Tag Archives : AML


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 »


DSA cited in Wall Street Journal

Rachel Louise Ensign of the Wall Street Journal reported on DSA’s analysis of Suspicious Activity Reports (SARs) regarding marijuana-related businesses.   “More than 1,700 suspicious activity reports using the phrase “marijuana limited” have been filed from 25 states since the agency of the U.S. Department of the Treasury in February advised financial institutions to use 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 »


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 »


How to Run a Successful Ponzi Scheme

Like any small business, Ponzi schemes can  be a flash in the pan or a long term endeavor, all depending on management. It is suspected that Madoff’s scheme went on for decades before it crumbled. The math behind running a long-term Ponzi scheme is fairly straightforward. If inflows and outflows are managed properly, the scheme 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 »


Alison Jimenez to Present on Employee Due Diligence at ACAMS Conference

  DSA president, Alison Jimenez, will be a panelist on the “Total Due Diligence: Know Your Customer, Vendors and Employees” presentation at the 13th Annual ACAMS AML and Financial Crime conference in Las Vegas. The presentation will be Tuesday, September 30th at 3:15. Ms. Jimenez will be speaking on Employee Due Diligence. Her fellow panelist 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 »


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 »


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 »


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 »