Some of the impetus for the UK Government's compulsory biometric National Identity Register and ID Card is supposed to be to help combat terrorist or serious organised crime money laundering and finance.
The Joint Money Laundering Steering Group of the British Bankers Association, has published a Consultation document which is open for comments from the financial industry and the public until 30th June 2005.
The financial industry seems to be slowly waking up to the increasing cost and bureacracy imposed by the current approach to Money Laundering , which on the one hand penalises the vast majority of their innocent customers with timewasting "identity checks", involving easily forged utitlity bills etc. On the other hand, it relies on systems which use various official Government financial blacklists as their raw "Garbage In, Garbage Out" data, dressed up as Know Your Customer or Anti-Money Laundering databases and software.
The aim of the Consultation seems to be to see if the industry can move over to a more intelligent risk based approach to Money Laundering Regulations, instead of the lip service and backside covering, which the current system seems to operate on.
Those of us who are interested in personal privacy issues, should take the time to contribute to this consultation, to remind the financial industry and its regulators of the public's Privacy and Data Protection fears and mistrust of this failed bureacratic form filling approach to combatting terrorism.
In order to protect themselves from possible legal action under the Proceeds of Crimes Act 2002, banks and financial institutions have been investing in increasingly complicated and expensive Know Your Customer database systems, against which they are supposed to check whether they are about to do business with someone who is on an official Government blacklist
To see just how useless these financial blacklists are, in actually catching anybody involved in terrorist or drug smuggling related money laundering, you only have to examine a typical one, e.g. published by the Bank of England:
"BIN AWAD;Osama;Bin Laden;Usama;Bin Muhammed;;;28/07/1957;;Yemen;Saudi citizenship withdrawn. Now officially an Afghan national;;;;;;;;;;;;Al-Qa'ida;Individual;AKA;Al-Qa'ida & Taliban;23/02/2001;23/02/2001;6896BIN AWAD;Osama;Bin Laden;Usama;Bin Muhammed;;;30/07/1957;;Yemen;Saudi citizenship withdrawn. Now officially an Afghan national;;;;;;;;;;;;Al-Qa'ida;Individual;AKA;Al-Qa'ida & Taliban;23/02/2001;23/02/2001;6896
BIN LADEN;Usama;;;;;;28/07/1957;;Yemen;Saudi citizenship withdrawn. Now officially an Afghan national;;;;;;;;;;;;Al-Qa'ida;Individual;AKA;Al-Qa'ida & Taliban;23/02/2001;23/02/2001;6896BIN LADEN;Usama;;;;;;30/07/1957;;Yemen;Saudi citizenship withdrawn. Now officially an Afghan national;;;;;;;;;;;;Al-Qa'ida;Individual;AKA;Al-Qa'ida & Taliban;23/02/2001;23/02/2001;6896
BIN LADEN;Usama;Muhammed;Awad;;;;28/07/1957;;Yemen;Saudi citizenship withdrawn. Now officially an Afghan national;;;;;;;;;;;;Al-Qa'ida;Individual;Prime Alias;Al-Qa'ida & Taliban;23/02/2001;23/02/2001;6896
BIN LADEN;Usama;Muhammed;Awad;;;;30/07/1957;;Yemen;Saudi citizenship withdrawn. Now officially an Afghan national;;;;;;;;;;;;Al-Qa'ida;Individual;Prime Alias;Al-Qa'ida & Taliban;23/02/2001;23/02/2001;6896"
The primary key for these blacklists seems to be an Anglicised spelling of a foreign name, which is open to many false positive mismatches, and vague address information (again, almost all of which cannot possibly be confirmed by an employee of a UK financial institution).
In the example above, does the confusion over the birhdate mean that Osama bin Laden (obviously different to Usama bin Laden) born on the 29th of July 1957, would not trigger a warning from such Know Your Customer systems ? Or is it more likely that anyone born on those dates would come under suspicion ?
How is a frontline employee of a financial institiution meant to be able to use pathetic "data" like this in any meaningful way, except to over report and thereby to put many innocent people under suspicion, simply to cover their own and their employers' backsides ?
There are whole categories of organisations and people who you might expect to be on such a terrorist finance blacklist, who are ommitted, e.g. the dodgy "charities" in Saudia Arabia which have been accused of funnelling funds to terrorists, or all but one of the Chechen rebel/terrorist groups (none of which are considered to be proscribed terrorist organisations by the Home Office) or any of the major cocaine or heroin smuggling cartels.
There are moves afoot to make the "money laundering blacklists" even more widespread on a European Union wide or G8 wide international basis.
To see what sort of information is already divulged on you and any of your financial transactions which are deemed to be suspicious, just download the official Disclosure forms from the National Criminal Intelligence Service website.
It is only slightly relevant to the interesting stuff above, but has anyone else notice, as they drive/ride/run around their respective towns and citys, billboard advertisments from credit card companies going on about "Identity Fraud"?
I started seeing these things around where i live a couple of weeks ago, and i recall there being a number of "political" talkshows and newspaper articles all about this so called threat at around the same time.
Is there nothing a compulsory, centralised, biometric database cannot be made to look helpful for?
The current "fear of identity theft" advertising campaign by CapitalOne is really insulting, given the amount of unsolicited "junk mail" that they send out every year - where did they steal my personal name and address details from ?
Their so called "identity theft protection" is nothing more than what they are already legally obliged to do under the Financial Service Authority regulations, just like all their competitors.
It would be interesting to analyse which of the media channels producing these talk shows and newspaper articles, also get paid by CapitalOne to carry their advertising.
It does not look as if the Bank of England financial sanctions against suspected terrorist money is having much effect, with only a small amount of money (less than the value of a house in central London) having been frozen:
http://www.publications.parliament.uk/pa/cm200405/cmhansrd/cm050322/text/50322w25.htm
"22 Mar 2005 : Column 713W—continued
Terrorist Assets
Dr. Vis: To ask the Chancellor of the Exchequer how much money suspected of being linked to terrorist assets (a) worldwide and (b) in the United Kingdom has been frozen since 11 September 2001. [223023]
Mr. Timms: Since 11 September 2001, 44 accounts totalling some £347,000 have been frozen in the UK. In total, 45 accounts, totalling some £378,000 are currently frozen by UK financial institutions. There is no global figure of the total assets frozen—monitoring frozen funds is a matter for individual jurisdictions.
All organisations and individuals whose assets have been frozen in accordance with the UN Security Council Resolutions, associated EC Regulations and domestic legislation are listed, by HM Treasury instruction, on the Bank of England's Financial Sanctions website. Asset freezing is an essential measure in countering the financing of terrorism by denying terrorists and their financiers access to funds across the world. Taking action not only freezes any funds in the UK but also creates a hostile environment to deter terrorists from using the UK's financial system in future. "
How much of this small amount of money was frozen due to the "vigilance" of Know Your Customer and Anti-Money Laundering systems is open to question.