Technology Driven Compliance Solutions
CSMB has partnered with a leading financial services technology firm to bring our customers cutting edge Compliance solutions utilizing technologies such as artificial intelligence, BigData, machine learning, and robotic process automation. The first of our products is RiskRator™, a dynamic, highly rigorous and efficient technology solution for performing single entity and enterprise wide risk assessments. The program utilizes an entities’ transactional data as its foundation and can be run on an annual, quarterly or custom date range. As in our traditional risk assessment process, the RiskRator™ program follows FFIEC and BSA/AML Examination Manual guidance and procedures, as well as FATF guidance, and includes the following activities:
The application also provides a series of interactive dash boards to present the Risk Assessment results in both high level “Board ready” images and detailed drill down data queries to provide in-depth insights of the factors driving the Risk Profile. Additionally, the tool provides the ability to explore “what if” scenarios to assist management decision making related to the risk impact of new products and services, acquisitions, divestitures, among others.
CSMB provides the complete array of AML/CFT Compliance Services to the financial services industry, including banks, credit unions, broker-dealers, insurance companies, money services businesses and credit card companies.
Our Compliance services include:
CSMB has extensive experience in Risk Assessments and developing Institutional Risk Profiles at the entity or group level. Our methodology follows FFIEC and BSA/AML Examination Manual guidance and procedures which are complemented by CSMB’s proprietary data driven analysis.
The Risk Assessment performed by CSMB combines quantitative analytics with thorough on-site reviews and qualitative assessments. The process evaluates a bank’s compliance systems and personnel, its transactions history and profile, its customers, products, channels and jurisdictions among other areas.
The CSMB Risk Assessment Methodology includes:
CSMB provides high caliber, industry certified, contract support staff for all areas of a financial institution’s Compliance Department. Whether to address an enforcement action, handle rapid growth, an acquisition or other department challenge, CSMB’s exceptional compliance personnel will deliver the results your organization needs in a cost effective, timely manner with vetted, proven professionals.
Our financial professionals are AMCLA, and / or CPMAL certified by the FIBA and FIU’s School of Business Executive and Professional Education. These certifications ensure our clients that the professionals from CSMB will provide exceptional services in the areas of financial crimes prevention, AML/CFT independent evaluations and risk assessments, and training, among others.
Our services range from placement of individuals to entire teams on-site or remotely. Our performance-based approach incorporates robust Quality Control processes, performance and budget tracking and frequent feedback to ensure our services always meet our client’s expectations and needs.
CSMB’s Compliance Support services feature:
CSMB provides specialized services intended to assist banks in reducing the risk and cost of their Correspondent Banking relationships. CSMB can provide an in-depth evaluation or review of a Respondent’s compliance program to evaluate the effectiveness of the Bank’s internal controls to prevent and detect AML/CFT risks and determine if those controls are adequate to comply with regulatory requirements of local laws and with internationally accepted standards.
CSMB also provides on-going support to respondent institutions to ensure compliance programs and personnel perform at internationally accepted competency levels.
CSMB Correspondent Banking Services for Respondent Institutions:
CSMB understands that borrowers, investors, vendors, customers and employees all bring a degree of risk to your organization and to the clients you represent. Counting with sound background knowledge of those whom you do business with will put your organization and the clients you represent at a competitive advantage and will help you formulate the most accurate investment proposal for the risks you are willing to take. The potential risk of doing business with someone who you do not know exceeds basic economic loss; it may increase your legal liability, including civil law suits and regulatory action, having a direct impact on an organization’s reputation and ultimately in shareholder value.
CSMB’s Due Diligence services range from basic background investigations to comprehensive evaluations of the internal controls established by financial services entities to comply with regulatory requirements. These services are offered in support of, among others, enhanced due diligence procedures for foreign and domestic financial institutions and multinational corporations, complex sales and transactions, and mergers and acquisitions.
