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The disclosure, this week, by the Secretary of the Department of Homeland Security*, that foreign visa applicants may be asked to give up their social media accounts passwords, received mixed reviews in the United States, but those sources of information are already in use in compliance, though this is not widely known.
Next generation AML/CFT resources have long been accessing social media information, to assemble data on individuals located in jurisdictions where it is either difficult to obtain or non-existent. Also, social media accounts are used to access personal information, where the target is either totally unbanked, or has a very small Internet footprint, insufficient for compliance purposes.
Most Americans know that prospective employers routinely access their publicly available social media information, but are concerned about the prospects that private information, not available except to those who have been approved, might be available. At this time, it only is being considered for the purposes of checking the background of foreign visa applicants, but even the remote prospect that your social postings, affiliations, friends, or others linked to you in social media, might be examined at a later date, is more than sufficient reason to carefully control your Internet social entries, and to promptly remove yourself from being associated from conduct that may be inappropriate, and might affect your career, reputation, or future litigation.
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* Apparently this was first considered in 2011, but never implemented by the United States in its visa program.
Chronicles of Monte Friesner
Contributed by Kenneth Rijock
