About Mike
Mike Carter is an expert in digital assets, regulatory compliance and financial crime investigations. Mr. Carter brings extensive experience providing advisory and investigative services for financial crime matters worldwide, including leading complex engagements for financial institutions, digital asset service providers and payments companies to address risk and compliance concerns.
Mr. Carter has held senior positions and advisory roles in various blockchain-native organizations. As the chief compliance officer (“CCO”) at a major digital asset exchange, he led the scaling and redesign of the global compliance program, which addressed issues related to money laundering, sanctions, fraud, consumer protection, data privacy, market surveillance, product risks, licensing, enterprise safety and regulatory examinations. He also served as an interim CCO, building the compliance program and executing the licensing strategy for a digital asset company providing application programming interface ("API") and relay services for digital asset pools and regulated money transmission. Prior to his time supporting digital assets organizations, he led compliance and regulatory projects at global consulting firms, addressing regulatory risks at various companies, supporting government-appointed monitors and conducting investigations for high-profile matters.
In addition to his executive roles, Mr. Carter has served as the Anti-Money Laundering/Bank Secrecy Act (“AML/BSA”) Committee Chair for the Virtual Commodity Association and the AML Committee for TRUST Travel Rule. He has been featured in Bloomberg Law, The Wall Street Journal and The New York Law Journal. Additionally, Mr. Carter authored the digital assets section of the Committee of Sponsoring Organizations/Association of Certified Fraud Examiners (“COSO/ACFE”) 2023 Fraud Risk Management Guide. Most recently, he contributed to the sanctions chapter of the book, “Banking [on] Blockchain: A Legal and Regulatory Primer.”
Mr. Carter is a U.S. Army veteran who served in Operation Enduring Freedom. He also serves on the boards of The Association of Women in Cryptocurrency and 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
- Reviewed a New York State Department of Financial Services-licensed digital asset and prepaid card provider’s historic customer activity and made assessments regarding the appropriateness of transaction monitoring rules; conducted phased work, including sampling, customer and transactional data assessment and rules tuning; prepared a subsequent lookback approach
- Assisted a client in successfully obtaining a digital asset business license from the Bermuda Monetary Authority; performed a gap analysis of the company’s prudential risk and compliance program into crucial focus areas, including risk management framework, client due diligence, internal management controls and conduct of business
- Conducted an AML and enhanced sanctions independent assessment for a U.S. bank servicing digital asset businesses through settlement and custody; the report and related findings were submitted to regulators as part of the bank's proposal for updated business operations approval and highlighted its compliance policies, controls and opportunities for improvement
- 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
- Led a consumer protection compliance operations advisory project for a peer-to-peer fiat and digital assets payments service; advisory work included development of a consumer protection principles report, updates to policies and procedures, improvement to customer-facing communications and customer support operations
- 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 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-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
Awards & Recognition:
- Prominent Patriot, GMU School of Business
- Bronze Star Medal, U.S. Army
- Meritorious Service Medal, U.S. Army
- Humanitarian Service Medal, U.S. Army
- Army Commendation Medal, U.S. Army
Certifications
Certified Anti-Money Laundering Specialist (“CAMS”)
Certified Fraud Examiner (“CFE”)
Certified Global Sanctions Specialist (“CGSS”)
Travel Rule Fundamentals Certification (“NB-TRFC”)
Project Management Professional (“PMP”)
Education
B.A., University of North Florida
M.B.A., George Mason University
-
Contact
T: +1 917 557 0765
mike.carter@fticonsulting.com -
Office
One Biscayne Tower
2 S. Biscayne Blvd., Suite 1850
Miami, FL 33131
United States
-
Expertise
Anti-money Laundering
Digital Assets
Fraud Risk
Global Risk & Investigations
OFAC Investigations