Whilst serving as a compliance officer, whether it is ordinary due diligence or the enhanced variety, I often used investigative tricks to help to verify the client's personal information. Remember, never box yourself into a corner, with perennially fixed procedures, and nothing more, because innovative money launderers will test your compliance system, learn from your information requests and your responses, and adapt the next time, to pass your compliance, and gain customer entry into the bank. Remember my golden rule: money launderers who are denied accounts by approaching the bank through the front door will often use the back door, or even the trap door. This means disguising an associate, and dressing up his or her personal information, specifically to pass compliance scrutiny. They learn from their mistakes, and are highly motivated to try again at the same exact financial institution where they were formerly denied access. Call it ego, or perhaps due to pressure from their employers/clients, but good money launderers will repeatedly attempt to place a confederate in a specific bank or NBFI that they want to use for funds transfers, or for laundering of illicit cash.

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