Senior Investigator | ENTERPRISE AML | BMO Financial Group
Andres Betancourt is a Senior Investigator in the High risk Team at the Bank of Montreal’s Enterprise AML Global Department. As one of the initial members of the Charter Class of CFCS Certified Specialists he currently focuses on the identification and management of risk exposure in relation to major/complex investigations, sanctioned countries, law enforcement referrals and multi-jurisdictional investigations. Betancourt is a compliance professional with over 7 years of Financial Industry experience in cash management legal documentation, client on-boarding requirements, correspondent banking, AML customer due diligence remediations and adjudication of risk incidents.
1) Tell us about your trajectory in the Compliance field:
My career started in the compliance field within the Personal and Commercial Credit Card portfolio with the investigation of financial and non-financial adjustments for a Canadian financial institution. I gained knowledge of audit activities and reporting within the Corporate Payment Products (Purchasing Card and Corporate Expenses) and began to endeavor in risk and control assessments of legal and audit requirements for the onboarding of new corporations. In time, I shifted to the review and analysis of cash management legal documentation within Global Treasury Management as well as watchlist management for on-boarding of commercial clients including Correspondent Banking. In the recent years, my focus has been on risk based money laundering and terrorist assessments from all banking areas (i.e. Personal, Commercial, Private Banking) in collaboration with law enforcement and other lines of business. I find fulfillment in being part of an evolving and challenging field of work where continuing education in fraud and other financial crimes has a direct effect on the protection of wealth and assets of diverse businesses and individuals.
2) Give us a practical tip on how to mitigate AML risk:
In my personal experience and from knowledge acquired from industry leaders in my organization, the best tip is to always approach assessments in a holistic 360 risk based approach with an unbiased mindframe. Biases and buried prejudice are remarkably influential underpinnings to all risk decisions and can affect the scope, efficiency and accuracy of results. In various occasions I have witnessed people’s views hinder investigations because the subject of interest is considered guilty prior to the completions of an investigation. It is pivotal to understand the highlighted activity, understand who your client is and who they allege to be so you can effectively define scope, related clients and formulate a well-informed risk decision that takes into consideration all factors. Following the above as well as staying up to date with current trends will provide a framework to properly identify, assess and mitigate regulatory, reputational and financial risk within your organization.
3) How did you get involved with ACFCS and how has it helped you in your career?
I became involved with ACFCS to expand my knowledge and to compare and share industry best practices and trends. Obtaining my CFCS credential proved to be a key milestone in my career as I have made excellent business contacts and have amplified my “brand” in the field. Added value of the CFCS designation is that it not only focuses on fraud or money laundering but on the broader spectrum of financial crime and corruption. In retrospective, I truly believe that being part of ACFCS has aided me to become a more well-rounded financial crimes professional.