This month the new SAR form is to be rolled out by FinCEN. A mere 10 years after the collapse of the largest Ponzi scheme in history, financial institutions will now be able to report suspected Ponzi schemes with a dedicated Fraud typology checkbox. So what should financial institutions be on the look-out for regarding Ponzi more »
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 »
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 »
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 »
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 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 »
Alison Jimenez, president of Dynamic Securities Analytics, was quoted in a recent Association of Certified Financial Crime Specialists article titled “Criminals Turning to Online Rentals to Launder Money” by Brian Monroe. “Online marketplaces such as Airbnb are attractive to money launderers for several reasons,” said Alison Jimenez, President of Tampa, Fl.-based Dynamic Securities Analytics, a more »
DSA president, Alison Jimenez, has presented on a wide variety of issues ranging from AML risk assessments, to securities fraud, to SAR filings and Counter Threat Finance in Fall 2017. Fall 2017 Presentations “On High Alert(s): Managing SAR Volume and Risk with Scoring Alerts and SAR Triage”, ACAMS AML & Financial Crime Conference, September more »
Dynamic Securities Analytics, Inc. analyzed 2017 SAR-SF filings from FinCEN’s SAR Stats to identify filing trends by securities firms regulated by the SEC. Securities firms filed 5 SARs for “Other Suspicious Activity” for every 1 SAR filed relating to securities fraud schemes. Securities firms filed 4.8 SARs for Fraud schemes for every 1 Securities Fraud more »
Multiple media outlets have reported that the gunman responsible for mass shooting in Las Vegas was the subject of over 200 Currency Transaction Reports (‘CTR’) and/or Suspicious Activity Reports (‘SAR’) filings. Dynamic Securities Analytics, Inc. (‘DSA’) prepared the analysis below of 2017 Casino SAR filings for Clark County, Nevada. There were 8,028 SARs filed in more »
FinCEN Targets Luxury Real Estate FinCEN has issued a series of Geographic Targeting Orders (‘GTO’) regarding certain high dollar value real estate transactions. FinCEN explained that the GTO will “require U.S. title insurance companies to identify the natural persons behind shell companies used to pay all cash for high-end residential real estate” and file more »
Dynamic Securities Analytics president, Alison Jimenez, will moderate an ACAMS webinar September 6th titled “Dark Web: What is it, How to Leverage Information & Understand Risks.” Learning Objectives Analyzing how the Dark Web is used by criminals looking to buy, sell and exchange illegal goods and services Reviewing proactive approaches used to monitor potential cyber more »
Dynamic Securities Analytics’ 2016 Ponzi Scheme analytics has been in the news recently. Matt Levine cited the analysis in his 8/10/17 Bloomberg MoneyStuff “Truth, Yachts and Accounting” article. Levine’s thoughts on DSA’s Ponzi sentencing analysis: Stealing a million dollars from poor retirees through outright intentional fraud is worse than losing $100 million at a public company more »
Dynamic Securities Analytics, Inc. in partnership with Jordan Maglich of PonziTracker.com published interactive analytics of alleged Ponzi schemes revealed and Ponzi-related prison sentences for 2016. Key Take-Aways: 59 new alleged Ponzi schemes were revealed in 2016. This is down from 61 schemes uncovered in 2015 and 70 schemes in 2014. However, the $2.3 billion more »
Alison Jimenez, President of Dynamic Securities Analytics, Inc., was quoted in a May 16, 2017 moneylaundering.com article titled “New Sentencing Guidelines Signal Consequences for Banking Marijuana Firms” by Valentina Pasquali. The article focused on Attorney General Sessions Department Charging and Sentencing Policy issued on May 10th which Pasquali notes “directs federal prosecutors to pursue criminal more »
Alison Jimenez will be a featured speaker at the Digital Finance Institute’s #FinTech2017 conference in Vancouver, Canada on May 3rd, 2017. Ms. Jimenez will be presenting on AML, FinTech and the legalized marijuana industry. Alison’s analysis of Suspicious Activity Reports involving marijuana related business has been cited by the Wall Street Journal, Huffington Post and more »
Pyramid Scheme SAR Filings Spike Dynamic Securities Analytics (“DSA’) has identified a trend in pyramid schemers utilizing social media platforms to execute their fraud. DSA analyzed FinCEN SAR Stat data and found a 340% increase in pyramid scheme Suspicious Activity Report (‘SAR’) filings by Money Services Businesses (‘MSB’) in monthly filing rates in 2017 more »
Alison Jimenez will be a panelist on the ACAMS International AML & Financial Crimes Conference panel, “The Algorithm is Your Friend: Creating and Using Them to Strengthen AML” in Hollywood, FL., April 3-5, 2017. Ms. Jimenez is the author of “Unmasking Bias in Anti-Money Laundering Algorithms” which was published in the Fall 2017 Issue of ACAMS Today. She served as more »
Dynamic Securities Analytics, Inc. (“DSA”) reviewed the SEC’s and FINRA‘s 2017 exam priorities letters to identify AML areas of focus. There are a few areas where the two regulators’ priorities overlap: suspicious activity monitoring, cyber security and elder financial exploitation. The focus on elder abuse is a new area for the SEC this year whereas more »
Dynamic Securities Analytics, Inc (“DSA”) analyzed 2016 SAR filings reported in FinCEN’s SAR Stats database. DSA will be posting a series of articles on the analysis with today’s post covering financial instruments used in suspicious activity. Visual Relationships The bubble chart below shows the relationships between Suspicious Activity Types, Products, Instrument (ie. payment mechanism) more »
Dynamic Securities Analytics, Inc (“DSA”) analyzed 2016 SAR filings reported in FinCEN’s SAR Stats database. DSA will be posting a series of articles on the analysis with today’s post providing a general overview and key findings. Key Findings Elder abuse saw the largest jump in SAR filings with an increase of 117% over 2015 more »
DSA president, Alison Jimenez, presented on emerging technology and analytics at the 2016 US Special Operations Command Working Group on Counter Threat Finance.