Our On-Site Due Diligence process includes performing on-site inspections to validate location, stated business purpose, presence of employees, inventory, equipment and other factors that support your KYC and Vendor Due Diligence process as well as background investigations on an entity’s key personnel.
Our Investigative Due Diligence services relay on techniques developed by law enforcement agencies thereby providing our clients with solid information about key personnel’s character, integrity and/or past conduct and their level of competence to perform assigned duties among other areas.
CSMB Due Diligence Services:
CSMB works directly with clients in formulating and designing tailored training programs to ensure that regulatory requirements are met and that learning objectives are achieved. We train the Board of Directors, all levels of management and staff members. Our training team consists of highly seasoned, industry certified professionals with deep compliance expertise. Programs are tailored to specific job-related functions and can be provided on-site or on-line via pre-recorded sessions.
CSMB’s training services include:
CSMB has deep expertise in all areas related to Ethics and FCPA. The firm conducts investigations into alleged violations of laws, allegations of bribery and financial mismanagement including kickbacks, money laundering, internal control lapses and other financial improprieties. Our professionals bring diverse and relevant experience to conduct assessments, train personnel, and where necessary find and interpret the evidence required to investigate harassment, ethical violations, FCPA violations, and fraud.
If your organization is a victim of fraud, corruption, or other misconduct, CSMB can assist by performing an investigation to assess the magnitude of the malfeasance, to quantify and qualify the impropriety, and to help identify the responsible party(ies). Furthermore, CSMB’s professionals are well versed in conducting such investigations while preserving valuable documentary and digital evidence, implementing internal controls and remediation, and preparing reports of findings for internal use or to support civil or criminal proceedings. Our combined experience in investigative and financial issues allows us to separate deceptions from facts and find the underlying cause of fraud schemes. Our team provides assessments of implemented programs and systems of internal control, identifying potential vulnerabilities and recommending modifications to reduce risks.
Our general methodology for assisting organizations with expert advice on Ethics and Compliance matters consists of multiple stages including:
CSMB facilitates coordinated efforts to identify, collect, analyze and interpret financial data, applying the relevant information to a legal dispute or issue, and rendering an opinion. CSMB understands that every organization is unique, yet our field experience enables us to rapidly discover and explore behavior patterns that may resemble others we have addressed in prior case assignments. Our insight, investigative skills, document and database control, analytical abilities, forensic accounting expertise, and report-writing capabilities have been brought to bear on high-profile cases, including foreign government corruption and financial fraud investigations.
Upon completion of a forensic investigation, CSMB will support your organization with risk management guidance and will assist in measuring your ability to detect and prevent future incidents. All clients’ affairs are handled by our senior level consultants in a highly professional manner with assured confidentiality.
CSMB Forensic Investigation Services:
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 of CSMB’s business practices.
As a former senior banking officer in both domestic and foreign banks including SunTrust, Banco Atlántico, International Finance Bank, and 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. 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 Florida International Bankers Association (FIBA), teaching the AMLCA and CPAML certification course in partnership with FIU.
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.
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.
Ana Maria de Alba is fully bilingual in English and Spanish.
Celeste De Armas is Principal and Chief Operating Officer of CSMB International. Ms. De Armas has over 30 years’ experience in executive management and consulting for corporate entities and financial institutions. Ms. De Armas leads the Firm’s Enhanced Due Diligence Practice focusing on site visitations and independent evaluations of high-risk customers particularly correspondent banking, wealth management and NRAs. Ms. De Armas also directs the firm’s technology services group developing cutting edge software for compliance automation. Beyond these areas Ms. De Armas guides the overall growth and operational strategy for CSMB.
Ms. De Armas has led staff assessment and operations improvement projects for financial institutions and corporations. Ms. De Armas joined CSMB in early 2013. Prior to joining CSMB, Ms. De Armas spent 5 years doing strategic consulting for early stage companies and founded and later sold Nueva Cocina Foods. Prior to Nueva Cocina, Ms. De Armas spent 15 years in senior positions with Nestle USA culminating in her role as SVP and General Manager of the Chilled Foods Division of Nestle USA and VP Corporate Strategy and Planning for Nestle USA.
