Clemente L. Vázquez-Bello

Clemente L. Vázquez-Bello is a shareholder in the firm's Corporate Department and Financial Institutions Practice Group. He serves on Gunster Yoakley's board of directors. Mr. Vázquez-Bello joined the firm in 1979.

Practice Areas

• Banking and Commercial Law
• BSA Compliance and Money Laundering Related Matters
• International Law

Mr. Vázquez-Bello is well-known in the U.S. and international banking circles for his long-standing career as counsel to domestic and foreign banks. In his capacity as banking counsel, Mr. Vázquez-Bello has counseled international and banking clients in licensing, regulatory and transactional matters. Additionally, he has developed substantial expertise in the development and implementation of policies, procedures, programs and systems to prevent, detect and react to the movement of illicit capital vis a vis U.S. laws and regulations. He has also acquired considerable experience in his dealings with U.S. banking and governmental authorities in his areas of specialization.

Education

University of Miami School of Law
J.D., 1974
University of Miami
B.A., cum laude, 1971

Professional Associations and Memberships

The Florida Bar, admitted 1974, International Law Section,
chairman (1986-87) and executive council (1985-89)
Cuban American Bar Association (CABA), board of directors
(1987-92)
General Counsel, Florida International Bankers Association (FIBA)
American Bar Association (ABA)
Miami-Dade County Bar Association
Member of the Bank Secrecy Act Advisory Group of the
Financial Crimes Enforcement Network (FinCEN),
Department of the Treasury (1998- present )

Honors

University of Miami, Early Admissions Program and Scholarship, 1967
AV Rated (means that his legal ability and ethical standards are very
high to preeminent) as independently determined by Martindale-Hubbell
Recognized in the USA Chambers 2004-07 Edition as leading lawyer in
banking and financial matters
Recognized by Florida Super Lawyers as an outstanding lawyer in the
area of Banking Law, 2006-08

Publications

Banking Operations, International Transactions Manual, The Florida Bar, 1998, co-author

