WILL GOOGLE'S NEW SYSTEM NOW ASSIST MONEY LAUNDERERS, FINANCIAL CRIMINALS AND OTHER HIGH-RISK INDIVIDUALS?

This week's news, to the effect that Google Search will now accept requests by individuals to have their "personal information" deleted from websites that show emails address, telephone numbers and other personal data, is a classic example of the Law of Unintended Consequences. While we certainly understand that legitimate, law-abiding individuals have a desire to have their very personal  data, that which can be used not only to to contact them, but to target them for unwanted and repeated commercial solicitations, the delivery of physical threats and unsolicited visits from a wide variety of salesmen, reporters and those with a political axe to grind, there's something much more relevant here for compliance officers. Google Search has noted that it will review such applications, and if granted, delete the relevant information now showing up on Google inquiries of targets. Though the platform is said to only be in the Beta stage, you can expect a final version shortly. 

Much of what compliance officers do is, by its very nature, dependent upon open source information to verify data for CIP, update existing files, and to check on unknown non-client counterparties, recipients of funds, references supplied as account opening, and to file SARs ( Suspicious Activity Reports). Of course, let's not forget the individual who shoulders the compliance responsibility at a non-bank, ro non-financial entity, whose idea of due diligence is to search Google quickly, and not finding anything negative, then approves the client. 

You'd better believe that many money launderers, as well as their career criminal clients, most of whom have never been arrested, let alone have felony convictions, are already sending in their requests for deletion to Google's administrators. The last thing they want is that you can find that they pushed a sophisticated synthetic identity on you, which you might be able to expose from something about an innocent victim whose personal data reveals their fraud.

 We need all the personal data present in the www to remain precisely here it currently resides, lest we give the laundrymen yet another advantage over the world's compliance officers. You may not like to hear this, but there is no personal right of privacy when it trumps AML, in my humble opinion. You are free to disagree until some financial criminal, taking advantage of Google's new "Right to be Left Alone," moves the proceeds of crime through your bank.