Best practices for a BSA/AML Risk Based Approach and Model Risk Management in a Complex Regulatory Environment

Raul Garcia,
CPA, ACAMS, CISA | Senior Audit Manager
Raul Garcia is a Senior Manager at PAAST, P.L. with over 10 years of experience providing audit and consulting services specializing in the provision of attestation services for financial institutions.
Raul has extensive experience with BSA/AML and OFAC/sanction screening Model Validations and verifies that BSA and OFAC models are performing as intended to meet the Bank’s objectives and in accordance with OCC 2011-12 and FRB SR 11-7.

Raul has worked with different financial institutions including Domestic and International banks, US branches of foreign banks, community banks, credit unions, and prepaid card issuers throughout the United States, Latin America, and the Caribbean.

Raul has worked with a variety of transaction monitoring, sanctions filtering, and customer risk rating models including Ocean Systems (ECS, Prevent, OFAC Verifier), Prime Compliance Suite (BSA Reporter and EDD Reporter), Assist, Sydel (CompliXpert and SearchXpert), FCRM, Patriot Officer, Yellow Hammer, Compliance Link, Catalyst, and internally developed applications for transaction monitoring and customer risk rating models.

As an internal auditor his experience working with financial institutions also includes internal audits such as Bank Secrecy Act/Anti-Money Laundering, Sarbanes-Oxley 404, information technology audits, deposit operations, compliance audits, allowance for loan and lease losses (ALLL) reviews, and credit administration, among others. In addition, he has helped banks verify compliance with BSA related regulatory matters by providing independent Look-back reviews as ordered by regulatory agencies and BSA/AML/OFAC risk assessments.

Raul earned his Bachelor of Accounting and Bachelor of Business Administration from Florida International University. He is a Certified Public Accountant, licensed in the state of Florida, Certified Anti-Money Laundering Specialist, and Certified Information Systems Auditor. Raul is also a member of several organizations, including the Florida Institute of Certified Public Accountants (FICPA), American Institute of Certified Public Accountants (AICPA), Information Systems Audit and Control Association (ISACA), and the Association of Certified Anti-Money Laundering Specialists (ACAMS).

Naomi Cabrera | Audit Supervisor

Naomi Cabrera is an Audit Supervisor at PAAST, P.L. with over five years of experience specializing in the provision of risk advisory services for financial institutions.
Naomi has performed various BSA/AML and sanctions model validations, which include performing gap analysis of the Bank’s BSA/AML program, data integrity testing, testing the generation of alerts and profile exceptions, and performing optimization analysis. Naomi’s experience includes working with several transaction monitoring, sanction screening, and customer risk rating models. These include but are not limited to Yellow Hammer, Assist, Enhanced Compliance Solution (ECS), Prime Compliance Suite, OFAC Verifier, and Prevent. She has also assisted in completing validations for bank’s Currency Transaction Reporting (CTR) models.

As an internal auditor her experience in the banking industry includes loan reviews, Federal Deposit Insurance Corporation Improvement Act audits, compliance audits, deposit operations audits, Bank Secrecy Act/Anti-Money Laundering, and credit administration audits. She has also performed look-back projects as ordered by different regulatory bodies.

Naomi earned her Bachelor of Accounting from Florida International University and her Master of Accountancy from the University of Scranton. Naomi frequently participates in educational programs provided by the South Florida Banking Institute in an effort to expand her industry knowledge and technical skills. 

Ana Maria H. de Alba, CPAML, AMLCA
Founder & CEO 

Ana Maria de Alba is a risk management and banking consultant with over 30 years’ experience providing compliance and risk management consulting services, as well as forensic investigations and litigation support to the domestic and international financial services community. Ms. de Alba founded CSMB in 1997 and since then she has conducted and participated in numerous consulting assignments throughout the United States, Latin America, and the Caribbean. She leads all CSMB’s business practices. In 2019 she created and co-founded the first AML/CFT and Sanction Programs risk assessment software, RiskRator®, which applies a bottom-up approach methodology to define an organization’s AML/CFT and OFAC risk profile.  Also, Ms. de Alba has participated in numerous consulting engagements, worldwide, in partnership with reputable and internationally recognized business intelligence, investigative, and risk management consulting firms such as Vance International, GardaWorld, Andrews International, Pinkerton Consulting and Investigations, Kroll Associates, Bob Lindquist FCA, and the Freeh Group International.