Ms. De Armas has a Masters’ Degree in Business from the Kelley School of Management at Indiana University, and a bachelor’s degree in Business from California State University, Long Beach. She holds the prestigious Anti-Money Laundering Certified Associate (AMLCA) designation from FIU/FIBA, which she maintains in good standing through continuing education in AML/CFT compliance matters.
Celeste de Armas is fully bilingual in English and Spanish.
Jairo Namur is a senior business executive with over 30 years of banking experience. Mr. Namur’s industry related expertise includes domestic and international cash management, correspondent banking, trade finance, corporate trust, Global Custody, Asset Management, and Payment/Securities systems development. As an expert in payment and securities market infrastructures Mr. Namur has worked with many private and government run entities throughout Latin America and the Caribbean in establishing or modernizing their operating systems.
Prior to joining CSMB, Mr. Namur spent 9 years at SWIFT in various Senior roles including Manager for Strategic Markets and Relationships LATAM, Regional Head of Sales and Business Development for Latin America and the Caribbean, and Head of Market Infrastructures LATAM and the Caribbean. In these roles Mr. Namur was responsible for leading the company’s strategy and sales efforts in the region across all products and services including the messaging platform, business consulting services, regulatory compliance services such as Sanctions Screening and the KYC Registry, and IT advisory services. His team’s responsibilities reached across all markets including Financial and non-bank financial institutions, central banks, broker dealers, trust companies, payment and securities market infrastructures, and government related regulatory entities.
Throughout his career, Mr. Namur has held a variety of senior level positions at some of the world’s largest global transaction banks. His prior roles include 5 years as Vice President Global Transaction Banking for HSBC Bank USA based in NY and Mexico City and 8 years at The Bank of New York. During His time at BNY he held various positions including Regional Head for the Andean and Central American regions, VP and Head of Cash Management for Latin America and the Caribbean, and General Manager of the Venezuelan Regional Representative office. Prior experience also includes Regional Head of Central America, and Head of Cash Management LATAM, at the Philadelphia International Bank, Philadelphia and Manager of the third-party payments clearing operation at the Philadelphia International Bank NY. Mr. Namur has also held key positions in the operations areas at Bankers Trust Company NY and Bank of America International NY.
Mr. Namur attended Pace University in NY, and Universidad de los Andes, in Bogotá, Colombia. Also, Mr. Namur holds various certifications including the Association for Financial Professionals, Certified Treasury Professional (CTP) as well as the prestigious FIBA/FIU’s Anti Money-Laundering Certified Analyst (AMLCA) designation, which he maintains in good standing through continuing education on AML/CFT compliance matters.
Jairo Namur is fully bilingual in English and Spanish.
Julio Aguirre brings to CSMB over 28 years of banking experience dealing with Compliance, Trade Finance and Bank Operations. Prior to joining CSMB, Mr. Aguirre served for over 11 years as Senior Vice President and Head of Compliance for Banco Latinoamericano de Comercio Exterior (Bladex), and for over 16 years as Senior Vice President and Finance Manager, at Banco Internacional de Panama (Bipan), where he was responsible for all matters ranging from Operations to Compliance for the bank and its subsidiaries.
Mr. Aguirre is a member and First Vice-President of the Money Laundering Prevention Committee of FELABAN (the Federation of Latin-American Banks). He held the chairmanship of the Compliance Officers’ Committee of the Panama Banking Association for more than 15 years, he is the President of the Organizing Committee of the Hemispheric Congress for the Money Laundering Prevention of the Panama Banking Association, and he is member of the Special AML and Crime Finance Committee of ACAMS Group for Latin America.