Seminars and Presentations

“Fraud Against Banks,” Banking in the ’90s—Opportunities and Challenges,
sponsored by Florida International Bankers Association, Jul. 1992
“New Law Governing Funds Transfers - Article 4A of the Uniform Commercial
Code,” General Meeting of International Banking Operations Associations,
Jul. 1992
“Right to Financial Privacy Act:  Subpoenas, Summonses and Seizures,”
Annual Legal and Regulatory Compliance Conference, Sponsored
by IBOA, Sep. 1992
“Compliance of Domestic & International Banks,” International Conference
on Money Laundering Asset Forfeiture and International Financial Crimes,
sponsored by Oceana Publications, Feb. 1993
“Recent Modifications to Article 3 (Commercial Documents) and Article 4
(Bank Deposits and Collections) of the Uniform Commercial Code,”
Annual Legal and Regulatory Compliance Conference, sponsored by
IBOA, Sep. 1993
“Protecting the Bank’s Assets and Wire Transfer Compliance,” Second
Annual International Money Laundering Conference, sponsored by
“Money Laundering Alert,” May 1994
“A Historical Review of Money Laundering from a U.S. Bank Perspective,”
International Seminar on the Detection and Prevention of the Movement
of Illicit Capital in the Banking System, sponsored by the Association of
Banks and Financial Entities in Colombia and Banco Cafetero, Sep. 1994
“Check Fraud:  The Problem of a Forged or Altered Instrument,” Annual Legal
and Regulatory Compliance Conference, sponsored by the IBOA, Sep. 1994
“Bank Confidentiality in the State of Florida and Legal Protections for Funds
Transfers:  UCC Article 4A,” Ninth Latin American Congress on Bank
Security, sponsored by FELABAN and Florida International Bankers
Association, Sep. 1994
“Recent Developments in the International Banking Arena,” 1994 Money
Laundering Enforcement Seminar, sponsored by American Bankers
Association and American Bar Association, Oct. 1994
Third International Conference on Money Laundering, Asset Forfeiture and
International Financial Crimes, sponsored by Oceana Publications,
“Money Laundering Problems in International Banking,” Feb. 1995
XIV Latin American Congress of Banking Law, sponsored by FELABAN and
by the Association of Banks and Financial Entities of Colombia, “The
Problem of Illicit Funds from the Perspective of U.S. Banks,” Apr. 1995
Anti-Money Laundering Workshop for the Office of the Attorney General of the
Republic of Colombia, sponsored by BANCAFE, “Anti-Money Laundering
Measures in the U.S. Banking System,” Jul. 1995
40th Annual CBF Convention, sponsored by the Community Bankers of
Florida, “The Problem of Money Laundering from a Banking Perspective,”
Aug. 1995
Annual Legal and Regulatory Compliance Conference, sponsored by IBOA,
“International Regulatory Update and Review,” Sep. 1995
Annual Meeting of FELABAN, “Money Laundering Risks and Problems for
Foreign Banks in the United States,” Nov. 1995
International Money Laundering and Transaction Fraud Conference,
sponsored by Global Business Research Ltd., “Recent International
Anti-Money Laundering Developments,” Dec. 1995
General Meeting of IBOA, “New Wire Transfer Recordkeeping Requirements
Regulation and Travel Rule,” Jan. 1996
Mid-Year Legal and Regulatory Compliance Conference (sponsored by IBOA),
Key Largo, FL, “New Treasury (FINCEN) and Federal Reserve Regulatory
on Reporting Suspected Crimes and Suspicious Activities,” Apr. 1996
International Money Laundering Conference (sponsored by Money Laundering
Alert), Miami, FL, “U.S. Office of Foreign Assets Control (OFAC) -
Regulations and Blocking of Assets of Specially Designated
Narcotraffickers,” May 1996
International Money Laundering Conference (sponsored by the Chamber of
Paraguayan Banks), Asunción, Paraguay, “Risks Confronted by Foreign
Banks Doing Business in the U.S. as a Result of Money Laundering
Problems,” Jul. 1996
Regulatory Compliance Conference (sponsored by IBOA), Naples, Florida,
“Post-Implementation Review of Joint Regulation and Travel Rule,”
Sep. 1996
Regulatory Compliance Conference on Bank Confidentiality Law and
Anti-Money Laundering (sponsored by Banco Bilbao Vizcaya, S.A.,
