Category Archives : Regulatory Analytics


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 »


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 »


1Q14 FINRA Disciplinary Actions: Law Firm Representation Stats

Dynamic Securities Analytics, Inc. (DSA) analyzed 1Q14 FINRA Disciplinary Actions Letters of Acceptance, Waiver & Consent (AWC) to determine legal representation trends. There were 164 AWCs during the first quarter of 2014. DSA broke down the analysis between disciplinary actions that named a firm versus those that named an individual. Broker/Dealers 67 AWCs named a Broker/Dealer 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 »


DSA’s Ponzi Analytics cited by The Street

The Street published an article by Philip van Doorn titled “Ponzi Scheme Database May Shock You” in which Dynamic Securities Analytics, Inc’s interactive Ponzi scheme visualization was cited. The first decade of the 21st century goes down as the “golden age” for Ponzi schemes. In the aftermath of Bernard Madoff’s epic 20-year scheme to defraud investors — more »


Should AML Departments be renamed Anti-Predicate Crime?

DSA analyzed the SAR-SF filing data reported by FinCEN to determine whether firms more often report suspicious money laundering activity or suspected predicate crimes. Every Anti-Money Laundering (AML) intro course teaches that money laundering is composed of three steps: Introduction, Layering and Integration. However, first must come a crime that generates illicit proceeds. Predicate crimes more »


Analysis of 2013 FINRA Dispute Resolution Statistics

DSA analyzed how cases were closed through the FINRA dispute resolution process in 2013. Customer Cases FINRA reported that in 2013 there were 499 Customer Complaint cases decided by Arbitration (paper & hearing) and in 212 of these cases, the customer was awarded damages. Based on the statistics provided by FINRA, DSA determined: 2,772 Customer more »


DSA’s Analytics cited in Herald Tribune Article

DSA’s analysis of Florida Ponzi schemes in the post-Madoff era was cited in the Sarasota Herald Tribune front page story “Florida’s Wealth a Magnet for Ponzi Schemes” by John Hielscher. Hielscher cited DSA’s ranking of Florida ponzi schemes and sentencing comparisons. DSA president, Alison Jimenez, was quoted on why Florida ranked so high in the more »


Interactive Ponzi Scheme Analytics

DSA prepared interactive analytics of over 500 Ponzi schemes in the post-Madoff era. The schemes can be filtered and analyzed by year, state, dollar value and months sentenced per million $. DSA partnered with Jordan Maglich of PonziTracker.com on this project.     Learn About Tableau


Business Journal Features DSA’s Ponzi Analytics

The Tampa Bay and Jacksonville Business Journals featured DSA’s analytics of Florida Ponzi Schemes. Jane Meinhart quoted DSA president, Alison Jimenez, in the “Ponzi schemers at Home in Florida” article. DSA partnered with Jordan Maglich of Wiand Guerra King to prepare the analysis. The analysis shows Florida ranks third in the county in the total value more »


Are Nebraskans Really the Most Suspicious People in the Nation?

If you gauge suspicious activity by the Financial Crimes Enforcement Network’s (FinCEN) “By the Numbers” report on the Securities & Futures Industries, then yes.  By FinCEN’s tally, Nebraska accounted for 7.31% of all SAR-SF filings from January 1, 2003 through June 30, 2008. Three states had higher counts (New York, Massachusetts & California) but Nebraska is more »