Mr. Aguirre has participated as member of the “US-LA PSD Steering Group meeting”, and he has participated and continues to be a frequent speaker at international Money Laundering Prevention and Terrorist Financing Congresses in LATAM, US and the Caribbean.
Mr. Aguirre is also a founder and director of A&S Advisors in Panama a firm dedicated to anti-money laundering and financial crimes consulting services and a member of the CSMB Network Alliance.
Mr. Aguirre holds an MBA in Business Administration from Latina University in Panama, a bachelor’s degree in accounting from Panama University, and holds both the ACAMS designation as well as the prestigious Certified Professional in AML designation (CPAML) from Florida International University (FIU) and the Florida International Bankers Association (FIBA), which he maintains in good standing through continuing education in AML/CFT compliance matters.
Julio Aguirre is fully bilingual in English and Spanish.
Roderick Schwarz is an attorney with over 16 years’ experience in the prevention of money laundering and financial crimes, corporate security, and investigations for banking, securities, insurance, MSBs and other related industries. Prior to joining CSMB, Mr. Schwarz served as Compliance Officer and as a Vice President of Corporate Security and Research Services in global banking institutions such as Citibank (Venezuela and Aruba) and other financial institutions operating in Venezuela and within the LATAM and Caribbean markets.
Mr. Schwarz has been responsible for leading and executing risk management projects to identify and measure the inherent risk level and define residual risk for large multinational institutions. He has implemented and developed processes, policies, regulations and internal compliance procedures, evaluated internal control systems, served as special guest auditor in inspection and corporate auditing procedures for correspondent banking clients and conducted specialized transactional audits (look-back's).
Mr. Schwarz has held executive positions in various compliance committees of the Asociación Bancaria de Venezuela. As an attorney, he has conducted comparative law examinations for multinational institutions with the purpose of aligning processes to local and international law and guiding corporate governance structures. In addition, Mr. Schwarz has served as a technical consultant in criminal procedures and he has served as a Professor at the Instituto de Altos Estudios de Derecho and the Instituto de Desarrollo Profesional de los Colegios de Contadores Públicos.
Mr. Schwarz received his legal degree from Santa María University in Venezuela and his advanced studies degree in banking from the Universidad Simón Bolívar. He maintains two leading AML/compliance certifications, namely, CAMS and the CPAML which is the prestigious Certified Professional in AML designation from Florida International University (FIU) and the Florida International Bankers Association (FIBA). Mr. Schwarz maintains all designations in good standing through continuing education in AML/CFT compliance matters.
Mr. Schwarz is also a co-founder and director of A&S Advisors in Panama, a firm dedicated to anti-money laundering and financial crimes consulting services and a member of the CSMB Network Alliance.
Roderick is bilingual in English and Spanish.
Cody Smith brings over 18 years of banking experience, specializing in Anti Money Laundering Compliance and Business Risk to CSMB where he leads projects for foreign and domestic financial institutions which include program development, independent evaluation and testing, risk assessment, examination remediation, advisory and training.
Prior to joining CSMB, Mr. Smith worked for Wells Fargo Bank where he traveled throughout Latin America evaluating the AML Compliance structure and programs of foreign financial institutions to identify the business risk posed by correspondent relationships. Prior to that he was Vice President of Compliance for the Americas region of a Spanish Caja de Ahorros where he developed and implemented the compliance program for this de novo International Agency.
Mr. Smith has also worked as the Compliance Officer of the International Wealth Management line of business at SunTrust Bank. In these roles he has been responsible for the on-going development, implementation and risk assessment of effective BSA/AML/OFAC, fraud prevention and consumer compliance programs and has trained teams to identify and mitigate associated risks.
Cody studied Political Science at Florida International University, and he is CPAML certified, the prestigious Certified Professional in AML, which is the highest level designation from Florida International University (FIU) and the Florida International Bankers Association (FIBA). Mr. Smith maintains all designations in good standing through continuing education in AML/CFT compliance matters.
