Have compliance databases gone too far? The case of World-Check

“The compliance infrastructure has grown into a monster, flagging every potential risk and swamping banks with false positives, while those truly involved in criminal networks are largely unaffected” stated David Leppan, the founder of World-Check.

Initially, World-Check was created to act as an “early warning system” for individuals who pose financial risks (such as those who may end up being put on a sanctions list).

Over time, financial institutions started to ask about “politically exposed persons” (“PEPs”), and the idea emerged that such individuals should be tracked and categorised. However, there were at the time no standard definitions or procedures for assessing political risk or reputational risk.

World Check’s founder has stated that issues have emerged with the precision of World-Check as a checking tool, by virtue of the database covering over six million profiles and focusing on minor offences, as opposed to only major offences such as bribery, corruption and terrorism. It has also led to the creation of false positive ‘hits’ when searching for an individual, caused by a lack of specificity in the database’s programming.

The consequences of getting a World-Check profile can be devastating. Individuals may be mistakenly flagged and may find themselves “de-banked” (having their accounts closed by virtue of having a profile on World-Check). If the individual has savings, mortgages or business accounts tied to this bank, the implications of such de-banking are notably severe. Such individuals may thereafter see their problems compounded – for example by experiencing difficulties opening an account with alternative banks in light of their World-Check profile.

What did the founder recommend?

Firstly, David Leppan recommended that databases, such as World-Check, ensure that their platforms are kept up-to-date as they continue to grow, in order to limit the possibility of false positive ‘hits’. Secondly, he stressed that a strict definition must be applied to who should be identified as a ‘PEP’.

How can we help?

Incorrect information about me on World-Check is having a detrimental effect: what can I do about it?

Gherson’s financial crime team has recently assisted two individuals in correcting their World-Check profiles.

Indeed, we are increasingly being approached by individuals who feel that incorrect information about them as displayed on compliance databases is having an adverse effect on them, whether by unduly harming their reputation and/or preventing them from properly accessing banking facilities and financial products.

The incorrect information on these databases often stems from biased media articles or the databases not undertaking proper due diligence or applying the incorrect criteria, such as whether the individual is a PEP.

General procedure: if the information on a compliance database file is wrong

If you think that the information held about you on a compliance database file is wrong (including an incorrect categorisation as a PEP), based on false information, or if you suspect that someone else may have used your details, there is a process which can be followed which should hopefully achieve some redress.

The first stage in this process is to ascertain whether you have been listed on one or more of these compliance databases. This may arise via communication from an entity that relies on these databases, such as a bank informing you that you are unable to open an account or apply for a loan with them, or from making direct enquiries with a particular database under applicable data protection laws.

What information is being shared?

Once this is established, the next step is to understand what information, whether incorrect, misleading or inaccurate, is being circulated and shared through these databases. Depending on your individual circumstances, this may be relatively simple to deduce, though the particulars of this information may be difficult to determine.

Having a firm grasp of the law and regulatory frameworks that govern this area is of particular importance here; Gherson have a wealth of experience in this field and can assist you to understand what you are facing.

How can I amend the information on these databases?

Most compliance databases have internal mechanisms in place for individuals to attempt to update or correct the contents of data subject reports about them. The individual will need to have valid reasons for doing so and to produce documentary evidence in support of their assertions. Being identified incorrectly as a PEP could be a relevant reason, especially is supported by evidence.

Importantly, the legislation in this field does not automatically guarantee individuals the absolute right to have their personal data expunged or amended in accordance with their wishes.

These databases will only accede to requests where they are compelled to do so: indeed, these databases make every effort to free themselves of any liability for publishing potentially false, inaccurate or misleading information by specifically informing subscribers of a number of caveats, which include emphasising the need for users to conduct their own independent checks to verify the credibility of information displayed in the report.

As such, it is advisable to consult experienced legal professionals to assist with navigating this complex legal and regulatory landscape.

What can I do to try and challenge a wrong decision to close my personal and/or business bank account(s)?

We are increasingly being approached by individuals who have been “de-banked” in circumstances where they are adamant that they have always acted in full compliance with the relevant bank account’s Terms and Conditions and all other legal and applicable rules and regulations.

We have previously written about how other issues individuals may face, including account closures, are not limited to political figures in the UK and affect many thousands of lawful individual and business customers every year. These cases have exposed the difficult balance many financial institutions and their individual and business customers must strike to gain and maintain access to basic banking services.

To assist those whose accounts have been closed, Gherson’s financial crime, investigations and regulatory team have previously written the following blogs:

“Why has my bank account been closed”

“Why has my business bank account been closed?”

“140,000 SMEs “de-banked” last year – why could I have been de-banked?”

“What are the proposed new laws aimed at preventing de-banking?”

“Why the proposed new laws to try and prevent de-banking to not go far enough”

“Am I entitled to a basic bank account in the UK?”

What can I do to try and challenge a wrongly-imposed CIFAS marker

We are also being approached increasingly by individuals who feel that a financial institution has wrongly imposed a CIFAS marker in their name.

If you have always acted in full compliance with the relevant bank account’s Terms and Conditions and all other applicable legal rules and regulations, then you should have a good basis to challenge the bank’s decision to implement any CIFAS markers.

A strong challenge will often involve demonstrating through evidence that you have not breached the bank’s Terms and Conditions or any rules and regulations, and that all transactions were at all times carried out in full compliance will all applicable laws and regulations.

In a previous blog, we examined what a CIFAS marker is and how to try and get it removed and also what you can do if a CIFAS marker has been wrongly imposed.

We have also recently examined the issue of crypto-related CIFAS marker – see out blog: Challenging a crypto-related CIFAS Marker: what you can do.

NAVIGATING FINANCIAL INSTITUTION-RELATED CHALLENGES

Adverse Information on Compliance Databases

We are also being approached increasingly by individuals who feel that incorrect and/or inaccurate data about them stored in compliance databases is having an adverse effect on their relationship with financial institutions and who are facing subsequent problems such as bank accounts closures and difficulties in opening a bank account.

We have also written a series of blogs with a basic overview of the main functions of compliance databases like World-Check and how you can correct information about yourself on such databases.

Updated: 17 July 2025

HOW GHERSON CAN ASSIST

Gherson’s regulatory, white-collar and investigations team are highly experienced in providing assistance with what you can do if your bank freezes or closes your account. This includes assisting you in submitting a request under data protection legislation, otherwise known as a Data Subject Access Request, to ascertain what information banks and other financial institutions may be holding on you and their decision-making, and then analysing the response and assisting with any appropriate challenge.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025