ACAMS Today published an article titled “Unmasking Bias in AML Algorithms” by DSA president, Alison Jimenez, in the Sept- Nov 2016 issue. As anti-money laundering (AML) departments increase their reliance on analytics and algorithms, the need to unmask potential bias in AML algorithms is a topic that can no longer be avoided. The article more »
Part of the Problem Anti-Money Laundering (“AML”) regulatory enforcement actions often cite poor AML training as contributing to the environment that allowed a violation to occur at a financial institution. Very often, the same enforcement action mandates more AML training. That makes me wonder why doing more of something that the financial institution was doing more »
In my upcoming article titled “Unmasking Bias in AML Algorithms” in the September/October edition of ACAMS Today, I explore the potential for bias (racial, ethnic, religious, gender, etc.) in Anti-Money Laundering algorithms used by financial institutions to detect potential suspicious activity. The most serious outcome of activity flagged by an AML algorithm results in more »
The Tampa Bay Business Journal published an article titled “Financial crimes experts get in the weeds over marijuana banking services” by Margie Manning. DSA president, Alison Jimenez, was quoted several times about the challenges that financial institutions have dealing with state-legalized marijuana businesses. The financial institutions often find themselves facing a Catch-22 situation, whether more »
Alison Jimenez, president of Dynamic Securities Analytics, will present on the topic “Mitigating Risks and Reaping Rewards of Social Media in AML/CTF Regimes” at the 2016 Association of Certified Anti-Money Laundering Specialists conference in Las Vegas. Key Areas Covered Adapting onboarding processes that mitigate the unique payment platform, KYC and sanctions risks posed by more »
Alison Jimenez, president of Dynamic Securities Analytics, Inc. (DSA), will be a panelist for the July 19, 2016 Association of Certified Anti-Money Laundering Specialists (ACAMS) webinar “Achieving Compliance Efficiency Amid Heightened Regulatory Scrutiny.” This is a one-hour complementary webinar offer by ACAMS. Learning Objectives Detailing increased scope and pace of enforcement actions to demonstrate more »
DSA president, Alison Jimenez, will be speaking on a panel titled “Adopting Compliance Strategies for Banking Hedge Funds and other Alternative Investments” at the 22nd annual ACAMS AML & Financial Crimes conference.
Alison Jimenez, President of Dynamic Securities Analytics (“DSA”), was interviewed for an article titled “Securities Firms Offer Warm(er) Reception to Marijuana Industry, Says Former Examiner” by Larissa Bernardes of moneylaundering.com. The interview centered around securities firms’ interactions with state-legalized marijuana businesses. Below is a excerpt: Which questions should broker-dealers be asking when they’re approached more »
Once again, Dynamic Securities Analytics, Inc. partnered with PonziTracker to create interactive analytics of Ponzi schemes uncovered or sentenced in 2015. There were 61 alleged Ponzi Schemes uncovered in 2015 while sentences were handed down for 69 schemes. The total value of the uncovered schemes was over $800 million. Read the full analysis at www.ponzitracker.com. more »
Dynamic Securities Analytics, Inc. president, Alison Jimenez, will speak at the February 9th, 2016 meeting of the Tampa chapter of the Association of Certified Fraud Examiners (“ACFE”). Ms. Jimenez will discuss Securities Fraud and provide case studies. The ACFE is the world’s largest anti-fraud organization and premier provider of anti-fraud training and education. Together with more more »
FINRA and the SEC recently released their respective 2016 exam & regulatory priorities. DSA reviewed the priorities for topics that directly or indirectly touch on AML issues. While there is overlap in the areas of cybersecurity, market manipulation and microcap securities, the two regulators diverge on other AML priorities. DSA prepared the comparison below: more »
The Credit Union Journal published a slideshow version of Alison Jimenez’ Op-Ed on Marijuana Banking Myths. See the full article here. DSA’s analysis of marijuana-related Suspicious Activity Reports was also cited in “Shh! Here’s How Cannabis Companies are Banking on the Low Down” by Bruce Barnett.
