Carlos M. Garza
Hebbronville, TX 78361
● Phone: 210-***-**** (cell)
● Email: *********@*****.***
Summary of Qualifications
Skillset: attention to detail; time management; analytical; communication; interpersonal; organizational; case management; research; documentation; multi-tasking; typing (65 wpm); Microsoft Office Suite including Excel and Word.
Experience: approximately twelve years in Anti-Money Laundering (AML)/Bank Secrecy Act (BSA) Compliance and Fraud which includes but is not limited to case investigations and account reviews, Suspicious Activity Report (SAR) drafting and SAR Reporting as well as case and SAR quality assurance, Currency Transaction Report (CTR) drafting and reporting, OFAC list screening, and supervisory experience. Vast experience and knowledge of the BSA and USA Patriot Act as well as experience with case management systems such as Actimize, Verafin, Abrigo, BAM+ and Bridger among others as well as national databases such as LexisNexis. I spent ten years (2008 – 2018) at JP Morgan Chase exclusively in the AML/BSA Compliance Department and have since worked a series of term contract roles which have mostly been in the AML/BSA and Fraud related fields. This is the reason for all gaps in employment after JP Morgan Chase.
Education
University of Texas at San Antonio 2001 - 2004
*Bachelor of Business Administration Degree in Finance
Professional Experience
BSA Analyst Feb 2024 to June 2024
R Bank
Responsible for conducting account reviews of customers deemed to be high risk as determined by citizenship (i.e. non-resident alien), expected account behavior and recent Suspicious Activity Report and/or recent applicable associated cases
Reviewed all associated accounts of high risk customers which included both consumer and business demand deposit accounts (i.e. checking/savings), investment accounts (i.e. certificates of deposit) and loan accounts (i.e. mortgage, personal/commercial, etc) for a minimum of twelve months of activity
Reviewed all associated documents including consumer and or commercial due diligence questionnaire(s), signature cards, secretary of state filings, beneficial ownership as well as associated identification documents (i.e. social security card(s), passport(s), driver’s license(s) and other applicable identification
Conducted on-site visits (as needed) for high risk business customers to tour the facility and observe business processes and practices and to identify any risk mitigating factors
Conducted due diligence in the form of internet research in an attempt to identify possible negative media associated with any and all authorized signer(s), beneficial owners, addresses, phone numbers, email addresses and identified and reviewed associated business websites
Documented all account activity observed during the account review(s), negative media research and overall investigation and summarized all findings in a clear, concise and to the point manner
Provided recommended risk review rating (low, medium, high) to management based on account investigation(s) and other risk factors such as volume, velocity and frequency of activity as compared to expected behavior and whether activity was business or consumer consistent
Escalated any suspicious activity identified during the account review(s) to case for possible Suspicious Activity Report filing or applicable case determination
AML/BSA Analyst Oct 2023 to Feb2024
Guidehouse
Responsible for working five to seven AML/BSA cases from start to finish generated via transaction monitoring and internal reports
Conducted thorough account investigations in an attempt to identify suspicious activity associated with possible money laundering and/or fraud
Performed SQL queries to retrieve account information and transactional activity associated with reloadable prepaid cards which act as debit/ATM cards as well as BaaS (Banking as a Service) accounts
Reviewed and analyzed transactional activity via MS Excel through pivot tables and spreadsheet manipulation and determine whether activity is legitimate or suspicious
Conducted internet research in an attempt to identify negative media and any other information associated with accountholders including Secretary of State searches for business affiliations
Identify potential suspicious activity and associate with typologies such as layering, structuring, ACH fraud and/or Identity Theft among others
Compiled Suspicious Activity Reports (SAR) by filling out all parts including drafting clear and concise narratives accordingly based on activity and typology being reported
Identified mitigating factors to reduce risk associated with transactional activity and drafted articulate No-SAR rationale which clearly stated and addressed reasons why activity does not pose a risk and is not suspicious and did not warrant SAR filing
Blocked, closed and/or notated accounts/cards included on SARs as well as accounts/cards associated with SAR subject/accountholder(s)
Uploaded reviewed and approved SARs on FinCEN’s BSA e-filing website and track accordingly
BSA Analyst II Sept 2022 to Feb 2023
American Bank
Responsible for working alerts and cases created from transaction monitoring, subpoena or internal referrals.
