ACAMS Today caught up with our first member Francisco Monteagudo for a quick trip down memory lane and an update on how the compliance field has changed in the past 10 years.
Monteagudo is the senior audit manager at Jon Campbell and Associates Inc. in Brandon, Florida. His duties include conducting regulatory compliance audits of small to medium banks. He also is involved with special projects such as reviewing customer historical account activity for suspicious activity and client compliance training sessions.
Prior to joining Campbell and Associates, Monteagudo served as the senior vice president in compliance for Pinebank, N.A., as director of internal control and compliance for American Express Bank International, vice president/compliance and CRA officer for Home Savings Bank FSB.
Monteagudo is also a Certified Fraud Examiner, Certified Regulatory Compliance Manager, Certified Financial Services Auditor and Certified Bank Auditor.
ACAMS Today: How did you first hear about ACAMS and what prompted you to join the new association?
Francisco Monteagudo: I first learned about ACAMS when I received the initial package in the mail announcing the formation of the organization. I thought that the time had come for BSA/AML officers to have their own organization that was specifically geared for BSA and AML matters. I sent in my membership request within minutes of having received the package.
AT: Did you know that you were the first person to join ACAMS?
FM: My membership certificate does not have a number on it, so I didn't know I was the first member until 2004. Tim Heine, general counsel for American Express (who I was working for at the time) announced it at an AML conference.
AT: When did you first become involved in the compliance field?
FM: I first became involved in the compliance field when I was an auditor at American Savings in Miami in the mid to late 80's. The Audit Department would perform BSA audits and loan compliance audits. The BSA audit consisted at that time of reviewing CTRs only as there were no other requirements at that time. Loan compliance audits consisted of reviewing Truth in Lending (Reg. Z) and RESPA requirements. There were virtually no deposit compliance regulations at that time as Truth in Savings (Reg. DD) and check holds (Reg. CC) did not come into effect until later.
AT: How has the compliance field changed in the past 10 years?
FM: We have seen the advent of the true compliance professional. Due to the numerous and complex compliance requirements, compliance professionals must now be highly trained, experienced, and key members of senior management. The days of assigning an employee compliance responsibilities because there was no other place for them in the organization are over.
AT: How has ACAMS helped you in your career?
FM: ACAMS has helped me by keeping up with current trends in the BSA/AML world. No matter how experienced you are, it's difficult to keep up with everything on a global basis, and ACAMS definitely helps to keep me informed and up-to-date.
AT: As a compliance auditor what is the main weakness you consistently see in compliance programs?
FM: Working for Campbell and Associates for the last five years, I get to see the inner workings of many banks all over the state. There is one common denominator for banks having successful compliance programs and that is engagement. Compliance officers have to be engaged with their local compliance associations (like ACAMS and other compliance associations), with their regulators, senior management, and with every aspect of their organization. That is a big factor in keeping up with all of the regulatory changes and expectations. It ensures that everyone is on the same page. Also, the BSA officer must be a member of senior management. They must be capable of making top-level decisions and even overriding management decisions when they see fit to do so.
AT: ACAMS is actively considering adding an advanced certification for AML Auditors. How would that improve the expertise of the AML community?
FM: As time has gone by, AML matters, issues, and programs have become more complex. BSA officers must continue to stay ahead of the game by being aware of trends and practices that may not impact their organization at the present time but could do so in the future. An advanced AML certification would definitely help in that regard.
AT: What is the best advice you have received during your compliance career?
FM: Be proactive, not reactive. Stay ahead of the game by being aware of regulatory changes coming down the pike today and not when the implementation date approaches. You'll sleep better.