Miami Agency), “BSA Anti-Money Laundering Program,” Oct. 1996
Article entitled “Compliance Issues Arise Under Wire Rules” published
by Money Laundering Alert, Oct. 1996 issue
Anti-Money Laundering Conference (sponsored by Banco Mercantil, C.A.),
Caracas, Venezuela, “Money Laundering Risks and Problems for
Foreign Banks in the United States,” Nov. 1996
IBOA General Meeting, Miami, FL, “FinCEN Advisory on Mexican Bank
Drafts and Factored Third-Party Checks,” Jan. 1997
Article entitled “Proposed Foreign Bank Draft Rules May Hurt Foreign
Commerce” published in Money Laundering Alert, Feb. 1997
IBOA Operations and Technology Conference, Key Largo, FL, “Are You
Ready for the Travel Rule? (Third Update),” Apr. 1997
International Banking Seminar (sponsored by the Central Bank of Honduras
and Amtrade International Bank), Tegucigalpa and San Pedro Sula,
Honduras, “Fraud, Risks and Problems for International Banks,” May 1997
Article entitled “Steps that a Bank Should Take Upon the Arrest and/or
Seizure of a Customer’s Account,” published in Money Laundering Alert,
May 1997
Bank Secrecy and Compliance Training Seminar (sponsored by Florida
International Bankers Association (F.I.B.A.), Miami, FL, “The Problem
of Money Laundering from a Banking Perspective,” Jun. 1997
Conference for the International Representatives of KPMG Peat Marwick, LLP
(sponsored by KPMG Peat Marwick), Miami, FL, “Money Laundering Risks and Problems for International Banks in the United States,” Jun. 1997
Conference for the Board of Directors of Banco Ganadero, S.A., Miami Agency
(sponsored by Banco Ganadero, S.A., Miami Agency), Miami, FL,
“Know Your Customer,” Jul. 1997
Conference for Banco Santander International, Miami, Florida, “Money
Laundering Risks and Problems for International Banks,” Sep. 1997
Regulatory Compliance and Operations Conference (sponsored by the
International Banking Operations Association [IBOA]), Naples, FL,
“Do You Know Your Private Banking Customer? - An Overview of the
New York Federal Reserve Bank Guidance on Sound Risk Management
Practices Governing Private Banking Activities,” Sep. 1997
Teleconference on the Prevention of Money Laundering in the Banking
System (sponsored by KPMG Uruguay Ltda.), “Money Laundering Risks
and Problems for International Banks,” Sep. 1997
Implementing OFAC Compliance Seminar (sponsored by Thomson
Financial Publishing and Money Laundering Alert), Miami, FL,
“New Developments and Issues in OFAC Compliance,” Sep. 1997
Bank Secrecy and Compliance Training Seminar (sponsored by Israel
Discount Bank Ltd.), Miami, FL, “The Problem of Money Laundering
from a Banking Perspective,” Nov. 1997
Anti-Money Laundering Conference (sponsored by KPMG El Salvador),
San Salvador, El Salvador, “Money Laundering Problems in the U.S.
for International Banks,” Dec. 1997
Anti-Money Laundering Conference (sponsored by KPMG Alcaraz Cabrera
Vazquez), Caracas, Venezuela, “Money Laundering Problems in the U.S.
for International Banks,” Dec. 1997
Annual Commercial Meeting of Grupo Santander in La Romana, Dominican
Republic, “Money Laundering Problems for International Banks in the
U.S.,” Dec. 1997
Presentation before the International Banking Operations Association
[IBOA], Miami, Florida, “Privacy and Confidentiality in Banking in the
State of Florida,” Jan. 1998
Presentation before the Cuban American CPA’s Association, Inc., Miami, FL,
“The Money Laundering Problem,” Mar. 1998
Bank Secrecy and Anti-Money Laundering Laws Seminar (sponsored by
Banque Sudameris), Miami, FL, “The Problem of Money Laundering from
a Banking Perspective,” Apr. 1998
Conference on Money Laundering Risks and Problems (sponsored by Banco
Santander International), Miami, FL, “Illicit Capital in U.S. Banking,” Apr. 1998
Presentation for the Board of Directors of Banco Internacional de Costa Rica,
S.A., Miami Agency, Miami, FL, “Obligation to Know Your Customer and to
Report Illicit, Suspicious or Doubtful Activities,” Jul. 1998
Presentation at the Meeting of Compliance Officers of Grupo Santander,
Miami, FL, “The Problem of Illicit Capitals in U.S. Banking,” Jul. 1998
