President-elect Donald Trump once called for “extreme vetting” of immigrants. After he said it, no one agreed or disagreed. Instead, they asked, “What’s extreme vetting?” Trump’s definition of extreme vetting is more of a value test, which involves interviewing prospective immigrants on whether they agree with many American core belief systems, like religious freedom and gender equality. Trump’s version of extreme vetting is a bit of a misnomer, as it is more of an ideological vetting. Extreme vetting doesn’t examine ideology, it uses various processes and technologies to do deep-level background checks and risk assessments.
For example, say you want to do extreme vetting on someone in the financial service sector. You certainly couldn’t conduct the same kind of investigation that Trump proposes, in which you ask them about their religion and politics. In fact, if you did that, you’d be violating several federal laws designed to prevent discrimination in employment. That’s not even to mention that the person’s answers wouldn’t necessarily indicate whether or not they are right for the job. Extreme vetting can help you find the best workers when you’re in the private sector, but you also need to ensure that this process stays on the right side of the law.
Best Practices for Hiring Financial Workers
The financial services sector has no standard model for vetting candidates, but in 2005 the Federal Deposit Insurance Corporation (FDIC) laid out some strategies for pre-employment vetting of financial services workers. These steps include:
- Completing state and federal level criminal background checks – This especially requires checking for any prior violations which would make someone unemployable under Section 19 of the Federal Deposit Insurance Act. This section makes it so that anyone who’s ever been convicted of a crime of dishonesty, breach of trust, or money laundering is permanently prohibited from working at any FDIC insured business.
- Taking fingerprint cards for searching crime databases – While the US criminal database system is good, it’s not infallible. If someone changes their name, for example, their criminal background check might not show crimes they were convicted of prior. However, they can’t change their fingerprints, which will allow you to uncover crimes that a standard background check won’t.
- Requiring candidates to complete written applications – Resumes are good, but they won’t include information that a candidate doesn’t want to share, like prior convictions. A written application forces the candidate to disclose certain things that may disqualify them.
- Doing credit checks which must comply with the Fair Credit Reporting Act – While companies generally can choose whatever profile they want for what they consider acceptable, if a candidate is turned down due to credit, they must be given notice that this was the reason. You may have to provide them with a copy of their credit report as well.
While these are the basic things that the FDIC recommends, they still don’t rise to the level of extreme vetting. For that, you’ll need to go a little deeper and take a few more steps.
Extreme Vetting for Financial Workers
Generally, extreme level vetting will involve several additional tactics, on top of the tactics the FDIC recommends. These include:
- Conducting in-person interviews with individuals from the candidate’s past, like coworkers and acquaintances. This is different from simply calling references, as the investigator will not use the individual’s references, but will instead conduct interviews with individuals they locate through an independent records search.
- Doing online searches and social media reviews to locate additional information like prior names, employers and other publicly available information. This can also be used as a source to find acquaintances who can be interviewed.
- Conducting database searches for corporate filings, civil court records, probate records, UCC filings and property records. This allows the investigator to find violations that the individual may not have committed under their own name, but instead as part of a corporate entity.
- Using biometric testing during interviews to determine the future risk level of a candidate. Technology like Remote Risk Assessment (RRA) can facilitate this. RRA analyzes the human voice using proprietary technology to measure risk when a candidate answers important questions like, “Have you ever committed a crime involving fraud?” Or, “Have you ever stolen from an employer?”
In this listing of extreme vetting tools, RRA alone provides the ability to identify as high-risk someone who does not appear on a database because they have not yet been caught. These extreme vetting tactics are best used for individuals who will have positions of high responsibility and access to clients’ funds.
AC Global Risk provides RRA technology as a means of doing extreme level vetting on candidates working in sensitive positions. It’s the fastest, most convenient way to get accurate results regarding a potential candidate’s risk so that you can make the right hiring decisions. Contact us today if you’re interested in adding this technology to your employee vetting process.