Kenneth Rijock in his blog reported on 18th December that the problems involved the UBS brokerage office in San Diego, where many non-resident aliens from Panama, Mexico and Venezuela had accounts. The $15 million was split between the SEC and FinCEN. The FinCEN Director is quoted as saying that broker-dealers providing banking-like services must properly mitigate the AML risks associated with this kind of service. These services enable the flow of funds through mechanisms such as wire transfers, check writing, and ATM withdrawals, creating AML risks that need to be properly addressed. It is said that the company failed to provide sufficient resources to ensure day-to-day AML compliance, and inadequate staffing led to a significant backlog of alerts and decreased its ability to timely file suspicious activity reports.