In the last post, we discussed the continued difficulties encountered by some people even after their Red Notices are removed from INTERPOL’s databases.

Particularly in cases where the underlying criminal charge is a financial crime, Red Notice subjects often find that INTERPOL is not the only organization that contains their personal data. Other organizations- with both domestic and international databases- collect data on individuals and then distribute that data to their customers.

Among the primary consumers of personal data based on financial activity are financial institutions and financial service providers.

Financial institutions and providers of financial services seek to avoid financially risky clients– those who may engage in activities that are illegal or financially questionable. Consequently, banks and financial service providers have come to rely on companies that provide personal data lists of people who are politically exposed, wanted for financial crimes, or listed by governmental agencies as prohibited business partners.

The companies that provide personal data lists, such as World-Check, LexisNexis, RDC (Regulatory DataCorp), Bureau Van Dijk, and Dow Jones may obtain their data from media sources without independently checking the accuracy of the source’s reporting. For example,  I have had a client whose data was reported by such a company as having an open criminal case months after the criminal case was completely dropped by the authorities. This client’s data was listed and circulated to every company that subscribes to this service, and the data was incorrect and outdated.

The failure to maintain an accurate database could result in legal action against the publisher, as has happened multiple times in the case of World-Check.  Most of the publishers of the data have specific personnel assigned to correct inaccurate data. Once they are made aware of the inaccuracy, they will either remove or modify the information.

As always, thoughts and comments are welcomed.