Conducted account reviews and analysis in an attempt to identify any potential suspicious activity and documented all alert and case findings in case management system.
Compiled SAR data and completed all sections of the SAR accurately and included composing SAR narrative to the appropriate typology which included fraud such as elder financial exploitation, check fraud, ID theft and ATO (account takeover) as applicable.
Reviewed SARs from peers and teammates and communicated any potential corrections which needed addressing prior to filing the SAR or made recommendations for a more efficient SAR.
Responsible for working the FinCEN (Financial Crimes Enforcement Network) 314(a) reports submitted to financial institutions every other week to determine and report any potential matches to FinCEN accordingly.
Responsible for sending 314(b) requests to participating institutions to inquire about mutual customer transactional data as well as worked 314(b) requests from external institutions and responded accordingly.
Conducted OFAC list screening searches for branch processes as well as for subjects on alerts/cases on a case-by-case basis as needed.
Updated missing and/or incorrect information on Currency Transaction Reports (CTRs) and submitted for approval and filing accordingly.
Fraud Analyst II March 2022 to April 2022
Union Bank (contract)
Worked several Fraud reports containing multiple alerts involving potentially fraudulent transactions and researched said transactions through multiple systems.
Identified suspicious transactions which appeared out of pattern of normal customer transactional activity.
Made contact with customer as needed to inquire whether transactions were conducted by or on behalf of the customer or are unknown to the customer and therefore potentially fraudulent.
Referred all potentially fraudulent transactions for additional review and documented the alert accordingly with findings of account research.
Compliance Officer September 2021 to December 2021
EMEX Financial Services (contract)
Responsible for running and analyzing daily reports for transactions conducted above a certain threshold, for potentially suspicious transactions and for transactions in excess of $10,000.
Conducted due diligence on customer and/or transaction(s) to identify potentially suspicious activity.
Developed and utilized KYC information on customers to identify expected transactional activity and whether it is business related or for personal reasons.
Communicated with branch personnel in attempts to contact customer or to gain additional information which may be prudent to the case.
Conducted account investigations and compiled all necessary parts of SAR(s) including drafting SAR narrative to report any suspicious activity identified during the review with all applicable customer and transaction information which were filed electronically to FinCEN.
Collected all applicable information for Currency Transaction Reports (CTR) to be filed for all transactions conducted with an aggregate amount exceeding $10,000 and uploaded CTR file electronically to FinCEN.
SAR QA/QC Specialist May 2021 to September 2021
Huntington Bank (contract)
Responsible for real-time quality assurance review of SARs being filed by Fraud Department and composed by Fraud Investigators prior to submission to FinCEN with typologies including but not limited to COVID-19 PPP (Payment Protection Program); COVID-19 EIP (Economic Impact Payment); debit/credit card fraud; check fraud; new account fraud; and account takeover among others.
Filed all applicable SARs with no errors directly through FinCEN’s network through Actimize Case Management System; SARs with potential errors were not filed until said potential errors were addressed and corrected.
Communicated with Fraud Investigators directly through email to include any potential SAR errors identified during the QA review process and advise Investigators to make appropriate corrections to be made in order to facilitate FinCEN SAR filing or by phone to provide feedback in an attempt to avoid repetition of errors in the future.
Responsible for reviewing case notes for all SAR filings; non-SAR filings as well as no-Supplemental SAR filings and determine if case notes were clearly documented accordingly with appropriate rationale and review all accounts which were in question to determine whether SAR filing was warranted (or not warranted); if no-Supplemental SAR determination was warranted (or not warranted) and if all applicable transactions were included in SAR or missed which would have substantiated a Supplemental SAR filing or Corrected SAR Filing.
