COMSURE’s Enhanced Open-Source Intelligence (OSINT) Due Diligence investigation – challenges and rewards

INTRODUCTION

Comsure is regularly instructed to undertake OSINT investigations. Instructions include looking for such matters as:-

• PEP exposure,
• Adverse media confirmation, 
• Red flag RISK exposure and
• Connections in company control

SUCCESS

Recently, a Comsure report highlighted to a client that there was a REAL AND PRESENT DANGER of the target of the investigation being hit with an OFAC sanction.

The Comsure observation was correct. The question is, did the client who commissioned the report act on it right away?

THE INSTRUCTION

Concerning a recent instruction, I wanted to share the challenges that our expert team will encounter.

COMSURE have been instructed to undertake an Enhanced Open-Source Intelligence (OSINT) Due Diligence investigation into

• Individual A’s wealth,
• Ownership of Company B, and
• The substantial increase in Company B’s value,

This investigation will be fraught with difficulties and challenges outlined below:

THE CHALLENGES

I have outlined the anticipated challenges, drawing on general OSINT principles and the complexities highlighted in relevant sources while critically assessing potential limitations.

1. UNDERSTANDING HOW INDIVIDUAL A MADE ALL HIS MONEY

Information Gaps in Public Records:

• Tracing an individual's financial history relies heavily on publicly available data, such as corporate filings, property records, legal documents, and media reports. However, public records often provide only a partial picture, especially in jurisdictions with limited transparency or where Individual A may have operated discreetly.
• For instance, high-net-worth individuals usually use complex structures like trusts or shell companies to obscure their wealth, which OSINT may struggle to penetrate fully without proprietary or non-public data.

Opaque Offshore Structures:

• If Individual A’s wealth is tied to offshore accounts or entities in jurisdictions with high secrecy (e.g., Cayman Islands, Panama), OSINT may uncover only surface-level connections.
• Confirming beneficial ownership or tracing funds through such structures can be challenging without access to private financial records or leaks like the Panama Papers.

Reliance on Unstructured Data:

• Much relevant information (e.g., social media posts, news articles, or blog mentions) is unstructured, requiring sophisticated natural language processing (NLP) and link analysis to identify patterns. Manual analysis risks missing subtle connections, while automated tools may produce false positives or fail to contextualise nuanced financial activities.

Time-Intensive Verification:

• Cross-referencing data from diverse sources (e.g., 600 billion+ archived web pages, 198 million+ corporate records) to verify the legitimacy of wealth sources is time-consuming.
• Even with AI-driven tools, ensuring zero false positives, as claimed, requires human judgment to interpret ambiguous or conflicting data, particularly if Individual A has a long or complex financial history.

Ethical and Legal Constraints:

• OSINT must adhere to legal and moral boundaries, limiting investigations to publicly available data.
• Suppose Individual A’s wealth stems from activities not documented in open sources (e.g., private investments or illicit dealings).
• In that case, the investigation may end without crossing into restricted methods like human intelligence (HUMINT).

2. DETERMINING HOW INDIVIDUAL A CAME TO OWN COMPANY B

Complex Ownership Structures:

• Company B’s ownership may involve layered corporate entities, nominees, or trusts, especially if Individual A sought to conceal their stake.
• Public registries in some jurisdictions (e.g., the UK’s Companies House) may list directors or shareholders, but others lack searchable ownership data or allow incomplete filings.
• If the structure is intentionally opaque, OSINT techniques like inspecting government gazettes or annual returns may still fail to reveal beneficial owners.

Historical Data Limitations:

• If the acquisition occurred years ago, archived records may be incomplete or inaccessible.
• Not all historical corporate changes (e.g., private share transfers) are publicly documented.
• Reconstructing the ownership timeline could require combining fragmented media reports or social media intelligence, which may lack reliability.

Hidden Transactions:

• If Individual A acquired Company B through private deals, mergers, or unreported transactions, OSINT may uncover only indirect evidence, such as sudden directorships or media speculation changes. 

Jurisdictional Variations:

• If Company B operates across multiple countries, different regulatory requirements complicate the investigation.
• Some jurisdictions mandate public disclosure of ownership, while others do not.
• Navigating these variations demands expertise in local corporate law and access to region-specific databases, which may not be fully integrated into OSINT platforms.

