Mike Carter

Mike Carter is an expert in digital assets, regulatory compliance, and financial crimes investigations. Mr. Carter has extensive experience providing advisory and investigative services for financial crime matters globally, including leading complex engagements for financial institutions, digital asset service providers, construction firms, manufacturing and distribution companies, and utilities services to address risk and compliance concerns.

Mr. Carter most recently served as the Chief Compliance Officer (“CCO”) from 2020 to 2023 at a major digital asset exchange where he led the scaling and redesign of the global compliance program addressing issues related to money laundering, sanctions, fraud, data privacy and protection, market surveillance, product risks, licensing and regulatory examinations.

In addition to his experience as CCO, Mr. Carter has led numerous compliance and regulatory projects at global consulting firms, including addressing regulatory risks at numerous digital asset companies during startup and growth phases, supporting government-appointed monitors, conducting sensitive investigations for high-profile matters, building executable compliance roadmaps and implementing data models to assess risk.

Mr. Carter served as the Anti-Money Laundering ("AML")/Bank Secrecy Act ("BSA") Committee Chair for the Virtual Commodity Association from 2019 to 2020 and on the AML Committee for TRUST Travel Rule from 2020 to 2023. A frequent contributor to financial crimes industry publications, Mr. Carter has been featured in Bloomberg Law, Wall Street Journal, and the New York Law Journal. He authored the digital assets section of the Committee of Sponsoring Organizations of the Treadway Commission ("COSO") and the Association of Certified Fraud Examiners ("ACFE") 2023 Fraud Risk Management Guide.

Mr. Carter is a United States Army veteran and served in Operation Enduring Freedom. He also serves as a board member of The Ability Experience.

Relevant Experience:

• Successfully led a digital asset exchange through dozens of U.S. and global regulatory examinations and investigations, saving the company tens of millions of dollars in anticipated fines and remediation costs
• Created a digital asset listing and assessment process designed to address AML, fraud, privacy, security and consumer protection risks at a global digital asset exchange
• Designed a data protection and privacy program aimed at addressing risks related to Gramm-Leach-Bliley Act, Federal Trade Commission and General Data Protection Regulation (“GDPR”) rules regarding processing, use, storage and security of consumer data
• Developed a data simulation model to assess internal and external fraud and corruption risk for a multifunctional, multijurisdictional Fortune 500 company in support of a Department of Justice monitorship
• Led an Office of Foreign Assets Control (“OFAC”)-based investigation into an Indian bank's transactions tied to Iranian, North Korean, Syrian and Turkish entities across a five-year span
• Assisted an eastern-European bank in assessing its customer risk, specifically reviewing high-risk customers for sanctions, adverse media and beneficial ownership issues; executed a targeted lookback of potentially suspicious transactions related to high-risk entities
• Project manager for a global Bitcoin exchange AML support initiative; project focused on mitigating customer AML/BSA risk with a team of 80+ investigators leveraging technology and research methods to address: account activity and linkage, source of funds, enhanced due diligence, deep web research, SARs and sanctions; project also incorporated risk assessments, international wires program development and AML program roadmaps
• AML/BSA adviser for a U.S.-based precious metals dealer
• Developed a compliance roadmap (AML/BSA/OFAC) for a global virtual currency firm focused on mapping risk assessment findings to regulatory guidance, then building a program of compliance improvement projects to meet regulatory expectations
• Built a weighted scoring model and methodology to measure money laundering and terrorist financing risk within a cryptocurrency exchange
• Team leader for a Know Your Customer (“KYC”) remediation project focused on a global financial institution’s high-risk customer base in response to an OCC Consent Order that identified systematic deficiencies in the bank’s AML program

Awards & Recognition:

• Bronze Star Medal, United States Army
• Meritorious Service Medal, United States Army
• Humanitarian Service Medal, United States Army
• Army Commendation Medal, United States Army
• Combat Infantryman Badge, United States Army
• Prominent Patriot, GMU School of Business