Alison Jimenez will present on regulatory algorithms at the World Bank- Law, Justice & Development Week.
Alison Jimenez
111 posts
Alison Jimenez explores the money laundering risks posed to financial institutions by EB-5 related-accounts in an ACAMSToday article.
Alison Jimenez, president of Dynamic Securities Analytics, Inc. recently presented on an ACAMS webinar titled "Strengthening Your Anti-Bribery and Corruption Oversight."
American Banker published an op-ed by DSA president, Alison Jimenez, titled “AI use carries bias risk for financial regulators.” Ms. Jimenez discusses the need for financial regulators to be aware of the risk of bias within their own supervisory algorithms. The article examines how bias can inadvertently and explicitly enter algorithms and highlights potential issues […]
DSA president, Alison Jimenez, was selected to participate in the Countering Transnational Organized Crime (CTOC) program held at the George C. Marshall Center on European Security Studies in Garmisch, Germany. The CTOC program invited 104 participants from 53 countries to develop strategies to disrupt and degrade transnational organized crime and terror groups. Participants represented governmental […]
DSA president, Alison Jimenez, was interviewed by ABC news for a story on the EB-5 Immigrant Investor program. The EB-5 program allows immigrant investors to apply for permanent residence if they make an investment of $500,000 in a commercial enterprise that creates or preserves 10 jobs for US workers. The EB-5 program is the US-equivalent […]
Dynamic Securities Analytics, Inc. in partnership with Jordan Maglich of www.ponzitracker.com prepared interactive analytics of alleged Ponzi schemes revealed in 2018 and of Ponzi-related prison sentences handed down in 2018. Click here to read the full PonziTracker write-up. The interactive analytics can be filtered by state, scheme size and Months Sentenced per $1Million stolen.
Dynamic Securities Analytics, Inc.’s president, Alison Jimenez, wrapped up 2018 with two very different presentations. In October, Ms. Jimenez participated as a private sector representative invitee at the 2018 Department of Defense/United States Special Operations Command Counter Threat Finance Working Group. The CTF Working Group topic was The Evolution of Counter Threat Finance. In November […]
Dynamic Securities Analytics, Inc.‘s original analysis of the first reported Human Trafficking and Human Smuggling SAR filings was cited in a www.moneylaundering.com article “US Banks, MSBs File Few SARS on Human Trafficking and Smuggling” by Daniel Bethencourt. “Many of the SARs filed on suspected smuggling originated from U.S. border states, such as Texas and California, […]
The Wall Street Journal’s Corruption Currents section referenced Dynamic Securities Analytics, Inc’s 2018 SAR Insights blog post. Here’s a few highlights from DSA’s analysis of Suspicious Activity Reports filed in 2018 in the US: A first look at the new Human Trafficking and Human Smuggling SAR options. There are marked differences in reporting by Banks and Money Services Businesses […]
With 2018 in the books, Dynamic Securities Analytics, Inc. returns with our annual analysis of Suspicious Activity Reports (‘SARs’). This time we focused on SARs filed in 2018 by Depository Institutions, MSBs and Securities/Futures firms. Something Old Some SAR categories have been tried and true out-performers. The top three SAR categories for both Banks and […]
The Venezuela corruption/bribery/pilfering of national coffers scandal has a re-occurring theme: alleged conspirators buying or controlling banks. According to indictments and criminal complaints, at least four banks were purchased or controlled by individuals alleged to have taken part in the international money laundering schemes. What better way to circumvent AML laws than to own the […]
A story by Neil Weinberg in Bloomberg relied on Dynamic Securities Analytics (‘DSA’) analysis of Finra employment arbitration results. DSA found that arbitrators sided with brokers in the majority of cases, finding that the employment termination U5 forms contained false, inaccurate and/or defamatory information. However, even when arbitrators found the information defamatory, they rarely […]
The move toward data analytics applied to broker supervision might seem on face value to result in objective identification of “high risk” financial advisers. However, once the technical jargon is stripped away, algorithms are just opinions embedded in mathematics. Algorithms are created by humans and can reinforce human prejudices. Researchers have noted that big data used in algorithms […]
With all the talk of corruption in the news these days, Dynamic Securities Analytics has taken a closer look at corruption-related Suspicious Activity Reports (‘SARs’) filed by financial institutions. SARs have separate categories for Domestic and Foreign corruption, we analyzed both. Domestic vs. Foreign SAR Filing Leaders Differ 15,498 suspected corruption SARs were […]
DSA president, Alison Jimenez, will serve as a panelist at the 36th Cambridge International Symposium on Economic Crime. Ms. Jimenez will present at the “Regulatory Technology Innovation” workshop on September 5th, 2018. Ms. Jimenez is an economist/data scientist, a software designer and former securities regulator, and appreciates the prospect of technology improving regulatory compliance. […]
This month the new SAR form is to be rolled out by FinCEN. A mere 10 years after the collapse of the largest Ponzi scheme in history, financial institutions will now be able to report suspected Ponzi schemes with a dedicated Fraud typology checkbox. So what should financial institutions be on the look-out for regarding Ponzi […]
