Category Archives : Money Laundering Enforcement


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 »


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 »


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.    


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 »


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 »


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 »


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 »


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 »


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 »


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 »


DSA to Present Ponzi Scheme / AML Webinar

DSA President, Alison Jimenez, will be among the presenters for an Association of Certified Anti-Money Laundering Specialists (ACAMS) webinar on Ponzi Schemes. The webinar will be held on November 25th, 2014. Jordan Maglich of Wiand Guerra King and the creator of PonziTracker.com will also be speaking.   Case Study: Dissecting the Inner Workings of Recent Ponzi more »


How is your State Suspicious? An Interactive Suspicious Activity Report (SAR) Map

Learn About Tableau     My goal was to create an interactive map of Suspicious Activity Reports (SARs) to determine what customer activity was reported as “suspicious” in each state. I planned to then declare that “Mississippi Tops the Ranks in ___ Fraud” and “Ohio is the Riskiest State for ____.” Instead, I was schooled more »


Is 179,000,000 Bank Secrecy Act records enough?

FinCEN’s record retention policy is detailed in the “Request For Records Disposition Authority” that FinCEN submitted to the National Archives and Records Administration. FinCEN’s policy for retaining CTRs, FBARs and SARs is as follows: Delete/destroy data when 11 years old or when no longer needed for administrative, legal, audit, or other operational purposes, whichever is later. Older, more »


Should the Currency Transaction Report Threshold be $60,900?

When the Bank Secrecy Act passed in October 1970 with the $10,000 Currency Transaction Report (CTR) threshold, the average US annual salary was $6,186. A new car cost $3,900 and the Jackson 5’s song “I’ll be There” was number one on the Billboard charts. All that has changed, except for the Currency Transaction Report threshold.   more »


How do SARs and Federal Money Laundering Convictions Compare?

In 2012 there was 1 federal money laundering conviction per 2,047 Suspicious Activity Reports (SARs) filed. If Currency Transaction Reports (CTRs) are included, then there was 1 federal money laundering conviction for every 19,379 CTR & SAR filed. Looking at trends from 2003 through 2012, the number of federal money laundering cases commenced decreased by 26.8% while all SAR filings more »