Deletion or Correction of Personal and Financial Data
DATA REMOVAL AND RISK-INTELLIGENCE DATABASE SERVICES
Impacts of AML/CFT Watchlist Listings
Financial-intelligence databases under Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regimes can have severe consequences for those listed. In practice, affected individuals and businesses often first learn of their listing only when “their bank writes and informs them that their accounts are being closed, or when a business transaction stalls,” sometimes without any prior notice. Other consequences can include frozen assets, travel bans or detention at borders, denied financing or insurance, and damage to reputation or employment prospects. In short, being flagged by these systems can lead to account closures, travel restrictions, reputational harm and widespread business disruption (for example, funding sources drying up).
Major AML/CFT Screening Databases
We regularly work with clients whose names appear in major international risk-intelligence databases. These include private data aggregators and watchlists such as LSEG’s World-Check, LexisNexis Risk Solutions (e.g. Nexis/WorldCompliance and Bankers Almanac), and OpenSanctions. Other prominent global compliance databases include Dow Jones Risk & Compliance, ComplyAdvantage, Moody’s Analytics (including Bureau van Dijk’s Orbis), and similar screening services. (Fintech and banking platforms often rely on a suite of such products for sanctions/PEP checks.) These databases consolidate information from official sanction lists, media reports and other sources to support KYC/AML due diligence.
Cross-Industry Use of Watchlists
Data from these risk databases is widely shared across sectors. In addition to banks, major global financial institutions and regulators, many fintech platforms, payment services and even transportation or logistics companies use these lists in their own screening. For example, LSEG reports that World-Check is “used and trusted by the world’s biggest companies for over two decades”, and independent analyses note its use by 49 of the world’s top 50 banks, hundreds of government agencies and thousands of organizations via background screening firms. In practice, a single flagged entry can trigger automated alerts throughout an entire network of banks, fintechs and service providers – making it difficult for the listed person or business to obtain accounts, loans or trade services from any of these parties.
Our Data Removal Services
We assist clients in correcting or deleting unjustified or outdated information from these databases. Our team prepares and submits formal remediation requests to the data providers, citing applicable legal standards and evidence. For private risk-intelligence firms (e.g. World-Check, Nexis, OpenSanctions, etc.), we work through their internal review processes – gathering documentary proof (court judgments, official statements, identity documents, etc.) and making detailed submissions to show that the listing lacks a factual basis. Where government-issued watchlists are involved (e.g. UN, EU, UK, or U.S. sanction lists), we guide clients through official delisting channels. For instance, U.S. Treasury’s OFAC provides a formal petition process to request removal from the SDN sanctions list, and United Nations sanctions committees allow individuals to petition for delisting either directly or via a Member State. In each case, we coordinate all communications, prepare required forms and legal arguments, and follow up until a determination is reached. Our global reach means we can also engage with local regulators, courts or human-rights authorities as needed to support the request.
Grounds for Removal
Successful challenges generally rely on demonstrating that the database entry is erroneous, outdated or legally disproportionate. Common grounds include:
· Factually inaccurate or obsolete information: Entries drawn from old or unreliable sources can be disproven. Risk databases often lack procedures to update or retract profiles even when facts change.
· Disproportionate use of sensitive personal data: Listings based primarily on a person’s political, religious or ethnic background may violate data protection norms. Data-protection authorities caution that processing “sensitive” personal data (such as political opinions or family ties to public figures) without consent risks unlawfulness.
· Change in legal status: If criminal charges were dropped, overturned or never pursued, that new reality can justify removal. We compile court records or official notices (such as acquittal orders or dismissal letters) to demonstrate that the original allegations no longer apply.
· Lack of any material connection to unlawful conduct: We show that the client has no credible link to the flagged offense or sanction criterion (e.g. no ownership/control of a listed company, no participation in the alleged scheme, etc.). Data-protection principles (including the GDPR’s “right to erasure”) support deletion of data that is “no longer relevant” or that cannot be justified by public-interest grounds .
Whenever possible, we assemble comprehensive evidence – such as court documents, government certificates, and expert affidavits – to back each point. By addressing the specific cause of error (wrong identity, misinterpretation of facts, political targeting, etc.), we craft persuasive petitions to each data controller or agency.
Global Process and Timeline
Our firm handles cases worldwide, navigating diverse legal regimes and languages. The data-removal process is often complex and varies by jurisdiction. In practice, private database providers typically respond within a few weeks to a few months, depending on case complexity. (One global casebook notes that removal from World-Check “usually” takes “several weeks or 1–3 months,” assuming sufficient evidence.) Government processes may take longer – delisting petitions to UN or national sanctions bodies can span many months. In total, clients should expect resolution times ranging approximately 1–12 months depending on the database involved, the need for inter-agency cooperation, and the responsiveness of the provider or regulator. Throughout, we keep clients informed of progress and advise on interim measures (such as alternative financial arrangements) where possible.
Summary
In sum, our “Data Removal” practice helps clients overcome the hidden but powerful effects of AML/CFT watchlisting. We combine legal and factual analysis to challenge unjust entries in major international risk databases, liaising with both private data firms and official authorities to secure corrections or deletions. By thoroughly documenting errors, disproving outdated claims, and leveraging global data protection rights, we work to restore our clients’ access to banking, travel, and business in a timely manner.