FinCEN recently released stats on the 314(a) information request program. FinCEN stated that over 16,000 financial institutions are contacted every two weeks with new subject names provided by federal, state, local and foreign law enforcement of persons who may be involved in money laundering or terrorism. The requests contain subject and business names, addresses, […]
Finra released a video interview on 1/10/18 with Mike Rufino, Executive Vice President and Head of FINRA Member Regulation—Sales Practice, about FINRA’s High-Risk Registered Representative Program. Mr. Rufino discussed some of the criteria and the methodology FINRA uses to identify and monitor High Risk Registered Representatives. He listed the following criteria as inputs into the High […]
Dynamic Securities Analytics, Inc (‘DSA’) analyzed a FinCEN report which provided data on Suspicious Activity Reports (‘SARs’) referencing 314(b) information sharing among financial institutions. What is 314(b)? FinCEN’s 314(b) FactSheet explains that “Section 314(b) of the USA PATRIOT Act provides financial institutions with the ability to share information with one another, under a safe harbor that […]
Much attention has been given to Attorney General Sessions rescission of the Cole Memo which offered guidance to DOJ attorneys and law enforcement on what types of types of marijuana cases to prioritize. Lost in the commentary is the fact that FinCEN’s guidance to financial institutions regarding Marijuana Related Businesses (‘MRB’) has not changed or […]
The SEC filed a complaint on 12/20/2017 against Robert Shapiro the former CEO of the Woodbridge Group, alleging he operated a $1.2 billion dollar Ponzi scheme. Per the complaint: Beginning in July 2012 through December 4, 2017, Defendant Robert H. Shapiro (“Shapiro”) used his web of more than 275 Limited Liability Companies to conduct a […]
Alison Jimenez, president of Dynamic Securities Analytics, was quoted in a recent Association of Certified Financial Crime Specialists article titled “Criminals Turning to Online Rentals to Launder Money” by Brian Monroe. “Online marketplaces such as Airbnb are attractive to money launderers for several reasons,” said Alison Jimenez, President of Tampa, Fl.-based Dynamic Securities Analytics, a […]
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 […]
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 […]
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 […]
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 […]
Dynamic Securities Analytics president, Alison Jimenez, will moderate an ACAMS webinar September 6th titled “Dark Web: What is it, How to Leverage Information & Understand Risks.” Learning Objectives Analyzing how the Dark Web is used by criminals looking to buy, sell and exchange illegal goods and services Reviewing proactive approaches used to monitor potential cyber […]
Dynamic Securities Analytics’ 2016 Ponzi Scheme analytics has been in the news recently. Matt Levine cited the analysis in his 8/10/17 Bloomberg MoneyStuff “Truth, Yachts and Accounting” article. Levine’s thoughts on DSA’s Ponzi sentencing analysis: Stealing a million dollars from poor retirees through outright intentional fraud is worse than losing $100 million at a public company […]
Dynamic Securities Analytics, Inc. in partnership with Jordan Maglich of PonziTracker.com published interactive analytics of alleged Ponzi schemes revealed and Ponzi-related prison sentences for 2016. Key Take-Aways: 59 new alleged Ponzi schemes were revealed in 2016. This is down from 61 schemes uncovered in 2015 and 70 schemes in 2014. However, the $2.3 billion […]
Alison Jimenez, President of Dynamic Securities Analytics, Inc., was quoted in a May 16, 2017 moneylaundering.com article titled “New Sentencing Guidelines Signal Consequences for Banking Marijuana Firms” by Valentina Pasquali. The article focused on Attorney General Sessions Department Charging and Sentencing Policy issued on May 10th which Pasquali notes “directs federal prosecutors to pursue criminal […]
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 […]
Pyramid Scheme SAR Filings Spike Dynamic Securities Analytics (“DSA’) has identified a trend in pyramid schemers utilizing social media platforms to execute their fraud. DSA analyzed FinCEN SAR Stat data and found a 340% increase in pyramid scheme Suspicious Activity Report (‘SAR’) filings by Money Services Businesses (‘MSB’) in monthly filing rates in 2017 […]
Alison Jimenez will be a panelist on the ACAMS International AML & Financial Crimes Conference panel, “The Algorithm is Your Friend: Creating and Using Them to Strengthen AML” in Hollywood, FL., April 3-5, 2017. Ms. Jimenez is the author of “Unmasking Bias in Anti-Money Laundering Algorithms” which was published in the Fall 2017 Issue of ACAMS Today. She served as […]
Dynamic Securities Analytics, Inc. (“DSA”) reviewed the SEC’s and FINRA‘s 2017 exam priorities letters to identify AML areas of focus. There are a few areas where the two regulators’ priorities overlap: suspicious activity monitoring, cyber security and elder financial exploitation. The focus on elder abuse is a new area for the SEC this year whereas […]
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) […]
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 […]
DSA president, Alison Jimenez, presented on emerging technology and analytics at the 2016 US Special Operations Command Working Group on Counter Threat Finance.
