SOCIAL MEDIA AND OTHER IMAGE SOURCES MOVE DATA TO A SECONDARY ROLE IN COMPLIANCE

If I am a corrupt Politically Exposed Person (PEP), known narcotics trafficker, or convicted money launderer and fraudster, and I want a clean passport, to move some dirty money, modern technology has made my task quite simple. I bribe a government official in my home country, purchase official identification under the name of an alias, which passes muster on any commercial-off-the-shelf database of high-risk individuals, and take it to another jurisdiction where money also talks.

I am now in one of the three East Caribbean CBI states where a large payment to the appropriate senior government official gets me a new passport, based solely upon the totally false, yet authentic, government-issued identification I presented to the CBI unit. Alternatively, I travel to one of the European CBI jurisdictions, and though it costs me more money in bribes and kickbacks, obtain the same result with my bogus documents. I may even go to a country where I can deal direct with the authorities, and score a passport that says I was born there and have always been a citizen. What's wrong with this picture ?

Modern technology and greed have combined to create a perfect storm of risk for compliance officers seeking to positively identify new clients in a potentially dangerous AML/CFT situation. The old database due diligence searches no longer guarantee that you have absolutely identified your target. Due diligence has become obsolete and ineffective, in a regulatory environment where compliance officers have become personally liable, even on the criminal level, and their future in the financial industry could be permanently terminated, should they fail in the identification role.

Since technology (paired with corruption) has created the problem compliance officers face, we must look past pure data to identify customers, to the solution that images offer. Only through the use of facial recognition software systems, which can scan social media, social networking sites, arrest records, visa photos, newsreel and CCTV footage, and many other pictorial resources, can we uncover the true identity of your clever criminal passport holder. Then, we employ enhanced due diligence, to verify our findings using data sources, albeit in a secondary role.

The days when a compliance officer can punch in a new customer's name, taken from his passport, into a commercial database, and know he has identified the client, are long gone. While databases still have their place in compliance, they are now in a secondary role. Images have replaced data as reliable sources of identification verification; To do anything less constitutes malpractice, and the threat pf personal liability and accountability for compliance failures.