Kenneth Rijock

Kenneth Rijock

Thursday, November 15, 2018


A recent article, in a website promoting Citizenship by Investment (CBI/CIP) products, interviewed two satisfied customers. The problem is, one was from Syria, and the other a Palestinian. Both of these jurisdictions have a number of Specially Designated Global Terrorist (SDGT) organizations operating within their borders, and any Customer Identification Program that examines them must rule out any connection to terrorism, directly or indirectly, including the possibility that applicants are providing material support to a terrorist organization.

This is why social media/social networking searches are necessary and prudent. The use of an effective facial recognition software system, to troll all the sites, seeking to encounter the target there, will insure that he or she is not engaged in activities that disqualify them for an account at your bank. 

Of course, you say that they are legitimate businessmen, and that there's no terrorist connection. Use of social media in searches could uncover any one of the following:

(1) The client is not personally engaged in terrorist activity, but his posts indicate strong sympathies for known terrorist organizations, or third parties that support them.

(2) The clients appears to be clean, but his adult children have made some radical postings, which he has followed on his sites, or which they placed there.

(3) The client supports political parties, or individual politicians, who are known to be associated with a terrorist group, in his home country.

(4) Individuals posting on your client's social media sites are themselves known to he radical in his home country.

It should stressed that these subjects do not, in themselves, confirm anything. What they do is to strongly suggest that you immediately conduct Enhanced Due Diligence upon the client, to rule out any link to terrorist activity, including financial links. By definition, the client lives in a high-risk region, and you must conduct your CFT compliance accordingly.

Clients are free to express their own opinions on the Internet, but if any of the above Red Flags are present, you must ramp up Enhanced Due Diligence, to take a close look. To do anything less raises the risk that the client might possibly use the account to provide material support to a terrorist organization at a later date, long after you have forgotten about him, and incorrectly assumed that he is low risk.

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