Potential for Misinformation:

• Public sources, including social media or news, may contain inaccurate or biased reports about Individual A’s acquisition.
• Filtering out misinformation to avoid incorrect conclusions requires rigorous validation, which can slow the investigation and introduce uncertainty.

3. EXPLAINING COMPANY B’S SUBSTANTIAL INCREASE IN VALUE

Limited Financial Transparency:

• If Company B is privately held, detailed financial statements may not be publicly available, unlike public companies, which must file with regulators like the SEC.
• OSINT can leverage corporate registries or media reports to estimate value growth.
• However, precise figures (e.g., revenue, profits) may be absent, forcing reliance on indirect indicators like market trends or competitor analysis.

Complex Value Drivers:

• Company B’s value increase could stem from strategic partnerships, intellectual property, market expansion, or inflated transactions to attract investors.
• Identifying these drivers requires analysing vast datasets (e.g., 40,000+ media sources from 100+ countries) and correlating them with Company B’s activities, which is resource-intensive and may yield incomplete insights.

Speculative or Hidden Factors:

• If the value surge involves non-public factors (e.g., undisclosed government contracts, private investments, or accounting manipulations), OSINT may struggle to provide definitive answers.
• For instance, while geospatial intelligence or social media analysis can reveal operational growth (e.g., new facilities), they cannot access internal financial strategies.

Time-Sensitive Data:

• Company B’s value may have risen due to recent market developments or regulatory changes, requiring real-time monitoring.
• Capturing fleeting market sentiments or unindexed news requires constant vigilance and may miss critical short-term events.

Competitive Analysis Challenges:

• Understanding Company B’s value growth often involves comparing it to industry peers. OSINT tools can provide competitive intelligence, but benchmarking against private competitors with limited public data introduces uncertainty.
• Additionally, distinguishing genuine growth from market hype or manipulation requires nuanced human analysis beyond automated tools.

OVERARCHING DIFFICULTIES ACROSS ALL OBJECTIVES

Potential for Evasion:

• Sophisticated individuals like Individual A may actively obscure their digital footprint using privacy services, VPNs, or minimal online presence.
• This counters OSINT’s effectiveness, especially for social media intelligence or geolocation techniques, leaving investigators reliant on less direct methods

Information Overload:

• The sheer volume of open-source data (e.g., billions of web pages, millions of corporate records) creates a risk of drowning in irrelevant information.
• Prioritising actionable intelligence over noise demands clear objectives and skilled analysts.

Accuracy and Reliability:

• Public data can be outdated, incomplete, or misleading (e.g., PR-driven news).
• Ensuring accuracy requires cross-verification across multiple sources, which is time-consuming and may leave gaps if primary data is unavailable.

Regulatory and Ethical Compliance:

• OSINT investigations must comply with privacy laws (e.g., GDPR) and avoid unethical data collection.
• This limits the depth of personal or financial insights, particularly for Individual A, and requires careful documentation to ensure findings are admissible in legal or business contexts.

COMSURE ENGAGEMENT STARTS WITH

To start any engagement, we begin with an initial discovery review. This gives us a good sense of the investigation and its challenges, and at this time, we can manage our clients' expectations.

Good afternoon   

Thank you for your follow-up email advising of your needs that are:-

• Understand how Individual A made all his money and
• How Individual A came to own Company B and
• How has Company B increased in value so substantially?

Based on the above, a COMSURE Enhanced Open-Source Intelligence (OSINT) Due Diligence Report (DDR), Comsure's initial fee for research into an individual and two entities will start at £POA.

Please note that this fee is based on an initial discovery review.

Because of your instructions, more hours will likely be recommended. The reason is that an OSINT investigation into Individual A’s wealth, ownership of Company B, and its value surge faces challenges like:-

• Incomplete public records, and records availability, e.g. behind paywalls or not electronically available
• Opaque offshore structures and complex ownership layers.
• Unstructured data and legal constraints hinder tracing wealth sources.
• Historical data gaps and hidden transactions may limit the uncovering of Company B's acquisition.
• Limited financial transparency and speculative factors complicate explaining its value growth.
• Information overload, misinformation, and regulatory compliance further complicate the process.

Until we review the individual and company details, we cannot determine whether additional work, if any, is needed, but extra hours may be required.

If you would like any further information, please feel free to ask.

Kind regards,Mathew

If you want to know more about Comsure services, please:

• Email mathew@comsuregroup.com
• Go to www.comsuregroup.com
• Call Mathew on 00441534626841