Tag Archives : suspicious activity report


DSA 2017 Fall/Winter Presentations

DSA president, Alison Jimenez, has presented on a wide variety of issues ranging from AML risk assessments, to securities fraud, to SAR filings and Counter Threat Finance in Fall 2017.   Fall 2017 Presentations “On High Alert(s): Managing SAR Volume and Risk with Scoring Alerts and SAR Triage”, ACAMS AML & Financial Crime Conference, September 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 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 »


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 »


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

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.


New Marijuana Banking SAR Data has International Implications

By Alison Jimenez, Dynamic Securities Analytics, Inc. and Steven Kemmerling, MRB Monitor   The quickly-growing state-legalized marijuana industry creates a number of unique compliance and AML/BSA challenges for Financial Institutions (“FIs”).^ MRB Monitor, which helps financial institutions mitigate risk related to the industry, has identified 8,000+  Marijuana Related Businesses (“MRBs”). As such, it may be naïve to more »


DSA’s Analysis of Suspicious Activity Reports cited in ACAMS Today

The latest issue of ACAMS Today features an article by Steven Kemmerling and Brian Arrington titled “Conflict and Uncertainty: Due Diligence Challenges for Marijuana-Related Businesses.” The article cites DSA’s analysis of marijuana-related Suspicious Activity Reports (SARs). The full article can be read here.    


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 »


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 »


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 »


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 »


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 »