Author Archives : Alison Jimenez


American Banker Op-Ed on Risk of Bias in Financial Regulators Algorithms   Recently updated !

American Banker published an op-ed by DSA president, Alison Jimenez, titled “AI use carries bias risk for financial regulators.” Ms. Jimenez discusses the need for financial regulators to be aware of the risk of bias within their own supervisory algorithms. The article examines how bias can inadvertently and explicitly enter algorithms and highlights potential issues more »


DSA President Selected to Participate in Countering Transnational Organized Crime Program at the George C. Marshall Center on European Security Studies

DSA president, Alison Jimenez, was selected to participate in the Countering Transnational Organized Crime (CTOC) program held at the George C. Marshall Center on European Security Studies in Garmisch, Germany. The CTOC program invited 104 participants from 53 countries to develop strategies to disrupt and degrade transnational organized crime and terror groups. Participants represented governmental more »


Alison Jimenez Interviewed by ABC News on EB-5 Fraud Schemes

DSA president, Alison Jimenez, was interviewed by ABC news for a story on the EB-5 Immigrant Investor program. The EB-5 program allows immigrant investors to apply for permanent residence if they make an investment of $500,000 in a commercial enterprise that creates or preserves 10 jobs for US workers. The EB-5 program is the US-equivalent more »


DSA Partners with PonziTracker.com for Analytics of 2018 Ponzi Schemes

Dynamic Securities Analytics, Inc. in partnership with Jordan Maglich of www.ponzitracker.com prepared interactive analytics of alleged Ponzi schemes revealed in 2018 and of Ponzi-related prison sentences handed down in 2018. Click here to read the full PonziTracker write-up. The interactive analytics can be filtered by state, scheme size and Months Sentenced per $1Million stolen.


DSA Winter 2018/Spring 2019 Presentations

Dynamic Securities Analytics, Inc.’s president, Alison Jimenez, wrapped up 2018 with two very different presentations. In October, Ms. Jimenez participated as a private sector representative invitee at the 2018 Department of Defense/United States Special Operations Command Counter Threat Finance Working Group. The CTF Working Group topic was The Evolution of Counter Threat Finance. In November more »


DSA’s Human Trafficking SAR Analysis cited in MoneyLaundering.com

Dynamic Securities Analytics, Inc.‘s original analysis of the first reported Human Trafficking and Human Smuggling SAR filings was cited in a www.moneylaundering.com article “US Banks, MSBs File Few SARS on Human Trafficking and Smuggling” by Daniel Bethencourt. “Many of the SARs filed on suspected smuggling originated from U.S. border states, such as Texas and California, more »


WSJ Features DSA’s 2018 Suspicious Activity Reports Analysis

The Wall Street Journal’s Corruption Currents section referenced Dynamic Securities Analytics, Inc’s 2018 SAR Insights blog post. Here’s a few highlights from DSA’s analysis of Suspicious Activity Reports filed in 2018 in the US: A first look at the new Human Trafficking and Human Smuggling SAR options. There are marked differences in reporting by Banks and Money Services Businesses more »


2018 SAR Insights: Suspicious Activity Reports Annual Analysis

With 2018 in the books, Dynamic Securities Analytics, Inc. returns with our annual analysis of Suspicious Activity Reports (‘SARs’). This time we focused on SARs filed in 2018 by Depository Institutions, MSBs and Securities/Futures firms. Something Old Some SAR categories have been tried and true out-performers. The top three SAR categories for both Banks and more »


Want to Circumvent AML laws? Buy a Bank

The Venezuela corruption/bribery/pilfering of national coffers scandal has a re-occurring theme: alleged conspirators buying or controlling banks. According to indictments and criminal complaints, at least four banks were purchased or controlled by individuals alleged to have taken part in the international money laundering schemes. What better way to circumvent AML laws than to own the more »


DSA’s Securities Employment Dispute Stats Cited by Bloomberg

A story by Neil Weinberg in Bloomberg relied on Dynamic Securities Analytics (‘DSA’) analysis of Finra employment arbitration results.   DSA found that arbitrators sided with brokers in the majority of cases, finding that the employment termination U5 forms contained false, inaccurate and/or defamatory information. However, even when arbitrators found the information defamatory, they rarely more »


The Potential for Bias against Women in FINRA’s High Risk Rep Algorithm

The move toward data analytics applied to broker supervision might seem on face value to result in objective identification of “high risk” financial advisers. However, once the technical jargon is stripped away, algorithms are just opinions embedded in mathematics. Algorithms are created by humans and can reinforce human prejudices.  Researchers have noted that big data used in algorithms more »


A Closer Look at Corruption SARs

With all the talk of corruption in the news these days, Dynamic Securities Analytics  has taken a closer look at corruption-related Suspicious Activity Reports (‘SARs’) filed by financial institutions. SARs have separate categories for Domestic and Foreign corruption, we analyzed both.   Domestic vs. Foreign SAR Filing Leaders Differ   15,498 suspected corruption SARs were more »


Alison Jimenez to Present at Economic Crime Symposium at Cambridge University

DSA president, Alison Jimenez, will serve as a panelist at the 36th Cambridge International Symposium on Economic Crime. Ms. Jimenez will present at the “Regulatory Technology Innovation” workshop on September 5th, 2018.   Ms. Jimenez is an economist/data scientist, a software designer and former securities regulator, and appreciates the prospect of technology improving regulatory compliance. more »


Updated SAR Form and Ponzi Schemes

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 »


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 »


DSA President Quoted regarding Online Rental Money Laundering Scheme

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 2017 Fall/Winter Presentations

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 »


Securities Fraud Schemes Account for less than 10% of SAR-SF Filings

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 »


Casino CTR / SAR Filings & the Las Vegas Shooting Investigation

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 »


Are Title Insurance Companies Meeting Luxury Real Estate AML Requirements?

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 »