American Banker published an Op-Ed by DSA president Alison Jimenez, co-authored with Steven Kemmerling of MRB Monitor. The Op-Ed titled “Banks Weighing Pot Business Find Haze of Misinformation” explains and corrects five common myths regarding marijuana businesses and financial services. Read the full article here.
A recent American Banker article titled “Don’t Bet on Pot-Banking Fix in New Year” by Chris Cumming referenced DSA’s analysis of Suspicious Activity Reports regarding the marijuana industry. See DSA’s marijuana SAR analysis here.
Alison Jimenez, president of Dynamic Securities Analytics, Inc (“DSA”), was recently appointed to the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) Education Task Force. ACAMS is the largest international organization, now at 30,000 members worldwide, dedicated to enhancing the knowledge and skills of AML and financial crime professionals from a wide range of industries with more »
Dynamic Securities Analytics’ analysis of marijuana-related SARs was cited by the Wall Street Journal. The WSJ: Risk and Compliance Journal included DSA’s analysis in the latest edition of “Corruption Currents.” See DSA’s analysis of securities broker’s engaging with marijuana-related businesses here and how the latest SAR data has international implications here.
Dynamics Securities Analytics, Inc. was cited in a recent American Banker article titled “Legal Clash Exposes Contradictions in Fed’s Pot-Banking Rules” by Chris Cummings. Read DSA’s blog post “New Marijuana Banking SAR Data has International Implications” to learn more about how financial institutions are engaging with marijuana-related businesses.
By Alison Jimenez, Dynamic Securities Analytics, Inc. and Steven Kemmerling, MRB Monitor The quickly-growing state-legalized marijuana industry creates a number of unique compliance and AML/BSA challenges for Financial Institutions (“FIs”).^ MRB Monitor, which helps financial institutions mitigate risk related to the industry, has identified 8,000+ Marijuana Related Businesses (“MRBs”). As such, it may be naïve to more »
By Alison Jimenez, Dynamic Securities Analytics, Inc. and Steven Kemmerling, MRB Monitor Securities Brokers Engaging with Marijuana Businesses Forty-one securities brokers filed Suspicious Activity Reports (“SARs”) regarding Marijuana Related Businesses from February 2014 through July 1, 2015. The count includes securities firms that terminated marijuana accounts. Securities brokers accounted for 8% of the financial more »
Dynamic Securities Analytics president, Alison Jimenez, was quoted in today’s Bloomberg article by Neil Weinberg on broker raiding cases. The article titled “Brokers’ Battle Over Memorial Day Raid Reveals Industry Strains” discusses a current Finra arbitration between Oppenheimer & Co. and Euro Pacific Capital. Ms. Jimenez commented on the number of raiding cases resolved more »
The latest issue of ACAMS Today features an article by Steven Kemmerling and Brian Arrington titled “Conflict and Uncertainty: Due Diligence Challenges for Marijuana-Related Businesses.” The article cites DSA’s analysis of marijuana-related Suspicious Activity Reports (SARs). The full article can be read here.
