About This Course
Correspondent Banking Relations (CBRs) facilitate access to financial services across jurisdictions, including cross border payments connected to remittances, trade financing and other economic activities. Well-functioning CBRs also promote financial inclusion. In recent years, there has been a growing trend to cut off the access to the financial system, including CBRs in many countries; thus, creating a problem known as “de-risking.” This practice has been particularly acute in the Caribbean.
In view of the above, the Association of Supervisors of Banks of the Americas (ASBA) and the Inter-American Development Bank (IDB) developed the project “Strengthening Financial Transparency: Rebuilding Trust in Correspondent Banking in the Caribbean.”
The project contemplates targeted training activities for compliance officers and other relevant staff at banks and regulation authorities in the beneficiary countries. With this in mind, the course “Efforts in Reducing the Negative Impact of Loss of Correspondent Banking Relationships in The Caribbean: The role of Supervisors and Financial Institutions” was developed. The objective is to ensure that financial institutions adopt the highest standards related to CDD, KYC and Beneficial Ownership information relative to the risks they face.
This course is available by invitation only. If you are interested in enrolling, please
send a request to elearning@asbasupervision.com.
Objective
The objective of the training is to address, from a practical standpoint, the risk of losing correspondent banking relationships (the de-risking phenomenon) in the Caribbean region, from the perspective of the Bank Supervisors and the Correspondent Banks. In addition, answer questions such as:
1) What do supervisors look for at the time of analyzing geographic and services risks in Caribbean countries?
2) What are the financial or compliance risks in the region?
3) Of the risks identified, which are those that play a significant role in triggering de-risking actions?
4) What are the elements that correspondent banks look for to establish a sustainable correspondent banking relationship?
5) Why should Correspondent Banks assess the AML/CFT risks of its correspondent institutions and the region’s clients?
The course also seeks to generate awareness about the current challenges in the Caribbean, in both Regulatory and Supervisory Authorities and Financial Institutions, and the identified weaknesses related to the de-risking phenomenon.
Course Staff
Leonardo Costa
Attorney. Founding partner of Brum Costa Abogados (Uruguay). Postgraduate Master’s Degree in Taxation - International Tax Program of Harvard University (1998). He has more than 15 years of experience in advising on matters of taxation, AML/CFT and central bank regulations, including the public and private sectors. He was the founder for Uruguay of GAFISUD, President of GAFISUD in 2003. Head of the National Drug Board (2000-2005), the body responsible for ML/FT prevention and control policies. Author of various draft bills and regulations in the above-mentioned areas, approved by the National Parliament and the Executive Power. He has been an evaluator and adviser to countries and financial institutions in Uruguay and the region, including the IDB, ASBA, FONPLATA, CIAT and other international organizations. Professor at the Universidad de la República (University of the Republic), Universidad de Montevideo (University of Montevideo) and Universidad Católica del Uruguay (Catholic University of Uruguay).
Juan Diana
Attorney Member of the staff of Brum Costa Abogados (Uruguay). He has extensive experience in the financial system regulation, mainly in the prevention of ML/FT. He provides legal advice and training in this area to local financial and stock market institutions (banks, stock brokers, investment advisors, among others). He has participated in various international consultancies for regulators and financial entities in the region, such as the Financial Intelligence Unit of the Republic of Peru (UIF Peru), the Financial Fund for the Development of the Rio de la Plata Basin (FONPLATA), the Inter-American Development Bank (IDB) and the Association of Banking Supervisors of the Americas (ASBA). He gives talks and presentations both locally and regionally on topics such as financial regulation and prevention of ML/FT. He has taken several postgraduate courses in this field at different local universities.
Oscar Herasme
Attorneys & Counsellors at Law
Herbert Law Group, LLC
Oscar A. Herasme counsels companies in the financial services industry on state and federal legal
compliance and enforcement matters, including anti-money laundering, risk control, permissible
investments, licensing and other regulatory issues. Mr. Herasme also counsels clients on a variety
of corporate matters, such as the development of Sarbanes-Oxley policies and procedures,
consumerprivacy, correspondent agreements and transactional due diligence. He is admitted to
practice in the state and federal courts of New York and the U.S. District Court for the Western
District of Wisconsin.
Mr. Herasme presided as president and general counsel of a leading anti-money laundering
compliance and transaction-monitoring firm based in New Jersey, served as an Assistant District
Attorney in the Trial Division at the New York County District Attorney’s Office in Manhattan, and
as legal counsel to the New York State Assembly Sub-Committee on Banking for Immigrants.
Alejandro Montesdeoca-Broquetas
AML/CFT Consultant. Mr. Montesdeoca-Broguetas, is and advisor for the Argentine Financial Intelligence Unit on
international matters and the Government of Paraguay for the development and implementation
of the National AML/CFT Strategic Plan and preparation for the Financial Action Task Force of
Latin America’s (GAFILAT) fourth round of mutual evaluations.
He is conducting Regional Analysis of the Technical Compliance of the Money Laundering and
Terrorist Financing Regulatory Framework’ for the Americas, and Honduran AML/CFT National
Strategy (IDB). At the Governance & Risk Institute (GovRisk) he is a lead expert is developing and
implementing technical assistance programs for Argentina, China, Cuba, Guatemala, Mexico,
Myanmar, Paraguay and Uruguay.
In the past, he has held relevant positions as: Executive Secretary of the Financial Action Task
Force of South America and Legal Advisor and President of the Governing Council of the Money
Laundering Prevention Training Centre, under the authority of the National Drugs Committee of
the Presidency of the Oriental Republic of Uruguay.
Farida Paredes Falconi
Chief of the ML/FT Risk
Superintendence of Banking, Insurance and Private Pension Funds of Peru (SBS).Farida Paredes works as Chief of the ML/FT Risk Department of the Deputy Superintendence of
Risks of the Superintendence of Banking, Insurance and Private Pension Funds of Peru (SBS). She
has over 11 years of experience assessing ML/FT risks management and also proposing sectorial
regulations regarding these risks. Ms. Paredes has a degree in Accounting and Law; with an MBA
from Mondragon University (Spain) and is Master in Culture and Governance of Organizations from
the University of Navarra (Spain).
She has been evaluator in the GAFILAT Mutual Evaluation of Honduras in 2015, and since then has
worked with the Peruvian task force for the Peruvian Mutual Evaluation that was conducted in
2018. She also has worked as a private consultant for the Paraguayan Government and some
private banks.