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
DSA president, Alison Jimenez, will be speaking on a panel titled “Adopting Compliance Strategies for Banking Hedge Funds and other Alternative Investments” at the 22nd annual ACAMS AML & Financial Crimes conference.
Alison Jimenez, President of Dynamic Securities Analytics (“DSA”), was interviewed for an article titled “Securities Firms Offer Warm(er) Reception to Marijuana Industry, Says Former Examiner” by Larissa Bernardes of moneylaundering.com. The interview centered around securities firms’ interactions with state-legalized marijuana businesses. Below is a excerpt: Which questions should broker-dealers be asking when they’re approached […]
Once again, Dynamic Securities Analytics, Inc. partnered with PonziTracker to create interactive analytics of Ponzi schemes uncovered or sentenced in 2015. There were 61 alleged Ponzi Schemes uncovered in 2015 while sentences were handed down for 69 schemes. The total value of the uncovered schemes was over $800 million. Read the full analysis at www.ponzitracker.com. […]
Dynamic Securities Analytics, Inc. president, Alison Jimenez, will speak at the February 9th, 2016 meeting of the Tampa chapter of the Association of Certified Fraud Examiners (“ACFE”). Ms. Jimenez will discuss Securities Fraud and provide case studies. The ACFE is the world’s largest anti-fraud organization and premier provider of anti-fraud training and education. Together with more […]
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: […]
The Credit Union Journal published a slideshow version of Alison Jimenez’ Op-Ed on Marijuana Banking Myths. See the full article here. DSA’s analysis of marijuana-related Suspicious Activity Reports was also cited in “Shh! Here’s How Cannabis Companies are Banking on the Low Down” by Bruce Barnett.
American Banker published an Op-Ed by DSA president Alison Jimenez, co-authored with Steven Kemmerling of MRB Monitor. The Op-Ed titled “Banks Weighing Pot Business Find Haze of Misinformation” explains and corrects five common myths regarding marijuana businesses and financial services. Read the full article here.
A recent American Banker article titled “Don’t Bet on Pot-Banking Fix in New Year” by Chris Cumming referenced DSA’s analysis of Suspicious Activity Reports regarding the marijuana industry. See DSA’s marijuana SAR analysis here.
Alison Jimenez, president of Dynamic Securities Analytics, Inc (“DSA”), was recently appointed to the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) Education Task Force. ACAMS is the largest international organization, now at 30,000 members worldwide, dedicated to enhancing the knowledge and skills of AML and financial crime professionals from a wide range of industries with […]
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.
Dynamics Securities Analytics, Inc. was cited in a recent American Banker article titled “Legal Clash Exposes Contradictions in Fed’s Pot-Banking Rules” by Chris Cummings. Read DSA’s blog post “New Marijuana Banking SAR Data has International Implications” to learn more about how financial institutions are engaging with marijuana-related businesses.
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 […]
By Alison Jimenez, Dynamic Securities Analytics, Inc. and Steven Kemmerling, MRB Monitor Securities Brokers Engaging with Marijuana Businesses Forty-one securities brokers filed Suspicious Activity Reports (“SARs”) regarding Marijuana Related Businesses from February 2014 through July 1, 2015. The count includes securities firms that terminated marijuana accounts. Securities brokers accounted for 8% of the financial institutions […]
Dynamic Securities Analytics president, Alison Jimenez, was quoted in today’s Bloomberg article by Neil Weinberg on broker raiding cases. The article titled “Brokers’ Battle Over Memorial Day Raid Reveals Industry Strains” discusses a current Finra arbitration between Oppenheimer & Co. and Euro Pacific Capital. Ms. Jimenez commented on the number of raiding cases resolved […]
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.
