Ep. 27 (Season 2): 2021 SAR Insights into Cryptocurrency Exchange Reporting

2021 SAR Insights Into Cryptocurrency Exchanges Reporting

Welcome to the episode 27of the 2nd season of “WE WERE ON A BREAK” - Ross Voice. The series where the host, Stephen Brent Sargeant (Compliance Consultant to Bitfinex) talks to industry professionals during the CoronaVirus (COVID-19) quarantine and gains industry insights and expertise. Stephen Sargeant is joined by Expert Witness and Queen of SAR Analytics, Alison Jimenez, who digs deep into SAR stats from regulatory body FINCEN to come up with useful data points around cryptocurrency exchanges SAR filing in San Francisco.

Youtube - https://lnkd.in/dpGYWGJu

Alison describes how she approaches her analytical process in decoding the vague FINCEN SAR data to arrive at a comprehensive analysis on what Cryptocurrency Exchanges are filing on and what they might be missing in their Anti-Money Laundering Efforts. Alison’s reporting is industry leading and her yearly reports are quoted and relied upon by industry professionals.

This is one all AML, Legal and Compliance professionals in the crypto space should tune into and take notes.

**This interview was recorded on February 10, 2022

**Disclaimer**
The views and opinions expressed in this episode (and all episodes) are those of the host and the guests. They do not purport to reflect the opinions or views of their employers, contractors or any organization they may be affiliated with now or in the future.

Discussion Topics
•What is an expert witness and what does Alison do on a day to day basis in that capacity
•How does Money Laundering, Data and SAR stats from FINCEN intertwine
•Is FINCEN the only FIU that provide this data and stats regarding Suspicious reporting or do other jurisdictions also release this information
•How do you use vague data and decipher what is Crypto Exchange reporting versus other fintechs, MSB and non-crypto tech companies
•Explanation that Fintechs/non-crypto organizations location and behaviour differ from Crypto exchanges and using that insight to determine SARs specific to Crypto Exchanges
•Did 2019 guidance from FINCEN, FATF and Project Participate give the industry more knowledge to file more SARs
•Registered crypto exchanges are filing more on unregistered MSBs and cryptocurrency exchanges
•Is Layering the leading cause for Cryptocurrency Exchange SAR filing or could it be more of a defensive filing mechanism
•Cryptocurrency suspicious activity is very similar to securities and other traditional illicit activity and its important to keep up with typologies and emerging trends
•What SARs weren’t being filed and why ??? Wash trading, corruption and other reactive filing behaviours / Cybercrime events seemed low compared to other industry numbers
•Comparing industry to industry cryptocurrency exchanges should be using this information to start conversations in the industry and remind the government to provide more context to providing stats, including improving the SAR forms
•How can FINCEN align national priorities but aren’t specifically carved out on the SAR form in order to produce better data

Stephen Brent Sargeant (Host)
•LinkedIn (Best way to reach me) - linkedin.com/in/stephen-brent-sargeant-cams
•Instagram (Everyday type stuff) https://www.instagram.com/stephen_b_sargeant/
•Twitter (I communicate in GIFs) - https://twitter.com/lifesgt
•Business Related Matters (Let’s Collab): [e-mail]

Alison Jimenez (Guest)
•LinkedIn - linkedin.com/in/alisonjimenez
•Company (Dynamic Securities Analytics Inc) Website securitiesanalytics.com
•Email - [e-mail]

Resources (Alison’s Blog)
•2021 Cryptocurrency Exchange Suspicious Activity Reports: https://securitiesanalytics.com/2021-cryptocurrency-exchanges-suspicious-activity-reports/
•Cryptocurrency SARs: What do we know?: https://securitiesanalytics.com/cryptocurrency-sars-what-do-we-know/
•2020 SAR Insights: Suspicious Activity Reports and COVID-19 - https://securitiesanalytics.com/covid-19-2020-suspicious-activity-reports/
•Silicon Valley & Social Media at Center of Pyramid Scheme Surge: .css-j9qmi7{display:-webkit-box;display:-webkit-flex;display:-ms-flexbox;display:flex;-webkit-flex-direction:row;-ms-flex-direction:row;flex-direction:row;font-weight:700;margin-bottom:1rem;margin-top:2.8rem;width:100%;-webkit-box-pack:start;-ms-flex-pack:start;-webkit-justify-content:start;justify-content:start;padding-left:5rem;}@media only screen and (max-width: 599px){.css-j9qmi7{padding-left:0;-webkit-box-pack:center;-ms-flex-pack:center;-webkit-justify-content:center;justify-content:center;}}.css-j9qmi7 svg{fill:#27292D;}.css-j9qmi7 .eagfbvw0{-webkit-align-items:center;-webkit-box-align:center;-ms-flex-align:center;align-items:center;color:#27292D;}