Thursday, July 6, 2023



With all the focus upon the fictional case law manufactured by an AI-powered legal search program that got a number of New York lawyers into hot water with a Federal Judge recently, compliance officers involved as gatekeepers approving new clients through Customer Identification Procedures should take away from that story the possibility that  their artificial intelligence-driven CIP research could create bogus confirmation of the bona fides of potential customers. The perfect storm of the availability of legitimate passports under aliases acquired through corruption, and through Citizenship by Investment (CBI/CIP) passport programs giving financial criminals bulletproof official identity documents, means that you might get AI-powered verification of a fraudster's carefully created alias identity. 

That is extremely disturbing to me as a former career money launderer, because well-crafted identities, that are subsequently AI-verified, will most likely be passed by gatekeepers every time. This means that clever money launderers, whose identities are well known in the financial world, could create new identities for their criminal clients, or terrorist financiers, by planting verification information in obscure places, online or otherwise, thereby consistently deceiving CIP inquiries that rely upon AI to find the truth. 

This is a serious matter, given that the laundrymen could then exploit the new accounts with impunity, until transaction monitoring catches up with them. Unfortunately, by then, the damage would have been done, and the laundrymen moved on to another bank, with still another set of stellar identity credentials, also employing the artful use of aliases. 

It is humbly suggested that compliance officers therefore supplement their CIP programs, which already use AI platforms to confirm the identity of new bank clients with an effective Facial Recognition* Software system. The system that you should acquire will feature an extensive private photo library, assembled by the program, of both official and unofficial images. This means passport and visa photos, as well as images otherwise obtained and accumulated.

Only through verification of the face proffered by the customer can one actually be able, with confidence, confirm identity. Technology, aided by systemic corruption in governments abroad, has presented compliance officers with the possibility that they are the targets of a very convincing campaign of disinformation and misinformation, which might actually be confirmed by their AI program. Use Facial Recognition Software programs to identify the laundryman, fraudster or other financial criminal  for whom he really is, and stop a potential problem in your bank before it starts. 

__________________________________________                                                                                   *e.g. Facepoint

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