Alison Jimenez Quoted on Foreign Corruption in

DSA president, Alison Jimenez, was quoted on foreign corruption in a article by Valentina Pasquali. The article discusses a recent Finra enforcement action resulting in a $20,000 fine.

The Finra enforcement action against BLV Securities involved allegations that proceeds from foreign corruption were laundered through the firm.

Customer A, a Brazilian citizen, was arrested in Brazil in 2018 based on his
alleged involvement in a wide-ranging public corruption and international money
laundering scheme
. After his arrest, which was reported in multiple Brazilian
news sources, BLV Securities nonetheless permitted Customer A to open 13
accounts at the firm, either in his name or the name of an entity he owed.

In 2019, Customer A sought to wire $2.5 million from a personal account at BLV
Securities to a bank account in his name in Panama. When a firm representative
asked for additional details about the purpose of the transfer, Customer A
responded by email, “[Y]ou got to be kidding me. Do I have to explain
transferring money from my account to another same owner’s account?”

A day after that transfer, Brazilian authorities approved the equivalent of a plea
agreement with Customer A, in which he admitted to participating in a money
laundering scheme and agreed to pay a multi-million dollar fine.

Alison Jimenez discussed the risk of foreign corruption in the article:

This case serves as a reminder that foreign corruption proceeds will seek out the weakest link in the U.S. financial system.

You can read the article here and the Finra enforcement action here.


To learn more about Corruption related Suspicious Activity Reports see:

A Closer Look at Corruption SARs – Dynamic Securities Analytics, Inc.

2016 SAR Insights: Suitcases of Cash No Longer the Front-Runner in Public Corruption. – Dynamic Securities Analytics, Inc.

Dynamic Securities Analytics, Inc. provides litigation consulting services to help clients successfully navigate disputes involving securities, cryptocurrency, and money laundering.