Sunday, September 30, 2018


When a new, and obviously affluent, customer applies to open a new account relationship at a financial institution that cater to an international clientele, in New York, London or Miami, is it not now a mandatory component of compliance due diligence that social media and social network resources be accessed, to adequately protect the bank, as well as the compliance officer ?

Today's technology, when paired with continuing unrestrained corruption in many parts of the developing world, has created the perfect storm for the financial criminal, dirty Politically Exposed Person (PEP), and terrorist financier They can acquire a completely legitimate forms of identification, such as a passport, in a clean alias, or altered identity that will not expose their true criminal history.

Whether it be a passport purchased from a corrupt official in their country, a Citizenship by Investment (CBI/CIP) passport with their real name cleverly (and intentionally inaccurately) transliterated from its original language, or a passport with their identity slightly tweaked to fool compliance searches of databases, the bottom line is that compliance officers are being presented with a passport that will pass scrutiny, allowing the holder to freely open accounts, and to launder criminal proceeds, clean the proceeds of corruption, or provide financial support to terrorist organizations.

There is a effective solution to this conundrum; searching all new account clients on social media and social networking sites, and other resources using an effective facial recognition software system. Not only are the social media sites searched for your client's image, the program also scanning images on company websites, charitable and sporting events, CCTV. fraternal organizations, and a wide variety of foreign websites where the client's image was taken and posted without their knowledge.

The result is either the confirmation of the customer's identity, and often their occupation as well, or the discovery that the client is not who he or she professes to be. PEP status is often uncovered through this process, as is media that confirms a criminal background or history. Given the unfortunate history of several ambitious CBI jurisdictions, corrupt passport officials, and individuals creating credible documents on Photoshop, it is an uneven playing field, when compliance officers are pitted against financial criminals dedicated to their dirty craft.

Therefore, it is humbly suggested that there be no Enhanced Due Diligence inquiries of foreign nationals seeking to open accounts, without employing facial recognition software systems that access social media/social networking resources, and all other available sources of images. Such searches will effectively cut through the disinformation, if it was presented as the truth, and expose financial criminals, and others who seek to deceive compliance with a seemingly clean identity.

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