Rafael joined Integro Advisers in October 2022 as a senior member of the firm’s AML Compliance Advisory team. He brings more than 20 years of specialized experience in BSA/AML/OFAC compliance and bank operations. He has designed and updated risk management programs for various financial institutions, in accordance with changes in customer profiles, existing products, geographies and regulatory changes. He has also performed training for executives and board members on BSA/AML/OFAC policies, regulatory requirements and expectations.
Rafael began his career in New York at Republic National Bank of New York where he learned banking Operations in his capacity as Officer and Assistant Vice President. He was subsequently promoted and transferred to an affiliate of RNBNY in Panama City, Republic of Panama, as Manager of Operations and Administration, where he had direct oversight of numerous departments with over 45 staff members.
From 1989 – 1997, Rafael worked in operations at Barclays Bank PLC in Miami, managing Loans and Time Deposits processing, Wire Transfers, Telecommunications, Tellers, and Check Processing.
Later he moved to lead BSA compliance programs at Hemisphere National Bank and the International Bank of Miami, both in Miami, Florida. At these institutions he oversaw training, organized and reported updates to the Bank’s board committee, updated each bank’s risk matrix and customer documentation, visited high risk foreign correspondent banking customers, and managed staff through restructurings and projects requested by regulatory examiners. He also acted as liaison between the bank and regulators, internal and external auditors.
Subsequently, between 2009 and 2022, he served two separate stints as the Compliance Manager and BSA Officer for Banco Internacional de Costa Rica (BICSA), Miami, Florida, during which time he was responsible for day to day BSA/AML/OFAC compliance activities, audits and assessments of the compliance program, updating of policies and procedures, ongoing reviews of controls to align them with best practices and regulatory requirements, and supervised annual account reviews, monitoring of customer activities and exceptions, and reporting to the Bank’s Compliance Committee and Board of Directors. He also acted as liaison between the bank and regulators, internal and external auditors.
From 1990 to 2005, he was President and Director of the International Operations Banking Association (IBOA) and the Financial Institution Risk Management Association (FIRMA), both in Miami, Florida. These associations organized monthly meetings and quarterly seminars addressing all relevant banking operations, compliance and risk management matters.
Rafael is a Certified Anti-Money Laundering Specialist (CAMS) and has also served as an expert witness on several legal matters related to AML and financial fraud.