Mr. Mirkin’s expertise, experience, and reputation for integrity have led to his selection as a corporate monitor/independent AML compliance consultant for a global financial institution and approval by US securities regulators. In that capacity, he has produced reports and recommendations for US regulators on virtually every aspect of AML compliance.
Mr. Mirkin has engaged in complex decision-making involving compliance and risk for:
- US, UK, European, and other foreign banks
- US and UK broker-dealers and investment advisers
- US, offshore, and other foreign hedge funds
- US, UK, and European multinational companies
- Payments companies and other fintechs
- Sovereign wealth funds
- Central banks
- High-net-worth investors
Mr. Mirkin has created, supervised, reviewed, and implemented risk assessments on issues such as:
- Know your customer (KYC) and onboarding risks (customer, vendor, and intermediary)
- Transaction monitoring
- Suspicious Activity Reports/Suspicious Transaction Reports
- Screening software (adverse media, sanctions, and politically exposed persons (PEP) accounts)
- Beneficial ownership
- False positives, false negatives, and alert clearing
- Due diligence programs
- Customer and country risk ranking and algorithms
- Benchmarking, metrics, and deliverables
- Training programs
With more than a decade of experience with cyber- and information-security programs, including having headed cybersecurity compliance for one of the world’s largest wealth managers, Mr. Mirkin is an expert in shrinking attack surfaces for both global enterprises and small and medium-sized businesses; and in preventing data leakage in areas such as social engineering programs, identification and authentication, patching protocols, least privilege, and information barriers. He also has overseen and advised prominent financial institutions in regulatory examinations of bank cybersecurity programs and cybercrime investigations.
Mr. Mirkin’s experience also includes global data rationalization and data lineage reviews and assessing data flows across networks and global organizations, as well as handling data breaches and incident response. A former corporate chief privacy officer, he led a prominent technology company’s global privacy program, including its General Data Protection Regulation (GDPR) compliance program.
As a senior regulator, Mr. Mirkin led teams investigating and prosecuting the Financial Industry Regulatory Authority’s (FINRA) highest-priority matters against member firms and their executive leadership arising from alleged violations of FINRA and Securities and Exchange Commission (SEC) rules and orders. He applied his expert insights on broker-dealer and investment management issues to advise FINRA lawyers and investigators in enforcement, member regulation, and market regulation on a range of key issues, including supervision and executive liability.
Mr. Mirkin serves as one of the two US representatives on the International Compliance Association’s Advisory Board and its ESG Compliance committee. He has served in leadership positions within the American Bar Association, including as co-chair of its International AML Committee and as an appointed member of its AML/Anti-Terrorism Financing Task Force.
Mr. Mirkin speaks frequently at conferences and seminars, including keynoting on US and EU compliance and regulation.
Employment History
Regulatory DataCorp (RDC)
Managing director & chief privacy officer
2017 – 2018
State Street Bank
Vice president, regulatory compliance
2015 – 2016
Nixon Peabody
Counsel
2013 – 2014
FINRA
Senior litigation counsel
2010 – 2013
Celadon Financial Group
Chief compliance officer
2007 – 2010
Fowler White Burnett
Partner
2003 – 2007
Professional Affiliations
American Bar Association
Joint Task Force on AML & Anti-Terrorism Initiatives (Section of Business Law)
Member (appointed)
2009 – present
International AML Committee (Section of International Law)
Co-Chair
2010 – 2011
International Financial Products & Services Committee (Section of International Law)
Vice-Chair
2010 – 2011
Corporate Counsel Subcommittee, Ethics & Professionalism Committee (Section of Litigation)
Chair
2010 – 2016