Author Archives : Alison Jimenez


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 »


Alison Jimenez to Moderate Panel on the Dark Web & AML

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 »


DSA’s Ponzi Analytics in the News

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 »


Would you spend 21 days in prison for $1 million dollars? 2016 Ponzi Scheme Analytics

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 quoted on Sentencing Guideline Implications

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 to Present at #FinTech2017

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 »


Silicon Valley & Social Media at Center of Pyramid Scheme Surge

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 to Speak at ACAMS Spring Anti-Money Laundering Conference

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 »


2017 Securities Regulator AML Exam Priorities vs. SAR-SF Filings

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 »


2016 SAR Insights: Suitcases of Cash No Longer the Front-Runner in Public Corruption.

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 »


2016 Suspicious Activity Reports: Most Industries Increase Filings, Securities the Exception. Elder Abuse has Largest Increase in SARs.

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 »


Unmasking Bias in AML Algorithms

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 »


AML Training: Part of the Problem or Part of the Solution?

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 »


FinCEN Doesn’t Track Bias in SAR Filings. Should it?

  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 »


Alison Jimenez quoted in article on AML & Marijuana Banking

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 to Present on Social Media & AML at ACAMS Conference

  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 to Present on AML Regulatory Enforcement

  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 »


Alison Jimenez to Present on Hedge Funds at Anti-Money Laundering Conference

  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.    


RegTelligence Featured in Tampa Bay Business Journal

A Tampa Bay Business Journal article by Margie Manning featured RegTelligence– your comprehensive source for regulatory analytics. RegTelligence is a FinTech / RegTech application that pulls together and analyzes financial services regulatory enforcement actions. Over 300 different regulators are contained within RegTelligence.   The app can help answer several different kinds of questions, such as which regulators more »


Alison Jimenez Interviewed by MoneyLaundering.com

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 »


DSA Partners with PonziTracker for 2015 Ponzi Scheme Analytics

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 »


Alison Jimenez to Present on Securities Fraud at ACFE Meeting

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 »


SEC vs. FINRA: 2016 AML Priorities

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 »


Credit Union Journal Features DSA’s Op-Ed

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.  


Op-Ed on Marijuana Banking Published in American Banker

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.


Alison Jimenez Appointed to ACAMS Education Task Force

  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 »


Wall Street Journal cites DSA’s Analysis of SARs

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.


Dynamic Securities Analytics cited in American Banker

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.


New Marijuana Banking SAR Data has International Implications

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 »


Securities Brokers have (Relatively) Open Arms to Marijuana Businesses

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 »


Alison Jimenez Quoted in Bloomberg Article on Broker Raiding Cases

  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 »


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Bates Group Launches RegTelligence- The number one source for intelligence on financial industry regulator behavior

RegTelligence™ is the first comprehensive database of all regulatory enforcement actions. PR Newswire LAKE OSWEGO, Ore., Sept. 9, 2015 LAKE OSWEGO, Ore., Sept. 9, 2015 /PRNewswire/ — Bates Group LLC, the nation’s leading provider of financial industry expertise, today announced RegTelligence™, a game-changing, unified source for SEC, FINRA, CFTC, and other federal agencies, state and foreign regulatory enforcement actions involving more »


DSA’s Analysis of Suspicious Activity Reports cited in ACAMS Today

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.    


Federal Marijuana Banking Bill Leaves Key Issues Unresolved

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 »


Why 35% of Broker-Dealers File Zero SARs.

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 »


What does Bribery Look Like?

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 »


FIFA Indictment & Conviction Roster

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


What do the Dennis Hastert & FIFA Indictments have in Common?

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 »


Alison Jimenez to Present on Marijuana Industry & Insider Fraud at AML Conference

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 »


Suspicious Activity Reports for Market Manipulation Spikes

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 »


Alison Jimenez to Present at American Banker AML/KYC Webinar

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 »


DSA’s Analysis of Suspicious Activity Reports cited in Huffington Post

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 »


DSA cited in Wall Street Journal

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 »


Alison Jimenez to Present at ACAMS Conference on Anti-Fraud Firewalls

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 »


How were 2014 FINRA Disputes Resolved? Analysis of Dispute Resolution Statistics

  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 »


Ponzi Schemes Continue to Proliferate in 2014

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 »


45% Spike in SAR- Securities & Futures in 2014

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 »


2014 Suspicious Activity Report filings Jump 35%

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 »


Alison Jimenez to Present on Problem Employees & AML Risk

  DSA President, Alison Jimenez, will be a speaker for the upcoming Association of Certified Anti-Money Laundering Specialist (ACAMS) webinar “Spotting and Removing Problem Employees.” The live webinar will be held May 13th from 12:00-2:00 EST. Registration is available through the ACAMS website. A full description of the webinar can be found below. Spotting and more »


How to Run a Successful Ponzi Scheme

Like any small business, Ponzi schemes can  be a flash in the pan or a long term endeavor, all depending on management. It is suspected that Madoff’s scheme went on for decades before it crumbled. The math behind running a long-term Ponzi scheme is fairly straightforward. If inflows and outflows are managed properly, the scheme more »


1st rule of SARs: You do not talk about SARs. 2nd rule of SARs: You do NOT talk about SARs.

SARs Rules #1 Do not talk about SARs #2 Do NOT talk about SARs   It may seem odd but the Suspicious Activity Report (SAR) confidentiality  rules are almost identical to the Fight Club rules. While there are confidentiality exemptions for sharing information within a financial services institution or with law enforcement, there remains a more »


The Man in the Mirror: Employee Due Diligence

Fill in this blank:  __________________ Due Diligence. If you are like most AML professionals, “Customer” was the first and only answer that came to mind. The importance of Customer Due Diligence has been drummed into the mind of AML practitioners and is a common training topic. However, the recent indictment of a former TD Bank more »


What Crime is the Largest Source of Laundered Funds?

Drug dealers get the most attention but tax evasion is by far the largest source of laundered funds. DSA analyzed US crime estimates 1 and found that there is $14.06 in dirty money generated from tax evasion for every $1 generated by illegal drug sales. Similarly, tax evasion generates $3.81 dollars to every $1 for other more »


Alison Jimenez to Present on Employee Due Diligence at ACAMS Conference

  DSA president, Alison Jimenez, will be a panelist on the “Total Due Diligence: Know Your Customer, Vendors and Employees” presentation at the 13th Annual ACAMS AML and Financial Crime conference in Las Vegas. The presentation will be Tuesday, September 30th at 3:15. Ms. Jimenez will be speaking on Employee Due Diligence. Her fellow panelist more »


Customers are the Minority of SAR Subjects

Customers Represent the Minority of SAR Subjects for Most Institutions   DSA analyzed FinCEN’s SAR Stats report to assess the nature of the filer’s relationship with the SAR subject. Securities/Futures,Money Services Businesses (MSB), Insurance or Other Firms^ characterize the filer/subject relationship as “customer” in less than 1/3 of Suspicious Activity Reports (SARs).  The filer/subject relationship was more »