced from his presence in group photos.

(3) Fraternal, social, professional or nonprofit association website images might cause you to classify him as a PEP, or alternatively, rule him out as one.

(4) Reports of financial crimes, in faraway places, yet covered by local media there, may prove instructive, even if no conviction is obtained, due to flight to avoid prosecution, or the payment or bribes to insure dismissal of all chaeges.

(5) Investigative news stories, detailing criminal organizations, could return images tagged with your target's name, or that or a close associate, requiring further inquiry.

The large number of images available to the compliance officer, through facial recognition software programs, each represent a potentially fruitful avenue of inquiry when performing Enhanced Due Diligence investigations.   

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