Online Banking Conversion Specialist March 2020 to March 2021
Harland Clarke (contract)
Responsible for providing customer support for business banking clients whose financial institution is migrating from current online banking platform to new enhanced platform from Bottomline Technologies.
Accountable for contacting clients to explain transition from old platform to new platform and provide remote training through Go To Meeting to discuss features (including but not limited to ACH/NACHA file imports, report creation, payments and payment templates, granting user permissions, alert creations and other treasury operation services) as well as assist with navigation and other available options to help support critical business online banking services.
Provided inbound customer support to answer any questions, provide assistance and guidance as well as troubleshoot any issues which may be experienced with the online banking platform experience.
AML Analyst May 2019 to September 2019
Fidelity Information Services (contract)
Compiled procedures for Fidelity Information Services (FIS) for the upcoming transition of the USAA Mutual Fund Portfolio as acquired by Victory Capital to be serviced by FIS.
Provided AML expertise to the team not familiar with Anti-Money Laundering and OFAC List Screening.
Conducted daily and weekly OFAC (Office of Foreign Assets Control) List Screening reviews through Lexis Nexis Bridger Insight which included screening new and existing clients through several different lists including but not limited to Politically Exposed Persons (PEP), Negative News and OFAC which houses known terrorists, drug traffickers, human traffickers amongst other individuals and business entities.
Reviewed FinCEN (Financial Crimes Enforcement Network) 314(a) reports which are sent bi-monthly which list potential suspects of financial crimes which requires data mining through several systems to assure no potential suspect(s) included on the report is a customer of the financial institution.
Received and reviewed several reports of transaction monitoring and rapid movement funds activity through the mutual fund portfolio and escalated to management with any potential suspicious activity and/or fraud identified.
Compliance Officer June 2008 to October 2018
JP Morgan Chase
Responsible for the completion of alerts and cases from start to finish which generated through transaction monitoring, branch referral and subpoenas and National Security Letters (NSL) in an attempt to identify potential suspicious activity.
Reviewed and conducted account investigations in consumer and business accounts across lines of business to identify potentially suspicious transactions including but not limited to structured cash transactions, unexpected volumes of activity and wires to and/or from high risk jurisdictions.
Identified and reported patterns of suspicious account activity via Suspicious Activity Reports (SARs) which were then filed with FinCEN (Financial Crimes Enforcement) accordingly.
Completed all parts of the SAR including drafting the SAR narrative to report potentially suspicious activity which included both AML and fraud related typologies including but not limited to structuring, human trafficking, human smuggling, drug trafficking, potential terrorist financing, Ponzi schemes, elder financial exploitation, check fraud and health insurance fraud among others.
Investigated account activity associated with several high-profile individuals for negative media which were subsequently presented to the department to educate on possible trends and other pertinent case findings.
Communicated with law enforcement regarding subpoenas received from multiple law enforcement agencies including, but not limited to, FBI, DEA, ATF and ICE sent to the institution for previous or current customers which were then investigated and investigated for potential suspicious activity.
Responsible for reviewing and completing the FinCEN 314(a) report provided by FinCEN twice per month and escalated any potential matches accordingly.
Responsible for the investigation of 314(b) requests submitted by external financial institutions inquiring into account transactions from mutual customer(s) as well as submitted 314(b) requests to participating financial institutions.
Conducted extensive research through several internet sites as well as through LexisNexis and interviewed branch staff as needed for additional KYC information and thoroughly documented all case findings.
Provided quality assurance for peer case documentation as well as Suspicious Activity Reports (SAR) for any potential errors and/or recommendations.
Managed, trained and coached contract employees to conduct OFAC list screening through Lexis Nexis Bridger Insight XG and provided quality assurance.
LinkedIn: https://www.linkedin.com/in/carlos-garza-7ba626116/