Monthly Archives: January 2018


16% of 314(a) Info Requests Involve Terrorism

FinCEN recently released stats on the 314(a) information request program. FinCEN stated that over 16,000 financial institutions are contacted every two weeks with new subject names provided by federal, state, local and foreign law enforcement of persons who may be involved in money laundering or terrorism.   The requests contain subject and business names, addresses, more »


The Links between FINRA’s High Risk Rep Program and Expungement

Finra released a video interview on 1/10/18 with Mike Rufino,  Executive Vice President and Head of FINRA Member Regulation—Sales Practice, about FINRA’s High-Risk Registered Representative Program. Mr. Rufino discussed some of the criteria and the methodology FINRA uses to identify and monitor High Risk Registered Representatives. He listed the following criteria as inputs into the High more »


FinCEN Reports Increased 314(b) Info Sharing. DSA Finds Room for Improvement.

Dynamic Securities Analytics, Inc (‘DSA’) analyzed a FinCEN report which provided data on Suspicious Activity Reports (‘SARs’) referencing 314(b) information sharing among financial institutions.   What is 314(b)? FinCEN’s 314(b) FactSheet explains that “Section 314(b) of the USA PATRIOT Act provides financial institutions with the ability to share information with one another, under a safe harbor that more »


The Catch-22 of Marijuana Banking

Much attention has been given to Attorney General Sessions rescission of the Cole Memo which offered guidance to DOJ attorneys and law enforcement on what types of types of marijuana cases to prioritize. Lost in the commentary is the fact that FinCEN’s guidance to financial institutions regarding Marijuana Related Businesses (‘MRB’) has not changed or more »


The Mathematics Behind an Alleged Ponzi Scheme: Woodbridge Group

The SEC filed a complaint on 12/20/2017 against Robert Shapiro the former CEO of the Woodbridge Group, alleging he operated a $1.2 billion dollar Ponzi scheme. Per the complaint: Beginning in July 2012 through December 4, 2017, Defendant Robert H. Shapiro (“Shapiro”) used his web of more than 275 Limited Liability Companies to conduct a more »