Cody is bilingual in English and Spanish.
Pamela Wilkerson is an international banking and compliance professional with over 30 years’ field experience in international financial matters for private and public financial institutions, in both the Latin American and Caribbean markets. Ms. Wilkerson specializes in matters relating to anti-money laundering, know your customer, correspondent banking, customer due diligence and enhanced due diligence per USA Patriot Act requirements, offshore banking, Foreign Corrupt Practices Act, and EU Directives.
Ms. Wilkerson joined CSMB in early 2016; since then, she has been involved in multiple large scale assignments with foreign financial institutions, assisting in the implementation of AML/CFT compliance programs; developing and documenting policies and procedures, providing AML/CFT training to both operations and commercial teams; performing gap analysis of internal controls; performing risk assessments; and conducting in high risk account reviews and investigations.
Prior to joining CSMB, Ms. Wilkerson was Vice President & Regional Risk Officer for Global Financial Institutions at Wells Fargo Bank. Her primary function was to provide client underwriting for international financial institutions, and relationship monitoring. Also, with Wells Fargo, she held a position with the Internal Audit Department with duties covering planning, execution, validation and reporting on the organization’s international compliance program.
Prior to Wells Fargo, Mrs. Wilkerson held several senior roles with JP Morgan Chase Bank in Dallas and Chicago. She was Relationship Manager focused on trade finance in emerging markets. As Vice President, International Compliance Manager in the Global Financial Institutions unit she coordinated the Anti-Money Laundering/Know Your Customer process and for correspondent banks and other financial entities in the Middle East, Latin America, Caribbean and Europe. She also worked on policy and procedure development and implementation, project management, regulatory examination, internal audit coordination, and training.
Prior to her involvement at JP Morgan Chase Bank, Ms. Wilkerson served at the World Bank Group (IBRD) in Washington D.C. as an International Investments Trader and Analyst.
Ms. Wilkerson has a Masters’ Degree of Science in Economics/Finance from Texas A & M University. She is certified as an Anti-Money Laundering Specialist by ACAMS.
Corina Mascaro is a banking executive with over 20 years’ experience in the domestic financial services industry, both in the banking and securities sectors. Ms. Mascaro's professional background expands over various fields such as Lending and Private Banking as well as Regulatory Compliance, where over the past 5 years she has developed extensive experience with particular emphasis on BSA, USA Patriot Act, Anti-Money Laundering, and Sanctions/OFAC related compliance matters.
Prior to joining CSMB, Ms. Mascaro was an international commercial lender at Northwest Bank Corp, in Minneapolis Minnesota, where she was responsible for origination, management and supervision of a portfolio of commercial loans with the objective of maintaining and increasing its asset quality and scope. She maintained up-to-date customer’s files including current balance sheets, profit and loss statements, cash flow projections and loan documentation, all in compliance with BSA/AML/OFAC regulatory requirements. In this position, she was also responsible for negotiating terms and loan structure based on risk considerations and presented new credits and renewals for approval to the Bank’s senior loan committee. From lending she transferred to Los Angeles, California and accepted a position at Shearson-Lehman Brothers as a securities broker dealer, where she built and managed an equity and fixed income portfolio for both international and domestic clients in the exchange market. Ms. Mascaro then joined Wells Fargo Bank in Los Angeles, California as a senior Private Banking executive where she managed a large portfolio of international clients.
Ms. Mascaro began consulting in 2012, where she began strengthening her knowledge around AML compliance matters. With CSMB, she has specialized in all matters regarding OFAC sanctions programs and assists both domestic and international clients in compliance related investigations, KYC remediation projects, and quality control assurance.
Corina Mascaro holds both a bachelor of arts degree and a master’s degree from the University of Missouri in Romance Languages, and a master degree in business administration from the University of Southern Illinois. Furthermore, she earned the prestigious FIBA AMLCA certification, which she maintains in good standing through continuing education in BSA/AML/OFAC compliance matters.
