Wednesday, February 26, 2020


If you were paying attention to my recent article about the German Bitcoin fraudster, Arthur Gehl, now referred to in media as "The Most Hated Man in Europe." you might have noticed that he disclosed that his Grenada Citizenship by Investment (CBI) passport is NOT under his legal name, but an alias. This little nasty detail which has been repeated thousands of times on CBI passports issued by those nations looking for a quick buck, and notably careless about who they sell passports to, is the reason that traditional Customer Identification Procedures where the target's name is the principal reference, are not obsolete, as well as not being considered Banking Best Practices by regulators.

Compliance officers can no longer rely upon CBI passport information as accurate, due to a number of factors:

(1) Corruption; illicit payments guarantee that an alias, and not the applicant's reel name, ends up in the treasured and coveted travel document.

(2) Transliteration of names into the English language, with Roman characters, Foreign languages, with different alphabets and equivalent letters, are rarely close enough to the original to be picked up in a search of databases.

(3) What if the applicant's personal information, from official sources in his home country, is already an alias ? Corruption at the front end of any application makes accurate identification impossible.

This means that compliance must access facial recognition technology to positively identify its targets; There is no effective alternative. Note that the program you use must have access to an extensive image library, and that the images simply must be of passport photograph quality. Using solely social media or internet photos will often result in false positives, or the inability to identify your target. Choose your facial recognition platform carefully for that reason. Do you know which are effective, and which are to be avoided ?

We have the CBI programs in the East Caribbean and the European Union to thank for this situation. The lure of easy money, which got the participating countries on board in the first place, also is responsible for the rampant corruption, which causes the program staff to accept knowingly accept  aliases, or invent them for applicants, or alter records. The days when one can go to sanctions lists, and commerical-off-the-shelf databases of  high-risk individuals and entities are long gone; use facial recognition software now to identify your customers.  

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