The Marijuana Businesses Access to Banking Act of 2015 bill’s stated purpose is: to create protections for depository institutions that provide financial services to marijuana-related businesses, and for other purposes. A press release by one of the co-sponsors, Senator Jeff Merkley (D-OR), points out the following: “Forcing businessmen and businesswomen who are operating legally under Oregon state law more »
It’s Suspicious to Not be Suspicious SEC Enforcement Chief Andrew Ceresney made headlines when he said: I can say that the number of firms that filed zero SARs or one SAR per year was disturbingly large. Unfortunately, Chief Ceresney did not provide the number of broker-dealer firms that filed zero or 1 SAR more »
Dynamic Securities Analytics, Inc. (“DSA”) analyzed Suspicious Activity Reports (SARs) filed with FinCEN from March 2012 through March 2015 that identified “Bribery/Gratuity” as the activity at issue. The analysis was undertaken to understand the characteristics of customer activity identified as potential bribery from a financial institution’s viewpoint. Key Takeaways: 1,780 SARs were filed more »
Get the latest stats on the individuals and entities under indictment or convicted in the FIFA corruption scandal. Search the roster by charge, charge status, and nationality. See the bottom table for key stats like age, title and role. FIFA Indictment & Conviction Roster
In the modern age of bitcoin and computer algorithms, it appears that old-fashioned cash transactions initially tipped off the government to the alleged crimes by former Speaker of the House, Dennis Hastert and FIFA officials. Money laundering can be quite complex. For example, one of the alleged schemes in the FIFA indictment involved moving funds more »
DSA president, Alison Jimenez, will speak on two anti-money laundering topics at this fall’s Association of Certified Anti-Money Laundering Specialists (ACAMS) conference in Las Vegas. On September 28th, Alison will be part of a panel discussion titled “This Joint is Jumping: Practical Coping Strategies for Ever-Shifting Marijuana Laws” and on the 29th, she will present more »
On April 22nd, 2015 FinCEN released In Focus: SAR Stats (April 2015). Dynamic Securities Analytics, Inc. (“DSA“) analyzed the new Suspicious Activity Report-Securities/Futures (“SAR-SF”) data and found that Market Manipulation/Wash Trades SARs have increased 63% from 2014 and 105% from 2013 levels (on a quarterly basis)*. The same day FinCEN released the latest SAR Stats, Navinder more »
DSA President, Alison Jimenez, will be a featured speaker for the upcoming American Banker webinar “Managing AML/KYC Compliance Risk, Rather Than Avoiding It.” The live webinar will be held May 11th from 12:00-1:00 EST. Registration is available through the American Banker website. A description of the webinar can be found below. Complimentary Web Seminar May 11, more »
Matt Ferner of the Huffington Post cited DSA’s analysis of Suspicious Activity Reports (SARs) in his article titled “Some Banks are Working with Marijuana Businesses, but they Remain Wary.” DSA president, Alison Jimenez, was also quoted in the article. See an excerpt below: DSA notes the total reports (SARs) filed add up to 3,341 more »
Rachel Louise Ensign of the Wall Street Journal reported on DSA’s analysis of Suspicious Activity Reports (SARs) regarding marijuana-related businesses. “More than 1,700 suspicious activity reports using the phrase “marijuana limited” have been filed from 25 states since the agency of the U.S. Department of the Treasury in February advised financial institutions to use more »
By Alison Jimenez, Dynamic Securities Analytics & Steven Kemmerling, Enhanced Compliance Solutions Pursuant to a Freedom of Information Act (FOIA) request, on April 6th the Financial Crimes Enforcement Network (“FinCEN”) provided Dynamic Securities Analytics (“DSA”) with new data on Suspicious Activity Report (“SAR”) activity relating to “marijuana industries.” In the disclosure to DSA, FinCEN reported that 3,157 more »
Dynamic Securities Analytic Inc. president, Alison Jimenez, will present a workshop on “Building Robust Anti-Fraud Firewalls” at the 20th Annual Association of Certified Anti-Money Laundering Specialists (ACAMS) conference in Hollywood, Florida on March 18th. ACAMS is the largest international membership organization dedicated to enhancing the knowledge and skills of AML and financial crime professionals from more »
Dynamic Securities Analytics, Inc. analyzed the numbers provided by FINRA Dispute Resolution covering all 2014 closed cases and found: 2,447 closed Customer cases, representing 64% of all closed cases 7% of Customer cases were closed via arbitration with damages awarded to the Customer Non-Customer Cases 1,391 Non-Customer cases (ex. Employee vs. Firm, Firm more »
Jordan Maglich of Ponzitracker.com wrote an in depth article that analyzed Ponzi schemes revealed and sentenced in 2014. See the excerpt below or read the full article here. Despite a burgeoning economy, increased regulation, and heightening scrutiny on financial crime, data compiled by Ponzitracker shows that Ponzi schemes continued to be uncovered at a steady pace more »
Dynamic Securities Analytics analyzed the latest FinCEN In Focus: SAR Stat report and found that SAR-Securities & Futures filings increased by 45% in 2014 over 2013 filings. 22,448 SAR-SFs were filed in 2014 versus 15,457 in 2013. Try out DSA’s interactive analytics below. SAR-SFs can be filtered by activity type, percentage and count change from more »
FinCEN released In Focus: SAR Stats (Jan 2015 Quarterly Update) which includes all 2014 Suspicious Activity Reports (SARs). In total, FinCEN reported 1,726,731 SARs filed in 2014 compared against 1,276,002 filed in 2013. This is a 35% increase in SAR filings over the 2013 levels. Major Increases in Most Industries Dynamic Securities Analytics, Inc. analyzed the FinCEN more »