As a former senior banking officer in both domestic and foreign banks including SunTrust (now Truist), Banco Atlántico (now Sabadel), International Finance Bank, and Banco Internacional de Costa Rica (BICSA), Ms. de Alba was engaged in private banking administration and organization, analysis and control of asset/liability mixes, analysis and management of foreign exchange, organizational definition, and strategic planning, internal investigations, investment analysis, market analysis, product and service development, and development and documentation of standard policy and procedures for the private banking function. Additionally, from 1997 through 2002 Ms. de Alba served as adjunct professor for senior level courses taught at the Management and International Business Department of Florida International University (FIU) in Miami, Florida, and is currently the lead academic advisor and instructor at Financial & International Business Association (FIBA), where she teaches the AMLCA and CPAML certification course in partnership with FIU. Certification courses are taught worldwide.

Ms. de Alba has utilized her banking and financial expertise to assist clients in conducting risk assessments, maintaining business integrity, uncovering breaches, and developing solutions to deter further criminal activity. She has supported a significant number of banks in evaluating internal controls through the process of risks assessments, as well as in developing and documenting standard operating policies and procedures and providing advice and consultation to clients regarding the prevention, detection, and deterrence of money laundering and terrorist financing.

She has been engaged by numerous financial institutions to perform mandatory and/or targeted training and development on AML/CFT subject matter, anti-money laundering and other consumer regulatory compliance evaluations, risk assessments to comply with provisions of various regulatory mandates, forensic or “look-back” reviews of high-risk account activity, forensic fraud investigations, and investigations on government corruption. As a financial investigator, her experience has been instrumental in uncovering violations to further resolution and prosecution. Ms. de Alba is also a frequent speaker at trade conferences in the United States, Latin America, and Europe.

As an investigator, her financial experience has been instrumental in uncovering violations to further resolution and prosecution. For example, she performed a forensic review of over 550 high-risk accounts for one client that uncovered over $90 million in Medicare fraud, money laundering, and an informal money transfer scheme from the U.S. to Pakistan. In an investigation of alleged over billing by a government contractor, Ms. de Alba performed exhaustive investigative work, examining contracts, invoices, and cost data as well as interviewing relevant personnel, that resulted in the discovery of over $10 million of overbilling by the contractor. Similarly, she participated in an investigation of an alleged fraud involving the issuance of worthless GDRs through the Bank of New York that resulted in the issuance of arrest warrants and extradition of the individuals involved in the scam.

Her vast business consulting experience also includes assisting a large multinational corporation in their effort to develop and establish an investment division. Her role in this engagement was comprehensive, including product development, promotions, and executive personnel recruitment. For another multinational client subject to NAFTA regulations, she supervised a large procurement effort in which she implemented a procurement/financial model for regulatory compliance and easy analysis of various procurement options, updates, and adjustments.

Ms. de Alba earned her master’s degree (MBA) in Banking and Finance from Nova Southeastern University and her Bachelors’ Degree in Business Administration with a Major in Finance from the University of Miami. She is FIBA certified in both AMLCA and CPAML and is certified by the CFATF (an FSRB for the FATF-GAFI) as an expert in Mutual Evaluations Methodology and was called by the Banking Association of the Dominican Republic to perform a nationwide assessment in preparation of the country’s 2017 mutual evaluation, allowing the country to identify their weaker areas and adopt new laws and regulations that ultimately resulted in forming an appropriately funded financial intelligence unit (FIU) and receiving a designation of mostly compliant.

Ana Maria de Alba is fully bilingual in English and Spanish.