
Mike C.
VP of Compliance Operations & Chief of Staff @ OKX
About
I help companies navigate the complex and evolving regulatory landscape of emerging technologies, such as cryptocurrency, blockchain, web3, and digital payments.
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United States
Financial Services
Artificial Intelligence (AI), Data Privacy, Global Regulatory Compliance, Payments, Cross-border Transactions, Money Transfers, Regulatory Compliance, Anti-Money Laundering, Blockchain, Digital Assets, Fraud Prevention, Fraud Investigations, Consumer Protection, General Data Protection Regulation (GDPR), Data Privacy Risk Management, Economic Sanctions, U.S. Office of Foreign Assets Control (OFAC), Risk Management, Process Improvement, Leadership
Experience

VP of Compliance Operations & Chief of Staff
~ Leads the core operational compliance functions consisting of over 200 staff responsible for Financial Crimes Compliance, Sanctions, KYC, Data Privacy, and Market Surveillance ~ Responsible for enhancing the operational posture of OKX's compliance programs through oversight of Compliance Data & Technology and PMO. ~ Supports CCO initiatives related to compliance governance and program maturity. ~ Supports compliance leads and local MLROs across 12 global regions.

Global Head of Compliance
~Led a team of 25 compliance staff addressing consumer protection, AML, sanctions, data privacy, and fraud compliance risks. Applicable regulatory frameworks include: BSA, OFAC, UDAAP, GLBA, FCPA, GDPR, and MiCA. ~Acted as the most senior advisor to the Board of Directors on critical compliance risks, issues, and solutions to maintain an appropriate safety and soundness posture and operate an effective compliance program. ~Served as the company’s primary AML and Sanctions subject matter expert. Oversaw the Know-Your Customer, Transaction Monitoring, and reporting programs to include risk-based policies, processes, and technology implementation. ~Managed US money transmission licensing and related reporting, examinations, and communications. Leads international licensing efforts, in addition to creating regulatorily-appropriate guardrails for global operations. ~Acted as the primary proponent for establishing US and international banking relationships in partnership with Arkham’s finance and operations teams. ~Served as the company’s Data Privacy and Protection Officer and BSA Officer.

Senior Managing Director
~Co-Leader of the firm’s Technology Governance-Risk-Compliance team. ~ Led the Compliance and Risk services for the firm’s Blockchain & Digital Assets team. ~Led multiple independent program assessments for various financial institutions’ BSA/AML, OFAC, ABAC, UDAAP, and GLBA compliance programs (including crypto, payments, and neobanks). ~Conducted a compliance gap assessment and improvement roadmap for one of the world’s largest digital asset exchanges to help remediate previous Department of Justice Anti-Money Laundering violations and prepare for expanded US licensing applications. ~Served as the Interim CCO for a technology company providing API and relay services for Ethereum privacy pools and regulated money transmission. ~Advised one of the world’s largest payments companies in mapping their restricted and controlled products and services controls to global regulations and controls. Deliverables included a rubric for assessing illegal products versus controlled products and related payments flows based on geographic restrictions, scenario modeling, and techniques for updating product screening controls. ~Provided advice to one of the world’s largest peer-to-peer payments services related to consumer protection and AML compliance operations. Advisory included the development of a consumer protection principles framework, updates to AML (transaction monitoring) and Customer Support policies and procedures, improvement to customer-facing communications and complaints management, and customer support operations. ~Established the AML, Sanctions, Consumer Protection, and Anti-Fraud compliance functions for an EMEA payments company looking to expand their operations in a variety of highly-regulated jurisdictions. ~Briefed the Department of Justice regarding the sufficiency and appropriateness of a client’s AML, sanctions, and export controls after a gap assessment and the provision of advice related to strengthening AML monitoring and customer controls.

Chief Compliance Officer
~Led a team of over 40 compliance staff addressing consumer protection, AML, sanctions, data privacy, and fraud compliance risks. ~Guided the company through an inherited Department of the Treasury investigation, and implemented remediation measures that saved the company tens of millions of dollars in fines. ~Developed compliance roadmaps to implement technology and process improvements to assist in scaled, smart growth. ~Advised global compliance teams in Bermuda and Europe on a variety of strategic compliance issues including regulatory reporting, license applications and maintenance, and enterprise risk. ~Led the company through 23 state and federal regulatory and compliance examinations and maintained MSB/MT licensure in 46 states. ~Oversaw enterprise risk with a focus on safety and soundness measures that include financial stability, security, and consumer protection.

Senior Director
~Developed a data simulation model to assess internal and external fraud and corruption risk for a multi-functional, multi-jurisdictional Fortune 500 company in support of a DOJ matter. ~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. ~Built a weighted scoring model and methodology to measure money laundering and terrorist financing risk within a cryptocurrency exchange. ~Led an 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.

Financial Crimes Consultant
~Team leader for a transaction monitoring project for a global financial institution that supported BAU screening functions and identified suspicious or prohibited transactions. Oversaw and performed OFAC screening by analyzing thousands of daily wire transfers and testing for compliance with OFAC restrictions on sanctioned entities. ~Team leader for a 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. Oversaw the analysis, data remediation, and risk profiling of over 6000 bank customers. ~Site and project team leader for Global Delivery Service teams for Anti-Money Laundering and Financial Crimes. ~Served as the EY Veterans Network Communications Leader for over 800 veterans of US and foreign militaries, military spouses, and anyone with an interest in veterans' issues.

Major
United States
• Led the planning and execution of complex projects and operations for units as large as 200 people. • Prepared detailed plans that supported execution of DoD policies and strategy, specifically as they related to counter-terrorism and threat response. • Responsible for the synchronization of activities across multiple lines of effort and time. Improved the operational systems, processes and policies in support of multiple organizations’ missions. • Served as senior planner and leader of various tactical operations in support of the Global War on Terror, including combat, terrorist finance network mapping, logistics, training, and budgeting. • Extensive experience in counter-terrorism activities, including CFT network mapping and disruption. • Consistently rated in the top ten percent of peers by senior commanders. • Continues to serve in the Individual Ready Reserve (IRR).
Mike C.'s Contact Information
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