Corina Mascaro is fluent in English, Spanish and French.
Markela Martinez brings over 20 years of experience in domestic and international banking, specializing in Operational Risk Management, Internal Controls and Compliance. She has developed solid expertise of the banking industry’s laws, regulations, risk management standards and international best practices. At CSMB Ms. Martinez consults across a variety of projects with a special focus on risk assessments, staff evaluations and technical compliance projects.
Prior to joining CSMB, Ms. Martínez was Operational Risk Officer at Banco LAFISE Panama, where she was responsible for assisting the Bank's Risk Manager in the implementation and compliance of the bank’s operational risk management framework.
Ms. Martinez attended the University of Santa Maria de la Antigua, where she earned a degree in Finance. She also holds the risk management certification AIRM (ALARYS).
Markela is bilingual in English and Spanish.
Yamishel Rodríguez is an attorney with more than 16 years of professional experience in AML/CFT Compliance related matters in the Banking, Insurance and Securities industries.
Prior to joining CSMB, Ms. Rodriguez held the position of Compliance Officer at Banesco Banco Universal as well as Prevention Manager at Inverunión Banco Comercial, SA. Ms. Rodriguez has also served as Chair of the Compliance Officers Committee of ASOCOVAL - the Association representing the Brokerage industry in Venezuela. In this role, she led the planning and training activities for the Directors and members of the Association. In addition, Ms. Rodriguez also worked at CONACUID, the National Anti-Drug Office of Venezuela (ONA), in the area of asset recovery from drug-related crimes.
Ms. Rodriguez manages a broad range of projects spanning from the development of AML policies and procedures, independent evaluations, transaction system validations, staff assessments, and Enhanced Due Diligence (EDD) validations among others.
Yamishel graduated from the school of law at the Universidad Santa María of Caracas-Venezuela. She is Certified as Anti-Money Laundering Specialist by ACAMS and as Risk Manager by ALARYS, the Latin American Risk Association.
Miguel Yépez brings over 30 years of banking and public sector experience to CSMB, and is responsible for representing CSMB in Ecuador. Mr. Yépez has been employed by the Government of Ecuador as a Consultant with the Secretaría de Inteligencia (the country’s Intelligence Agency) as well as a Consultant in the Financial ad Economics Analysis Unit of the Unidad De Análisis Financiero Económico (UAFE), Ecuador’s financial intelligence unit.
Mr. Yépez started his professional career in the operations area of Bank of America. In the banking sector Mr. Yépez served as President of Banco De Préstamos in Panama where he was responsible for opening the branch, hiring the staff, building the client base, and negotiate lines of credit among other duties. Prior to moving to Panama, Mr. Yépez spent 7 years with Banco De Préstamos in Guayaquil in various roles including head of Operations, Head of Accounts, Manager of the bank’s Branches and Head of the Credit Department.
Mr. Yépez also brings extensive experience in the insurance sector having spent over five years working for OMG Seguros and ATESEGU in Guayaquil.
Miguel has a finance degree from Universidad LAICA “Vicente Rocafuerte” de Guayaquil, and he also holds the prestigious AMLCA certification as certified specialist in Anti-Money Laundering, a designation from Florida International University (FIU) and the Florida International Bankers Association (FIBA). Miguel maintains all designations in good standing through continuing education in AML/CFT compliance matters.
CSMB is headquartered in Miami Beach, Florida with a network of CSMB alliances in Panama, Ecuador, Venezuela and Mexico.
CSMB International Inc.
300 71st Street, Suite 450
Miami Beach, FL 33140
Edificio World Trade Center
Avenida Francisco de Orellana
Torre B, Oficina 526
Aguirre & Schwarz, S.A.
Avenida Ricardo J. Alfaro
Piso 4, Oficina 401
Panama, Republic of Panama