Overview
Arthur D. Middlemiss practices in the area of financial crimes compliance. Mr. Middlemiss focuses on providing strategic counsel to foreign and domestic entities seeking to mitigate regulatory, criminal and reputational risk in the areas of anti-money laundering (AML), anti-bribery and corruption (ABC) and economic sanctions. Mr. Middlemiss has represented individuals and corporations in criminal investigations, investigated alleged violations of the Foreign Corrupt Practices Act, and advised financial and other companies with respect to best practices in the fields of AML and ABC compliance. He has served multiple times as an AML expert for the Financial Industry Regulatory Authority (FINRA).
Prior to joining the firm, Mr. Middlemiss was the Director of the Global Anti-Corruption Program at JPMorgan Chase & Co, responsible for designing and executing an enterprise-wide compliance program to mitigate corruption-related risk. Mr. Middlemiss also held multiple senior positions in the bank’s Anti-Money Laundering Program. Among them, Mr. Middlemiss headed the firm’s Financial Intelligence Unit, a group formed to develop strategies to identify and confront proactively emergent money laundering-related risk, including that posed by human trafficking.
In the public sector, Mr. Middlemiss served for thirteen years under Robert M. Morgenthau as an assistant district attorney in the New York County District Attorney’s Office. As bureau chief of the District Attorney’s international financial crimes bureau, Mr. Middlemiss conducted and supervised investigations involving complex securities fraud and money laundering. The resolution of multiple matters Mr. Middlemiss supervised required financial institutions to reform materially their internal compliance controls. Mr. Middlemiss also co-led the District Attorney’s investigation into the role of U.S.-based financial institutions in the collapse of Enron.
Mr. Middlemiss is a regular public speaker on financial crime compliance topics, and has provided Congressional testimony about international money laundering.
SPEAKING ENGAGEMENTS
- Speaker, July 2014 - Human Trafficking Compliance Programs, 3rd Latin American Congress on Ethics, Transparency and Anti-Corruption Compliance, Buenos Aires, Argentina
- Speaker, May 2014 - “The Foreign Corrupt Practices Act and International Anti-Corruption Developments in 2014,” PLI, New York, New York
- Moderator, February 2014 – Anti-Corruption panel, 14th Annual FIBA Anti-Money Laundering Conference, Miami, Florida
- Speaker, January 2014 – “Amplifying Information Sharing with Correspondent Relationships to Effectively Manage Risk,” ACAMS 2nd Annual Risk Management Conference, New York, New York
- Speaker, November 2013 – “Big Data Technology: the Impact on BSA/AML Compliance,” Foundation for Accounting Education Money Laundering Conference, New York, New York
- Speaker, September 2013 – “The Role of the Private Sector in Combating Human Trafficking,” 31st Symposium on Economic Crime, Jesus College, Cambridge University, Cambridge, United Kingdom
- Moderator, September 2013 – Case Study: Anti-Corruption Internal Investigations, 5th Business Law Forum: Global Integrity Challenges for Anti-Corruption and Anti-Money Laundering, New York, New York
- Speaker, August 2013 – Topics: Insider Trading; Trends in International Enforcement, 2nd Latin American Congress on Ethics, Transparency and Anti-corruption compliance, Buenos Aires, Argentina
- Speaker, July 2013 – “Corporate Corruption, Challenges for AML/CFT Risk Management,” XIII Congreso Panamericano de Riesgos de Lavado de Activos y Financiacion del Terrorismo, sponsored by Asobancaria, Cartagena, Colombia
- Speaker, June 2013 – “Correspondent Banking and Suspicious Money Movement,” 2013 Financial Symposium, sponsored by the New York High Intensity Financial Crime Area and the Homeland Security Investigations El Dorado Task Force at the Federal Reserve Bank of New York
- Speaker, March 2013 – “Anti-Money Laundering Issues and Best Practices,” 5th Annual Global Ethics Summit sponsored by the Ethisphere Institute and Thomson Reuters, New York, New York
Professional Affiliations
- Morgenthau Alumni Group
- New York City Bar Association
Practice Areas
Education
- Boston University School of Law (J.D. 1994)
- Lafayette College (B.A. 1991)
Bar Admissions
- New York
- U.S. District Courts for the Southern District of New York and the Eastern District of New York