For private banks and wealth managers, Know Your Customer (KYC) screening is no longer a regulatory checkbox, it has become a cornerstone of responsible client onboarding and ongoing due diligence.

Among the many tools at their disposal, open-source intelligence (OSINT), publicly available that information from the internet, has become indispensable. Adverse media screening helps uncover early warning signs of reputational, legal, or regulatory risk before they crystallise into major issues.

Yet, in practice, many institutions face a difficult paradox: how do you leverage open web searches effectively while protecting client confidentiality? In some jurisdictions, even entering a client’s name into a search engine like Google may be considered a breach of privacy law. The challenge is clear: banks must screen without leaving a digital footprint that could expose their client relationships.

The role of OSINT in KYC screening
Open-source intelligence (OSINT) broadly refers to any information that can be legally accessed from publicly available sources. In the context of KYC and due diligence, this mainly includes:

-- Adverse media: News articles, blogs, NGO reports, investigative journalism; 
-- Watchlists and sanctions: Government and regulator-maintained lists of restricted parties; 
-- Corporate registries: Information on ownership, directorship, and beneficial ownership; and 
-- Court and legal filings: Data on litigation and bankruptcy.

Adverse media has become a regulatory expectation. Bodies such as the Financial Action Task Force (FATF), the European Banking Authority (EBA), and the UK Financial Conduct Authority (FCA) all encourage financial institutions to integrate adverse media checks into their KYC programmes. Negative news can reveal certain risks that no watchlist will capture, from corruption allegations and ESG controversies to regulatory scrutiny or reputational scandals.

For private banks and wealth managers working with high net worth (HNW) and ultra-HNW clients, adverse media screening is critical. These clients often have complex financial footprints, international business interests, and public exposure, making them more susceptible to reputational risk.

The privacy challenge: When searching becomes risky
While OSINT is invaluable, its use introduces a lesser-discussed risk: the digital imprint left behind by online searches. Every time a client’s name is typed into a public search engine, there’s potential for:
1. Search visibility: Search engine operators (e.g. Google, Bing) log queries, potentially linking client names to your institution’s IP address; 
2. Data profiling: Third-party advertising ecosystems tracking search queries, sometimes enriching datasets that profile individuals and entities; 
3. Jurisdictional risk: In strict banking secrecy environments such as Switzerland, Luxembourg, or Monaco, even revealing that a client is under review may constitute a legal breach; and 
4. Reputational exposure: If investigative journalists or counterparties detect unusual search activity linked to a name, it may draw attention before any formal action is taken.

For wealth managers, who trade on discretion as much as returns, the stakes could not be higher. The reputational damage from even the appearance of a confidentiality breach could far outweigh the risk they are trying to mitigate through screening.

Why anonymity matters in adverse media screening
When it comes to screening, anonymity is both a legal and a commercial imperative. Private banks and wealth managers must ensure that:

Client names are never exposed unnecessarily
Searches do not leak to public search engines in a way that reveals a client relationship.

Regulatory expectations are balanced with secrecy laws
AML and KYC regulations demand adverse media screening, but secrecy laws demand privacy. Institutions must navigate this carefully.

Audit trails remain intact without creating external risk
Compliance teams must be able to evidence that adverse media checks were performed, but without leaving external footprints.

This is why many institutions are moving away from reliance on direct Google searches and towards specialised tools that anonymise or proxy search activity.

Techniques for anonymising searches
To reduce the risk of leaving a digital footprint, compliance teams can consider several approaches:

1. Proxy servers and VPNs
Using proxies or VPNs can mask the origin of a search, ensuring that search engines such as Google cannot easily associate a search query with a specific institution. However, this is only a partial solution, search providers may still log queries themselves.

2. Dedicated OSINT platforms
Purpose-built OSINT tools act as intermediaries, conducting searches across multiple engines and sources without exposing client names directly to the search providers. These platforms often log the activity internally for audit purposes while keeping external footprints hidden.

3. Federated search models
Instead of querying Google directly, federated search technology aggregates results from multiple sources, often through licensed data partnerships. This avoids reliance on a single search engine and significantly reduces traceability.

4. Automated screening engines
Advanced adverse media solutions integrate directly into the KYC process, using natural language processing (NLP) to extract risk-relevant facts. These tools conduct anonymised searches at scale, ensuring both coverage and confidentiality.

Balancing OSINT value with privacy obligations
Private banks and wealth managers must walk a fine line:
-- Regulators expect thorough adverse media screening to detect reputational and financial crime risks early; and 

-- Clients expect absolute discretion, and in some jurisdictions, the law requires it.

The solution lies in technology-enabled anonymity. By adopting systems that screen effectively while masking client identifiers, institutions can satisfy both sides of the equation. This balance is critical when dealing with politically exposed persons (PEPs) or clients from sensitive jurisdictions where adverse media risk may be high, but the expectation of confidentiality is even higher.

The risk of getting it wrong
Failing to manage anonymity properly can have serious consequences:

-- Legal liability: In secrecy jurisdictions, even an inadvertent disclosure may be prosecutable; 

-- Regulatory sanctions: Regulators may penalise firms for inadequate screening, especially if adverse media was missed; and 

-- Reputational harm: For private banks, reputation is everything. A single slip can result in loss of client trust and market standing.

Equally, under-screening or avoiding adverse media altogether isn’t an option. Regulators expect it, auditors will look for it, and counterparties assume it.

Towards safe and effective adverse media screening
To future-proof their operations, private banks and wealth managers should consider embedding the following best practices:

1. Embed adverse media screening into onboarding and ongoing monitoring. It should be a core component of enhanced due diligence for HNW and UHNW clients.

2. Adopt technology that combines AI with anonymised search. The most effective solutions extract and categorise risk intelligence without leaking identifiers.

3. Ensure auditability and explainability. Regulatory scrutiny is increasing under frameworks such as the EU AI Act. Screening must be both effective and explainable.

4. Train staff in operational secrecy. Even with technology in place, human error (e.g. manually Googling a client name) can undermine safeguards.

5. Align with ESG and reputational risk expectations.

Screening should extend beyond financial crime to include ESG controversies, which increasingly matter to regulators and investors alike. For private banks and wealth managers, adverse media screening using OSINT is essential, but so too is protecting client confidentiality. In a sector built on discretion, the way you search can matter just as much as what you find.

AI-powered tools that anonymise searches, process multilingual sources, and deliver explainable results at scale are quickly becoming the industry standard. They allow institutions to comply with regulatory expectations while upholding their duty of confidentiality to clients.

In the end, effective KYC in private banking means screening smarter, not louder, and uncovering the risks without leaving a trace.

About smartKYC
smartKYC is the leading provider of AI-driven KYC screening and monitoring solutions for private banks and wealth managers.

Designed to address the unique due diligence challenges of high net worth clients, smartKYC combines advanced AI, multilingual NLP and cultural nuance to deliver accurate, real-time risk insights – from onboarding through to continuous monitoring. 

Critically, smartKYC enables anonymous, non-attributable searching, ensuring that client names remain private and protected – a key requirement in many jurisdictions. By automating manual research and reducing false positives, smartKYC empowers compliance and relationship teams to make faster, smarter decisions while safeguarding reputational and regulatory integrity.

To find out more visit www.smartkyc.com.