- Twenty years as a risk and compliance executive in and advisor to Fortune 500 multinationals
- Extensive experience directing domestic and cross-border investigations of alleged fraud and other corporate misconduct
- Architect and leader of ERM and global anti-corruption, 3PRM, privacy, international trade, records management and conflicts of interest compliance programs
- Wide-ranging US federal, state and local and non-US public sector compliance experience
- Former Fellow of the Ethics and Compliance Initiative (ECI) and
- ECI Leadership Professional in Ethics and Compliance (LPEC)
- Certified Compliance and Ethics Professional (CCEP)
Chris DePippo is an accomplished risk and compliance leader with 20 years of advisory and executive experience in Fortune 125 technology services companies with $6B to $25B global businesses. His career is marked by significant achievements as a strategic architect and day-to-day leader of global risk programs, a seasoned second line risk defender, a determined change agent and culture steward and, more recently, a digital transformation and modernization strategist.
Broadly, Chris’s competencies include best-in-class ethics and compliance program strategy and governance, program assessment and leading practices alignment, values-in-action programs, global expansion, risk assessment and internal controls, risk handling plan administration, 3PRM and due-diligence, Code of Conduct and enterprise policy management, compliance training and education, internal controls monitoring and audit, root cause analysis and continuous improvement, GRC platform/application selection and implementation, strategic process optimization, ethics and compliance program benchmarking, management and Board reporting, and ERM.
In addition, Chris is an experienced investigations leader who has built Fortune 125 internal investigations teams and functions and overseen or directed nearly 1,100 domestic and international investigations of alleged fraud and other misconduct. Here his experience has been to establish helpline and investigator teams, assemble tools, and optimize processes to investigate fraud, public sector bribery, commercial corruption, asset misappropriation, and other misconduct from intake and assignment through investigation, reporting, closure, root cause analysis, and remediation.
Chris is a former Fellow of the Ethics and Compliance Initiative (ECI), an ECI Leadership Professional in Ethics and Compliance (LPEC), and a Certified Compliance and Ethics Professional (CCEP). He earned a Bachelor’s degree from Cornell University and a Master of Business Administration from The George Washington University.
Before joining SunHawk, in 2020 Chris established his Trio Inspired consultancy to help compliance leaders meet effectiveness and transformation imperatives and risk executives meet demands for value from the discipline of ERM. As Trio’s Principal Strategist, Chris led for a leading IT services company a current state assessment of the global ethics and compliance function and advised strategies for stronger alignment to regulatory and leading practice frameworks. For a leading investment bank, Chris supported efforts by legal and compliance to scope a strategic process and technology optimization initiative intended to promote consistent execution of standards promulgated by the compliance function’s central rules/policy and training teams. And for a technology and legal services company, Chris led a strategic exploration of the potential to commercialize outsourced, right-shored “managed compliance and investigations as-a-service” business opportunities in the risk and compliance domain.
Before leading Trio, Chris spent 12 years with Fortune 125 enterprise technology services provider DXC Technology (NYSE: DXC) and its predecessor, CSC, as the company’s first-ever Chief Ethics and Compliance Officer and ERM leader. Soon after his 2008 arrival at CSC, the company came under investigation by the SEC for certain accounting, internal control, and disclosure irregularities. An independent Board investigation followed.
In response, Chris secured Board approval for the values-based ethics and compliance and internal investigations programs he would build and lead for more than a decade, and which would provide opportunity to develop and refine the expertise he delivers SunHawk clients today. His role as the architect and leader of these programs helped CSC settle the matter without criminal charges—consistent with the terms of the settlement order, Chris twice certified to the government that his programs had adopted certain remediations recommended by an independent compliance consultant and comported fully with the effectiveness criteria set forth in the US Federal Sentencing Guidelines’ Effective Compliance and Ethics Program framework.
Earlier, Chris began his compliance career while at Affiliated Computer Services, then a $6B global provider of diversified business process outsourcing and IT services to government and commercial clients. In 2003, not long after the accounting scandals that collapsed Enron and WorldCom, Chris was named to a team responsible to bring ACS into compliance with newly-enacted Sarbanes-Oxley legislation. Later, in 2007, he was appointed VP and Group Compliance Officer for ACS’s $2.4B US state and local government business and given responsibility to develop for that business a compliance program that would evidence more strongly the effectiveness criteria outlined by the US Federal Sentencing Guidelines.
"SunHawk was an outstanding partner in the provision of interim leadership in compliance and internal audit for our organization. They provided seamless coverage and advancement of our compliance and internal audit functions. As CEO, I had no concerns or worries during our engagement. They were true partners for us!"
Alfred E. Pilong
President and CEO
"James and the SunHawk team have been an invaluable resource for our Compliance Office - they are a reliable, well experienced, trusted and knowledgeable team of professionals who at a moment’s notice will take your calls or respond to your emails.
