Investigative and Leak Data Sources

Investigative and leak datasets can reveal offshore links, historical relationships, intermediary networks and public-interest reporting leads. They must be handled carefully because inclusion in a leak or investigative database does not by itself prove wrongdoing.

1. Key open sources #

Source What it contains AML use Evidence limitation
ICIJ Offshore Leaks Database Offshore entities and relationships from major leak investigations Offshore structure leads, intermediary links, historical context Inclusion does not imply illegality
OCCRP Aleph Public records, leaks, court files, company data and investigative datasets Cross-border entity and document discovery Requires source-by-source verification
OpenCorporates Provenanced company data from public sources Corporate discovery and registry-source linking Coverage varies by jurisdiction

2. Safe interpretation rule #

Treat investigative datasets as lead sources unless the source itself is an official record, court record, regulator notice or directly verifiable registry record.

A finding should be described as:

  • a public-source lead;
  • an offshore data reference;
  • a document link;
  • a relationship requiring corroboration;
  • not a conclusion of criminal conduct.

3. Evidence capture #

Record the dataset name, search term, subject identifiers, date checked, source document if available, relationship type and why the result may or may not be relevant.

4. Common AML relevance #

  • offshore intermediary or service-provider links;
  • complex ownership chains;
  • repeated use of secrecy jurisdictions;
  • historical director/shareholder connections;
  • links to PEPs, sanctioned persons, fraud cases or procurement scandals;
  • unexplained mismatch between customer declaration and public records.

5. Boundary language #

Use neutral wording. Do not state that a person or company committed wrongdoing merely because they appear in a dataset. Explain the limitation clearly.

6. Source basis #