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 […]
Monthly Archives: June 2015
2 posts
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 […]