Their advice helped us navigate the ever evolving, highly regulated healthcare industry! Whether it’s discussing report methodology or determining appropriate repayment, SunHawk provides the reassurance and confidence that you are doing the right thing!
We are honored to have partnered with SunHawk and will continue to do so in the future!"
Vice President/Chief Ethics, Compliance and Privacy Officer
Community Health System
"SunHawk’s professionals are leaders in the compliance and risk industries. Over the years I have worked with a number of their professionals on a series of projects/issues and learned SunHawk’s professionals are problem/solution-oriented and great coalition builders.
SunHawk Professionals get the job done and are a pleasure to work with. Commitment, Experience, Professionalism, and Integrity; that's what SunHawk Professionals brings to the table."
Vice President/Chief Ethics, Compliance and Privacy Officer
Phoenix Children's Hospital
"Jim Rough is among the most conscientious professionals I have encountered. When he says he is going to do something -- he does it. Jim has a broad range of experience gained over decades in leading organizations.
Now as the founder of his own firm, Jim will be enabled to provide the same high-quality service to his clients in a setting that allows greater customization to his clients' financial circumstances."
Frank M. Placenti
Chair, US Corporate Governance & Securities Regulation
Practice, Squire Patton Boggs
"SunHawk Consulting's HIPAA Check Program provided us with an invaluable third-party review of our HIPAA policies and practices. The tracking tool SunHawk includes with the Program has become an integral part of our continued monitoring for HIPAA compliance.
Jan Elezian's extensive hands-on compliance experience was evident during site visits and staff interviews as she translated difficult subject matter into practical use scenarios and provided quality feedback. Thank you SunHawk team!"
Vice President, Compliance
Chicanos Por La Causa, Inc.
"SunHawk provides an array of dynamic professionals, each with significant subject matter expertise and a problem-solver approach. Beyond their knowledge and conscientious work ethic, however, is a team of caring individuals who strive to furnish individualized, tailored assistance with a personal touch.
Jim Rough's dedication to the success of SunHawk clients is evidenced by his strategic and prospective thinking complemented by his ability to truly anticipate the needs of a company in the midst of the complicated compliance climate. I highly recommend SunHawk for companies of any size seeking actionable solutions and measurable results."
Vice President and Chief Compliance Officer
Paragon 28, Inc.
“Sunhawk Consulting has proven to be a trusted partner with the ability to deliver results. We have consistently been impressed with their expertise, professionalism, and commitment to customer service. Sunhawk Consulting has supported our enterprise-wide risk assessment, risk management activities, and the configuration of our Governance, Risk and Compliance software tool.
Sunhawk Consulting’s leadership and consultative services have helped us to successfully navigate through the complexities of SOC, HIPAA, NIST and FedRAMP audits this year. The knowledgeable team of Sunhawk professionals has been and continues to be an invaluable resource for us, ensuring we are positioned for success in all our audits and assessment activities.”
Chief Technology Officer (CTO)
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SunHawk Consulting specializes in professional consulting services and has a team of highly skilled subject matter experts with substantial backgrounds in:
* Healthcare Compliance: Statistical Sampling, Medical Coding Audits, Healthcare Compliance Programs, Evaluation of Compliance Programs and Risk Assessments, HIPAA Compliance Risk Assessments & Training, Corporate Integrity Agreement (CIA) Board Advisor, Independent Review Organization (IRO) Services, Interim Healthcare Compliance Support, Physical Security Assessment, Design and Implementation of Sunshine Act Compliance Programs, Enterprise Risk Management Optimization, Governance, Risk and Compliance (GRC) System Support, Electronic Health Record (EHR) System Implementation, Outsourced Audit Function Support, Medical Risk Adjustment Compliance (Medicare, Medicaid, Commercial), Policy, Procedure, Internal Control Development and Evaluation, FedRAMP Compliance;
* Corporate Investigations: Fraud Investigations and Forensic Accounting, Anti-money Laundering (AML), Bank Secrecy Act (BSA), Know Your Customer (KYC), Foreign Corrupt Practices Act, Third-party Due Diligence;
* Corporate Compliance: Evaluation and Design of Corporate Compliance Programs, Interim Compliance Support, Compliance Risk Assessments, Physical Security Assessment, Enterprise Risk Management, Private Equity Governance, GRC System Support, Audit Function Support, Fraud Risk Assessments, Investigations Program Assessment and Enhancements, Qui Tam Investigations, Hot Line Support;
* Litigation Disputes: Complex Litigation and Disputes, Mergers and Acquisitions: Regulatory Due Diligence, Expert Witness, Statistical Analysis, Healthcare Payment Disputes, Litigation Support, Physical Security Assessment, Neutral Party Data Analysis.