Adverse Media

1. Practical definition #

Adverse media is negative public-source information that may indicate ML/TF/PF, sanctions, fraud, corruption, organised crime, regulatory enforcement or other financial crime risk.

2. Why this matters for AML practitioners #

Adverse media can reveal risk not visible in customer documents. But bad media must be assessed carefully: source quality, identity match, recency, relevance and severity all matter.

3. Trigger events #

  • New onboarding.
  • Periodic review.
  • PEP review.
  • Sanctions proximity review.
  • Alert involving fraud/corruption/enforcement.
  • Sudden change in customer activity.
  • External news or regulator update.

4. Source basis #

  • SRC-FATF-001: RBA, CDD, EDD, STR/SAR and record keeping.
  • Local override: some regulators prescribe adverse media scope, sources and review frequency.

5. Practitioner workflow #

  1. Build search strings: exact name, aliases, transliterations, prior names, directors, UBOs and company names.
  2. Search reputable sources and selected open web sources.
  3. Separate subject identity from namesakes.
  4. Classify content type: allegation, investigation, prosecution, conviction, enforcement, regulatory action, sanctions, civil dispute, insolvency, reputational commentary.
  5. Assess recency and relevance to proposed relationship.
  6. Assess credibility: official source, court/regulator, major media, local media, blog/forum, anonymous content.
  7. Link facts to AML risk factors.
  8. Ask for explanation only if doing so does not create tipping-off risk.
  9. Produce adverse media memo.

6. Evidence to collect #

  • Search queries used.
  • Search date/time.
  • Source links.
  • Screenshot or archived copy where policy permits.
  • Summary of relevant facts.
  • Identity match rationale.
  • Customer explanation where obtained.
  • Analyst relevance assessment.

7. Source quality scale #

Level Examples Weight
Very high Regulator, court, FIU/public authority, official sanctions notice Strong evidence
High Established financial press, major national media, official company registry Important evidence
Medium Local media, specialist blogs, industry databases Corroborate if possible
Low Anonymous posts, forums, social media claims Use as lead only

8. Red flags #

Medium#

  • Old allegation with no follow-up.
  • Civil dispute unrelated to financial crime.
  • Low-quality source with plausible but unverified claim.

High#

  • Multiple independent reports of fraud/corruption/misappropriation.
  • Ongoing investigation by regulator or law enforcement.
  • Regulatory penalty for AML, sanctions or fraud controls.
  • Customer/UBO/director named in major bribery or embezzlement case.

Critical#

  • Conviction or enforcement for ML/TF/PF, sanctions evasion or organised crime.
  • Official notice ties subject to sanctions, terrorist financing or proliferation financing.
  • Customer explanation is false or contradicts official records.

9. Decision matrix #

Media result Required action
No relevant media Record search terms and date
Low-quality or unrelated Record and do not overweight
Relevant but explainable EDD / document explanation
Serious and recent MLRO escalation
Official financial crime/sanctions finding Critical escalation

10. Example output #

# Adverse Media Memo

Subject: [name/entity]
Search scope: [names/aliases/languages]
Sources reviewed: [list]
Relevant findings: [facts only]
Identity match: [confirmed/likely/uncertain/unrelated]
Source quality: [very high/high/medium/low]
AML relevance: [low/medium/high/critical]
Customer explanation: [if obtained]
Recommendation: [clear/EDD/escalate/decline]
Source basis: SRC-FATF-001
Evidence index: [links/screenshots]

Wolfsberg negative-news screening layer#

SRC-WOLF-005 provides industry-practice guidance for negative-news screening. It supports:

  • risk-based search scope;
  • source and allegation classification;
  • identity resolution;
  • materiality and relevance assessment;
  • governance, quality control and recordkeeping.

It is industry best practice, not binding law. A media result remains a review input and should be traced to reliable underlying reporting or primary records where possible.