The Marijuana Businesses Access to Banking Act of 2015 bill’s stated purpose is: to create protections for depository institutions that provide financial services to marijuana-related businesses, and for other purposes. A press release by one of the co-sponsors, Senator Jeff Merkley (D-OR), points out the following: “Forcing businessmen and businesswomen who are operating legally under Oregon state law […]
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 […]
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 […]
Get the latest stats on the individuals and entities under indictment or convicted in the FIFA corruption scandal. Search the roster by charge, charge status, and nationality. See the bottom table for key stats like age, title and role. FIFA Indictment & Conviction Roster
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 […]
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 […]
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 […]
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, […]
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 […]
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 […]
By Alison Jimenez, Dynamic Securities Analytics & Steven Kemmerling, Enhanced Compliance Solutions Pursuant to a Freedom of Information Act (FOIA) request, on April 6th the Financial Crimes Enforcement Network (“FinCEN”) provided Dynamic Securities Analytics (“DSA”) with new data on Suspicious Activity Report (“SAR”) activity relating to “marijuana industries.” In the disclosure to DSA, FinCEN reported […]
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 […]
Dynamic Securities Analytics, Inc. analyzed the numbers provided by FINRA Dispute Resolution covering all 2014 closed cases and found: 2,447 closed Customer cases, representing 64% of all closed cases 7% of Customer cases were closed via arbitration with damages awarded to the Customer Non-Customer Cases 1,391 Non-Customer cases (ex. Employee vs. Firm, Firm […]
Jordan Maglich of Ponzitracker.com wrote an in depth article that analyzed Ponzi schemes revealed and sentenced in 2014. See the excerpt below or read the full article here. Despite a burgeoning economy, increased regulation, and heightening scrutiny on financial crime, data compiled by Ponzitracker shows that Ponzi schemes continued to be uncovered at a steady pace […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
Learn About Tableau My goal was to create an interactive map of Suspicious Activity Reports (SARs) to determine what customer activity was reported as “suspicious” in each state. I planned to then declare that “Mississippi Tops the Ranks in ___ Fraud” and “Ohio is the Riskiest State for ____.” Instead, I was schooled […]
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, […]
FINRA arbitration isn’t just for customer disputes. As DSA found, over half of FINRA arbitrations are non-customer related. A large portion of the non-customer disputes occur when Associated Persons sue their current or former broker/dealer employer. Allegations in Associated Person vs Member Firm cases often include: defamation, reformation of U-5, wrongful termination and compensation disputes. […]
Dynamic Securities Analytics, Inc. (DSA) analyzed 1Q14 FINRA Disciplinary Actions Letters of Acceptance, Waiver & Consent (AWC) to determine legal representation trends. There were 164 AWCs during the first quarter of 2014. DSA broke down the analysis between disciplinary actions that named a firm versus those that named an individual. Broker/Dealers 67 AWCs named a Broker/Dealer […]
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. […]
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 […]
The Street published an article by Philip van Doorn titled “Ponzi Scheme Database May Shock You” in which Dynamic Securities Analytics, Inc’s interactive Ponzi scheme visualization was cited. The first decade of the 21st century goes down as the “golden age” for Ponzi schemes. In the aftermath of Bernard Madoff’s epic 20-year scheme to defraud investors — […]
A ponzi schemer would follow these rules in order to keep the scheme going for as long as possible: Encourage “reinvestment” of income. The less income the schemer pays out, the longer the scheme will last. Moderate the amount stolen each year. If he steals a smaller amount each year, the scheme will last […]
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 […]
DSA analyzed how cases were closed through the FINRA dispute resolution process in 2013. Customer Cases FINRA reported that in 2013 there were 499 Customer Complaint cases decided by Arbitration (paper & hearing) and in 212 of these cases, the customer was awarded damages. Based on the statistics provided by FINRA, DSA determined: 2,772 Customer […]
DSA’s analysis of Florida Ponzi schemes in the post-Madoff era was cited in the Sarasota Herald Tribune front page story “Florida’s Wealth a Magnet for Ponzi Schemes” by John Hielscher. Hielscher cited DSA’s ranking of Florida ponzi schemes and sentencing comparisons. DSA president, Alison Jimenez, was quoted on why Florida ranked so high in the […]
DSA prepared interactive analytics of over 500 Ponzi schemes in the post-Madoff era. The schemes can be filtered and analyzed by year, state, dollar value and months sentenced per million $. DSA partnered with Jordan Maglich of PonziTracker.com on this project. Learn About Tableau
The Tampa Bay and Jacksonville Business Journals featured DSA’s analytics of Florida Ponzi Schemes. Jane Meinhart quoted DSA president, Alison Jimenez, in the “Ponzi schemers at Home in Florida” article. DSA partnered with Jordan Maglich of Wiand Guerra King to prepare the analysis. The analysis shows Florida ranks third in the county in the total value […]
The Dodd-Frank Wall Street Reform and Consumer Protection Act mandated that advisers to venture capital funds and/or to small private fund (less than $150 million assets under management) report certain items to the SEC. Dynamic Securities Analytics, Inc. analyzed the disciplinary disclosure items reported by Exempt Reporting Advisers (“ERA”). Key Findings: 3% of ERAs report regulatory, criminal or civil disciplinary […]