Category Archives : Broker Dealers


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 »


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 »


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 »


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 »


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 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 »


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 »


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.


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 »


The Cost of Not Conducting an Independent AML Audit

If you are an AMLCO or CCO who must justify the cost of your firm’s annual independent AML audit, the PDF  Download FINRA 2010 AML Audit fines should help you.  The cost of not conducting an independent anti-money laundering audit is steep. The PDF contains excerpts compiled from 2010  FINRA Monthly Disciplinary Reports.  Fines were imposed for either more »