WOLFSBERG GROUP LISTS FACTORS TO CONSIDER WHEN ASSESSING NEGATIVE OPEN-SOURCE INFORMATION DURING DUE DILIGENCE INVESTIGATIONS

In determining what constitutes a “good” source, the [Wolfsberg] Group believes that typical characteristics of reputable sources are:

• Media Type: international news agencies and national newspapers which report on a broad spectrum of global and national events usually provide accurate and higher quality reporting. Regional and local news providers may report on events which are not covered by larger scale outlets, indicating that the reporting may only be deemed material to a specific location.

• Content: in larger scale primary media, credibility of the content is in general higher when subject to editorial oversight. There are a few factors which may indicate that a source is not reliable:
  o content is being corroborated from social media or appears to be non-professional o can be edited online by network participant(s), or

  o appears to be opinion-based9.

• Geopolitical context: publications considered as politically neutral, or not fulfilling any

  specific political purpose would in general be more credible. Consideration should be given to news reported in countries with weaker democracies and/or non-democratic states where media may be controlled or influenced by leaders or leading parties. The presence of polarised news reporting should also be considered10 and FIs should refer to sources such as the Press Freedom Index11 to confirm the independence level of the press from political and corporate influence.

• Redundancy: in general, where the content of media sources can be substantiated by relevant or related material found in other reputable, the media sources are more reliable.

• Editorial Coherence: publishers who provide relevant details (e.g., statistics, dates, numbers, figures, names, and locations) and original source of information, cites, quotes or footnotes, usually represent higher quality and fact-based news. Sources where materials contain typographical, spelling, and other errors or lacking rhetorical structure may not be reliable. An author’s linguistic choices and lexical diversity (e.g., emotional, extensive punctuation, eye-catching words) may indicate filtering of facts.

• Website Layout and Appearance: websites which appear to be poorly laid out or badly maintained may indicate less reliable content.