Leaving Compliance Footprints in the World

When investigating screening alerts, here at SQA Consulting we find that the most valuable secondary attributes – after date of birth – are country of residence, nationality (of course for nationality, read citizenship) place of birth and country of registration. We call these two pieces of data: location and origin, and they are vitally important for triage and further investigation of Sanctions, PEPs, and Adverse Media alerts.

We are often presented with this information neatly formatted in specific fields and find them very easy to handle. However, be aware – as we have covered in our Sanctions Screening Articles – having differing values for location and origin can be potentially misleading and care should be taken over comparing close relationships like Sudan/South Sudan, China/Hong Kong, the United Kingdom/Isle of Man, and many others.

The address and nationality fields, however, are not the only source of information available to you and if you look deeper you might find other attributes that might influence your investigation. So where do you look for more location and origin information?

Here are some suggestions:

• BIC – Most banks have SWIFT BIC; the 5^th and 6^th characters give you the ISO Country Code of the branch.
• Passport – When capturing passport information for KYC, the country of issue is often recorded.
• Social Security Number – Similarly for SSNs and Driving License numbers, the country of issue is often captured.
• Transaction History – International transactions and card transactions can give a good indication of where a person has been, and what countries can be associated with them.
• Personal Name – A personal name tells a story about a person in the same way as DNA tracing.
• Company Name – A company name can itself contain direct geographical references, but also the use of suffixes and prefixes such as ‘OOO’ can place a company in a geographical region.
• Vessel Information – The vessel flag is not necessarily significant, but AIS vessel tracking is, and the history of a vessels movements around the world are easily accessible.
• Plane Tail Code – Common information in the insurance business, the tail code is geographically structured, and the country of ownership can be easily derived.
• Phone Number – Any phone number beginning with 00 or + immediately gives away country information.
• Internet Bank Access – Many banks now deploy monitoring software on internet bank access to detect and potentially restrict access from certain countries. A scan through the internet access can reveal more information as to the location of your client, however, no monitoring system can reliably detect location when the access is through a VPN.
• Phone Banking Access – Similar to internet access your phone banking can may record where your clients have accessed your systems from, however beware mobile phone roaming will not necessarily give accurate information.
• URLs / E-Mail Addresses – Internet domains often have country codes, although these are not always ISO Country Codes, and some oddities exist like the prevalence of the IO code for the British Indian Ocean Territory.
• Company Ownership – The company registrar for your country may have additional address information both for your company and for its owners.

When you have sourced all your location and origin information and checked the footprint left by your client, then you have the basis of a thorough investigation.

For more information on how the AML team can help your organisation, contact us.