Second Hemispheric Congress for the Prevention of Money Laundering
(sponsored by the Panamanian Banking Association), Panama, Republic
of Panama, Round Table on the topic of “The Black Markets and Their
Effect on International Commerce,” Aug. 1998
First Seminar on Banking Security (sponsored by Febraban- Brazilian
Federation of Banks), Sao Paulo, Brazil, “Illicit Capitals and U.S. Banking,”
Aug. 1998
Banking Compliance Conference (sponsored by International Banking
Operations Association “IBOA”), Naples, FL, “Update on Recent
Developments in Anti-Money Laundering,” Sep. 1998
Seminar on Money Laundering Prevention (sponsored by Corp Banca, C.A.),
Caracas, Venezuela, “Problems of Illicit Capital in U.S. Banking,” Oct. 1998
Seminar on How to Safely Transact Business in South America-Uruguay:
Gateway to Investment and Trade in Mercosur (sponsored by Gunster,
Yoakley, Valdes-Fauli & Stewart, P.A.). Eurofiducia Management and
others, “Are You Ready to Do Business Abroad? Checklist to Reduce
Legal Risks,” Oct. 1998
10th Annual Money Laundering Enforcement Seminar (sponsored by American
Bar Association and American Bankers Association), Washington, D.C.,
“Federal and State (Florida) Confidentiality on Banking, Disclosures,
and the State Harbor Provision,” Nov. 1998
Seminar on the Federal Reserve’s proposed Know Your Customer
Regulation (sponsored by IBOA), Miami, FL, Dec. 1998
Conference on the Proposed Federal Reserve Know Your Customer
Regulations (sponsored by Banco Mercantil, S.A.C.A., Miami Agency,
Miami, FL, “Do You Know Your Customer?,” Feb. 1999
11th International Money Laundering, Cybercrime, Forfeiture, and International
Financial Crimes Conference (sponsored by Oceana Publications, Inc.),
Miami, FL, “Federal and State (Florida) Confidentiality in Banking,
Disclosures and the Safe Harbor Provision,” Feb. 1999
Compliance Conference for Banco Portugues do Atlantico, Miami Agency,
Miami, FL, “The Problem of Money Laundering from a Banking
Perspective,” May 1999
Seminar on Money Laundering and Know Your Customer (sponsored by
The Financial Institute and International Bankers of the Netherlands
Antilles, Curacao, N.V.), Curacao, N.V., “Do You Know Your Banking
Customer?” Jun. 1999
3rd Hemispheric Congress on Money Laundering Prevention (sponsored
by the Panamanian Banking Association), Miami, FL, “Do You Know Your
Banking Customer?,” Aug. 1999
The Miami Herald Americas Conference: The Problem of Money Laundering
in our Hemisphere: Where We Are and Where We Are Going (sponsored
by Gunster, Yoakley, Valdes-Fauli & Stewart, The Miami Herald, American
Airlines, and others), Miami, FL - Topic: “The Global Fight Against
Corruption,” Sep./Oct. 1999
Banking Compliance Conference (sponsored by IBOA), Naples, FL, Topic:
“To Know or Not to Know,” Sep. 1999
Workshop for “Private Banking America” of Banco Bilbao Vizcaya, Miami, FL, Topic:”Problems of Illicit Capital in U.S. Banking,” Nov. 1999
Americas Software Assist//Ck Conference II, Coral Gables, Florida - Topic:
“The Future of Know-Your-Customer,” Jan. 2000
13th Oceana Anti-Money Laundering, Compliance and International Crimes
Conference, Miami, FL (sponsored by Oceana Publications and The
Centre for International Financial Crimes Studies, College of Law,
University of Florida  - Topic: “Know-Your-Customer,” Feb. 2000
Anti-Money Laundering Seminar for International Bankers (sponsored by
FIBA, Miami, FL) Topic: “Overview of BSA/Anti-Money Laundering
Developments During 2000,” Jan. 2001
Private BankAmericas Seminar (sponsored by BNP/Paribas), Key Biscayne,
FL, Topic: “The BSA/Money Laundering Threat,” Apr. 2001
Seminaire Europe (sponsored by BNP/Paribas), Talloires, France, Topic:
“The BSA/Money Laundering Threat: How to Confront It,” May 2001
Workshop on Prevention of Money Laundering (sponsored by Banco Mercantil,
C.A.) Caracas, Venezuela. Topic: “ The Bank Secrecy Act and the Money
Laundering Threat; How to Confront It,” May 2001
2001 Convention on Money Laundering and Cyber Crime (sponsored by
EnCambio and ICSA), Caracas, Venezuela. Topic: “Bank Secrecy Act/The
