The identification of Politically Exposed Persons, more commonly known as PEPs, remains one of the most difficult challenges facing compliance officers at international banks, especially when the individuals come from countries in the developing world where freedom of the press, and of information in general, is restricted, monitored, controlled, or censored.
Your applicant who is seeking to open a new account, and who is a close associate of a senior government official, military officer, government-controlled or owned corporation executive, or senior charitable entity or NGO official, may choose not to disclose that relationship to you, due to the fact that his deposits will be the proceeds of bribes, kickbacks, or other income received due to corruption. Your job is to ensure that you have identified him as a PEP and to put in place the safeguards and account monitoring that such a status requires.
While the joint use of facial recognition software and social media platforms is well known as an effective tool for law enforcement use, as we have previously noted on this blog*, teaming up these two effective search resources can establish a PEP relationship where no other asset in your toolbox can. Many PEPs have relationships that establish their status outside normal channels, and the images you find in social media may be the only evidence that exists to confirm he is a PEP. The importance of this technique, which couples two valuable compliance tools, cannot be underestimated.
Your target need not actually be a user of social media to be found using this technique. The fact is you can confirm that he or she is a PEP through remote and indirect relationships that would most likely never be uncovered using conventional investigative techniques. This is known as Shadow Profiling, and we have previously detailed its effectiveness.**
PEPs can go to great lengths to conceal the existence of relationships that make them PEPs; you need to avail yourself of all the possible resources available to you to find those relationships.
*Facial Recognition Software is highly effective when paired with Social Media Platform
**Using Social Media to create Shadow Profiles in Investigations