Sunday, June 2, 2019


Now that the US State Department is requiring visa applicants to disclose their social media and email addresses, and given the current ability of foreign applicants for bank accounts to conceal their true identities, should bank compliance officers now also obtain social media and social networking information on new foreign clients, and employing a facial recognition software program, verify client identity, as well as check for potential PEP status or terrorist affiliation ?

If the US Government deems social media information to be so important that it now orders it to be divulged on visa applicants, that should convince compliance officers of its importance in the due diligence process. As a risk reduction tool, the verification of a new customer's true full legal name, using facial recognition on social media and other Internet resources, will greatly minimize the possibility that the client is using an alias, or is otherwise unsuitable for onboarding for a number of  important reasons.It will essentially rule out the client as high risk.

New accounts staff are advised to revise their account application forms to include social media user names, Internet websites and blogs, and any relevant social networking information, as an integral part of the customer identification procedure. Should you fail to do so, and money launderers, hidden PEPs, or terrorist financiers obtain accounts, and abuse them, compliance officers may be looking at a future finding of compliance malpractice, or regulatory action.

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