Threat of Money Laundering in the U.S. Banking System” – Oct. 2001
Breakfast Forum “Cyber Money Laundering Overtakes the Market”
(sponsored by Kroll Consulting Company), Miami, FL, Topic: “The
Looming Threat of the Cyberspace Payment/Transfer Systems,” Oct. 2001
ABA/ABA Money Laundering Enforcement Seminar, Arlington, VA, Topic: “The
BSA/Money Laundering Threat: Correspondent Banking, How to
Confront It,” Oct. 2001
Conference on Anti-Laundering of Monies Obtained Through Corruption
and Organized Crime (sponsored by Banco del Caribe, C.A./Banco
Universal), Caracas, Venezuela; Topic: “The Bank Secrecy Act and
Money Laundering in the United States Banking System,” Nov. 2001
Conference on Title III of the USA Patriot Act (sponsored by the Florida
International Bankers Association, FIBA), Miami, FL, Topic: “International
Money Laundering Abatement and Anti-Terrorism Financing Act of 2001
in a Nutshell,” Dec. 2001
International Banking Conference (sponsored by the Panamanian Banking
Association), Panama City, Panama, Topic: “The USA Patriot Act and
Other Recent Measures Taken Against Terrorism and Money
Laundering,” Dec. 2001
Workshop on the Prevention of Money Laundering and Terrorism
(sponsored by Banco Atlantico, S.A., Miami Agency), Miami, FL, Topic:
“The USA Patriot Act and Other Recent Measures Taken Against Terrorism
and Money Laundering,” Jan. 2002
Conference on EDD Under Title III of the USA Patriot Act (sponsored by
Americas Software Corporation), Miami, FL, Topic: “EDD and the USA
Patriot Act,” Feb. 2002
International Conference on Anti-Money Laundering and Compliance with
the Bank Secrecy Act (sponsored by Florida International Bankers
Association, FIBA), Miami, FL, Topic: “Title III of the USA Patriot Act,” Mar. 2002
Workshop on Anti-Money Laundering and Anti-Terrorism (sponsored by the
Venezuelan Banking Association), Caracas, Venezuela, Topic: “The USA
Patriot Act and Other Recent Events Against Terrorism and Money
Laundering,” Mar. 2002
VI Hemispheric Congress for the Prevention of Money Laundering
(sponsored by the Panamanian Banking Association), Panama City,
Panama, Topic: “The Patriot Act and its Impact on International Banking,”
Aug. 2002
Conference on the Bank Secrecy Act (sponsored by Banco Atlantico, S.A.,
Miami Agency), Miami, FL, Topic: “Amendments to the BSA by the
Patriot Act,” Sep. 2002
2002 IFSA Annual Conference (sponsored by the International Financial
Services Association), Ft. Lauderdale, FL, Topic: “The Impact of the
Patriot Act on Financial Institutions,” Sep. 2002
BSA/Anti-Money Laundering Conference (sponsored by ABN AMRO Bank N.V.,
Miami Agency), Miami, FL, Topic: “Overview of the BSA and the Patriot
Act,” Oct. 2002
Conference on the New Customer Identification Program (CIP) (sponsored
by the International Banking Operations Association), Miami, FL, Topic:
“New Customer Identification Program,” Oct. 2002
ABA/ABA Money Laundering Enforcement Seminar (sponsored by the
American Bankers Association and the American Bar Association),
Washington, D.C.  Topic: “The Impact of the Patriot Act on Correspondent
Banking,” Oct. 2002
Seminar on BSA/Anti-Money Laundering (sponsored by Banco Internacional de
Costa Rica, S.A., Miami Agency), Miami, FL, Topic: “The Patriot Act and its
Impact on Banking,” Nov. 2002
Second Global Conference on International Tax Planning and Money
Laundering Compliance (sponsored by St. Thomas University), Topic:
“The Patriot Act,” Dec. 2002
Third International Conference on Anti-Money Laundering and BSA
Compliance (sponsored by FIBA), Miami, FL.  Topics:  "Overview
of the USA Patriot Act and its Impact on U.S. Financial Institution,
Correspondent Banking and Private Banking" – Jan. 2003
Conference on the USA Patriot Act (Banco Atlantico Group), Panama City,
Panama. Topic: "Impact of the USA Patriot Act on International Banking
Law" – Feb. 2003
Conference on Prevention of Money Laundering (sponsored by Banco
Popular Dominicano, S.A.), Santo Domingo, Dominican Republic. 
Topic: The USA Patriot Act and Other Anti-Money Laundering
Developments" – Mar. 2003
Conference on New Requirements under the USA Patriot Act (sponsored
