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 »
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 »
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 »
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 »
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 »
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 »
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 »
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 »
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 »
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 »
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 »
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 »
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 »
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 (“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 »
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.
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.
