Tag Archives : SAR


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 »


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 »


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 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 »


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 »


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 »


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 »


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 »


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 »