Dow Jones Risk & Compliance: 7 Key Questions About the Database and Profile Removal

Dow Jones Risk & Compliance is a popular online risk assessment system used worldwide by international banks, financial institutions, government agencies, and commercial companies to check counterparties. Inclusion in the system can lead to consequences such as refused transactions at foreign banks and difficulties purchasing real estate abroad.

If you have questions about our approach, please submit a request, and Avagard Global experts will respond promptly.

The Dow Jones system allows organizations to minimize the risks of facilitating illicit activities such as money laundering, terrorist financing, and other criminal activities with little effort. For example, poor compliance can carry serious reputational risks for banks and result in millions of dollars in fines, including license revocation and closure.

In 2014, for example, BNP Paribas, the largest bank in Europe, paid an $8.9 billion fine for processing dollar payments to Iran, Sudan, and Cuba, all of which were under U.S. economic sanctions. In addition to the fine, the bank was prohibited from performing certain financial transactions for several years. These serious consequences have prompted many banks to establish risk assessment systems and tighten compliance procedures.

Although risk assessment systems aren't mandatory for state and financial regulators, they're now a gold standard for compliance procedures, and most organizations rely on them.

Based on data from systems like Dow Jones, banks decide whether to open an account for a client or approve financial transactions, migration services decide whether to issue a residence permit, government agencies decide whether to allow the purchase of real estate or opening a company, and foreign companies decide whether to cooperate with a business.

Databases like Dow Jones are often integrated into the IT systems of large organizations, which simplifies the process of checking counterparties.

Therefore, it's important to know how entities are added to the Dow Jones database to avoid being denied:

• A residence permit or the purchase of real estate in another country
• Services from international banks
• Cooperation with foreign companies
• Opening a company in another country

The following individuals are most often included in Dow Jones:

• Politically Exposed Persons (PEPs): Individuals who, due to their high position in the government, could potentially be involved in corruption and money laundering (e.g., officials, deputies, and managers of state-owned companies).
• Individuals associated with PEPs: Relatives and business partners.
• Sanctioned individuals and their associates
• Financial offenders: Individuals involved in money laundering or financing illegal activities.
• Defendants in criminal cases and their associates
• Individuals involved in high-profile political and financial scandals or victims of "black PR."

As you can see, a wide range of individuals can be included in the Dow Jones database, which leaves room for interpretation. You don't have to be a criminal to be included in the Dow Jones system. Sometimes, a few media publications with unreliable or outdated information, such as about cooperation with state-owned companies or a reputational scandal, are enough.

Dow Jones, like World-Check and LexisNexis, aggregates open-source data, collecting publicly available information about individuals from the internet. This includes official sources, such as sanctions lists and information from government agencies about criminal cases, financial criminals, and terrorists.

Dow Jones also collects information from open sources, including the media, social networks, and other articles online, which can lead to an unfounded inclusion in the database. For example, a person may be included if they were only a witness in a high-profile criminal or financial crime, not a defendant. Similarly, a person may be included if they were the victim of a "black PR" campaign by competitors alleging unfair activities.

In general, both risk assessment systems use a similar algorithm and similar, though not identical, sources. They share the same official resources, but their open sources may differ.

According to Avagard Global specialists, if a person is included in one risk assessment system, they will likely be included in others. Recent cases have also shown that Dow Jones updates information faster than World-Check. For example, Dow Jones updated its information when a person was removed from sanctions lists, while World-Check had not.

Another factor is that different international organizations, even within the same jurisdiction, can use both risk assessment systems simultaneously. There are also regional preferences; for example, Dow Jones is more common in EU countries, while World-Check is more common in the USA and the Middle East.

If you need to check a person's status in Dow Jones Risk & Compliance quickly, Avagard Global specialists can complete the process within one business day.

If a Dow Jones Risk & Compliance check reveals that a person is on the list, Avagard Global specialists offer a systematic approach using a well-developed algorithm, which offers a high chance of deleting or adjusting the profile in Dow Jones (including removing PEP status). The algorithm is similar to the approach used to adjust profiles in World-Check.

Here are the four steps:

In the first stage, Avagard Global specialists analyze the client's dossier in the compliance database to determine the reason for inclusion. Based on this, they select the best strategy for removal. For example, a person may be included in Dow Jones based on outdated information about connections with government agencies. Media mentions may list the person as an official or an employee of a state-owned company, even though they left the position long ago and are now engaged in entrepreneurial activity.

At this stage, the Avagard Global team studies all mentions of the person on the first page of Yandex and Google search results in both Russian and English. Because the Dow Jones system can aggregate information in more than 50 languages, it's important to analyze search engines in the client's jurisdiction in addition to the English results.

The analysis considers not only overtly negative references (e.g., information about court cases, financial fraud, or corruption) but also any potential risk factors, such as connections to the government (not just as an official or politician, but also as a businessman close to the authorities), state awards, participation in state projects, or reputational scandals.

The Dow Jones system considers a wide range of compliance risks, so it's important to address any potential "red flags."

Depending on the scale and nature of the unreliable or outdated information that needs to be neutralized, a strategy for adjusting the digital footprint is selected.
There are four main tools:

• Removal: Negotiating with site owners to remove content.
• Legal mechanisms: De-indexing content, using the right to be forgotten, and litigation.
• Search Engine Reputation Management (SERM): Managing a person's or brand's reputation in search results by displacing negative content.

To maximize the chances of having your profile removed from Dow Jones, you should neutralize outdated data and remove defamatory or compromising information. You should also publish articles in authoritative and cited media outlets about the client's current status, creating a positive image, such as leaving politics for private business.
Without a comprehensive approach to managing a digital footprint, a person risks worsening their situation by requesting removal from the database. When compliance officers re-check the person to review the application, they may detect additional risk factors and add them to the dossier.

Once your digital footprint is successfully managed, Avagard Global specialists will help you collect the necessary documents to request removal from Dow Jones.

Therefore, the decision to include a person in the Dow Jones database can be changed, but only if there are valid grounds and a comprehensive effort has been made.