by FIBA), Miami, FL. Topic: "New Requirement of Customer
Identification Program" – Jun. 2003
Conferences on the BSA and the Patriot Act (sponsored by the Florida Bankers
Association (FBA), Naples, Orlando and Boca Raton, FL.  Topic:
Impact of BSA and the Patriot Act on Trust Business" - Jun. and Oct. 2003
VII Hemispheric Congress for the Prevention of Money Laundering
(sponsored by the Bankers Association of Panama), Panama City,
Panama. Topic: "Update on the USA Patriot Act" - Aug. 2003
Conference on the New Requirements of the BSA (sponsored by the
South Florida Compliance Association), Miami, Florida. Topic:
"New Customer Identification Programs and FinCEN Reports"
– Aug. 2003
Forum on Anti-Money Laundering and Compliance (sponsored by the
Institute of International Research) New York, New York. Topic:
"Impact of the Patriot Act on U.S. Banks and on the International
Banking Business" – Sep. 2003
Annual Conference on Compliance (sponsored by IBOA), Miami, Florida.
Topic: "Latest Developments on the USA Patriot Act - Its Interpretation"
– Sep. 2003
International Private Banking Meeting (sponsored by Santander Group),
Naples, Florida. Topic: "New Compliance Requirements" – Dec. 2003;
4th International Conference on Anti-Money Laundering and Compliance
(sponsored by FIBA), Miami, Florida. Topic: "Implementing the USA
Patriot Act" – Mar. 2004
Annual Conference (sponsored by Asociación  Bancaria y de Entidades
Financieras de Colombia [ Asobancaria] ), Cartagena, Colombia. Topic:
“ The Impact of the USA Patriot Act on Foreign Correspondent Banking”
- Jun. 2004
Annual Compliance Conference (sponsored by IBOA) - Topic: "Update on
BSA/AML", Naples, Florida – Sep. 2004
BSA/AML and Anti-money Laundering Conference (sponsored by First
National Bank of South Florida), Homestead, Florida. Topic: "A Review
of BSA/AML, Anti-Money Laundering and the USA Patriot Act" – Dec. 2004
Fifth Annual BSA/AML Conference sponsored by FIBA & CSBS - Topic:
"Requirement of Reporting Suspicious Activities", Miami, Florida
– Feb. 2005
The International Bank of Miami Annual BSA/AML Seminar - Topic:
"Update on BSA/AML Laws and the USA Patriot Act", Miami, Florida
– Apr. 2005
2005 Trust Conference of the Florida Bankers Association - Topic:
"The Current BSA/AML Scenario in the Aftermath of Riggs Bank
and AmSouth Bank", Palm Beach, Florida – Jun. 2005
Risk Management and Regulatory  Compliance Conference of  the
Financial Institutions Risk Management Association (FIRMA) -
Topic: "Overview of Suspicious Activity Reporting Requirements
and Updates", Naples, Florida – Sep. 2005
Sixth Annual Anti-Money Laundering Compliance Conference sponsored
by Florida International Bankers Association (FIBA) - Topics:
"Section 312 - Final Rule and Notice of Proposed Rulemaking"
and "Recent BSA/AML Developments", Miami, Florida – Feb. 2006
Senior Management Certification Course sponsored by Florida International
Bankers Association (FIBA)'s Anti-Money Laundering Institute - Topic:
"The Management of BSA/AML Risk",  Miami, Florida – Nov. 2006
FIBA 7th Annual AML Compliance Conference - Topics: "Overview of
Suspicious Activity Reporting Requirements" and "Overview of
Requirements on Foreign Correspondent Banking", Miami, Florida
– Feb. 2007
FIBA Anti-Money Laundering Institute, Senior Management Certificate
Course - Topic:  "The Management of BSA/AML Risk"
– Miami, Florida – Apr. 2007
The South Florida Compliance Association Regulatory Compliance
Conference - Topic: "Continuing Compliance Headaches",
Miami, Florida – Jun. 2007
2007 Annual Convention of The Florida Bankers Association -
Topic: "BSA/AML Requirements of Senior Management and
Board: How to Limit Personal Risk" – Jun. 2007
Argentine Banking and Financial Sector Conference - Topic:
"What the BSA and Other Anti-Money Laundering Regulations
Require of U.S. Banks" - Buenos Aires, Argentina – Sep. 2007
FIBA 8th Annual BSA/AML Compliance Conference - Topic:
"Suspicious Activity Reports: If I Don't File, Will My Decision Be
Questioned/Overruled?", Miami, Florida – Feb. 2008

Languages

Spanish