Friday, October 15, 2021



Ladies & gentlemen; if you work in compliance, and in light of the special threats posed by terrorist financiers, you want to have as complete a toolbox available to you, to check entities and individuals even possibly linked to active terrorist organizations, particularly Specially Designated Global Terrorist (SDGT) organizations.

I spent several years working for two commercial out-of-the-box (COTS) databases of high risk entities and individuals, World-Check and Complinet,  and in working in over 100 countries, met many compliance officers. In my experience, I often encountered compliance departments that had more than one of the major databases, which is frankly an excellent way of reducing the risk that your frontline compliance officers will fail to identify an obscure or minor terrorist financing entity that is only identified in one such database.

While we may not have a great amount of respect for Facebook's management, due to recent negative media about the company, one investigative website obtained a leaked copy of Facebook's Dangerous Individuals and Organizations List,  which appears to contain valuable information about terrorist organizations. Any supplemental data that you are able to access, when it comes to terrorist financing, will operate to assist you in your risk-based compliance program.

While we have no assurances that this list is 100% accurate, you can use it to confirm information that you acquired elsewhere, and if it turns you on to data that you, as a gatekeeper, use to bar the door to terrorist financiers or even to stop terrorist organizations seeking to quietly open accounts at your bank, believing that you are unable to identify them, this data could prove very valuable. While there are no warranties given, use it knowing that verification may be necessary, especially where the information is not confirmed on your COTS resources. Use it wisely.

Facebook Dangerous Individuals and Organizations List

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