Tag Archives : AML


Alison Jimenez to Present at Economic Crime Symposium at Cambridge University

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 »


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 »


The Catch-22 of Marijuana Banking

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 »


DSA President Quoted regarding Online Rental Money Laundering Scheme

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 »


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 »


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 »


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 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 »


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.    


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   Recently updated !

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.


Federal Marijuana Banking Bill Leaves Key Issues Unresolved   Recently updated !

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 »


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