The Organization for Economic Cooperation and Development (OECD) has identified twenty-one countries and territories that it deems high risk, due to their operational CBI or RBI programs. Compliance officers should note that neither a personal appearance nor residence are generally not required to obtain a passport or residency document, which is fertile ground for identity manipulation, to conceal the true identity of the passport holder.
Antigua & Barbuda
Commonwealth of the Bahamas
Commonwealth of Dominica
St Kitts & Nevis
Turks & Caicos Islands
United Arab Emirates
Due to the increased risk that passports and identity documents from the above jurisdictions pose to international financial institutions, compliance officers conducting Customer Identification Procedures are advised as follows:
(1) Conduct Enhanced Due Diligence investigations on all individuals from these countries and territories.
(2) Verify actual legal name identity through the employment of advanced facial recognition software systems on the individuals' likeness.
(3) Access social media and social networking resources, to confirm, or rule out, Politically Exposed Person (PEP) status, of the individual, as well as his or her business associates, family members and friends.
Candidly, given the ability of applicants to foist counterfeit or alternative identity documents upon greedy CBI or RBI units, one must assume that names are bogus, and proceed to identify the true legal names of the individuals, using facial recognition software systems, EDD, ang social media resources. To do anything less, with any of the above countries, constitutes compliance malpractice.