Corporate Investigations, Risk & Compliance, Fraud Investigations
Jerry is a former federal law enforcement professional and corporate investigations subject matter expert with global experience in mitigating risk and promoting ethics and compliance. For over 20 years, Jerry had a distinguished career as a Special Agent and Supervisory Special Agent with the Federal Bureau of Investigation and the Naval Criminal Investigative Service before that. He has extensive investigative experience ranging from U.S Government procurement and bribery within the Pentagon to complex narcotics, domestic and international terrorism matters. Jerry was routinely deployed internationally conducting investigations in Asia, the Philippines, Africa, Europe, and the Middle East. For the last four years of his FBI career, he was assigned to the U.S. Embassy in Singapore as the FBI’s Assistant Legal Attaché covering Singapore, Malaysia, and Indonesia. In that role, he was responsible for managing and conducting complex international investigations of fraud, terrorism, and other crimes. Jerry’s Legal Attaché work overseas involved liaison and briefings to both high-level U.S. Government and foreign government officials.
Jerry retired from the FBI to join Microsoft Corporation’s Financial Integrity Unit, a global business conduct investigations, and compliance program. He spent over 15 years at Microsoft and developed and managed the Financial Integrity Unit’s investigation program first in the Asia Pacific Region including China, India, Australia, and New Zealand, and then in the Latin America and Caribbean Regions. At Microsoft, Jerry conducted internal investigations alleging marketing and procurement fraud, bribery, conflict of interest, favoritism, whistleblower retaliation as well as other employee and vendor misconduct. Jerry has experience in presenting the results of those investigations to law enforcement for prosecutorial consideration. In addition to his investigative experience, Jerry was a member and a team leader on the Washington, DC Field Office’s FBI SWAT Team which included planning and executing high-risk search and arrest warrants, tactical response, and executive protection. He is uniquely certified as a Death/Homicide Investigator by the Metropolitan Police Department, Washington, DC.
Jerry has received numerous awards and recognition for investigations he has conducted from the FBI, the Department of Justice, and other foreign and domestic organizations. He is most proud to be a recipient of the FBI Shield of Bravery and the FBI Agents Association’s J. Edgar Hoover Memorial Award For Valor.
Prior to entering law enforcement, Jerry was a schoolteacher in El Paso, Texas. He then taught overseas in Germany and Okinawa, Japan, with the Department of Defense Overseas Dependents School System (DODDS).
Select Engagement Experience
Investigation of Promotion Favoritism
Following receipt of an anonymous hotline allegation that a manager and his/her direct report were involved in an extra marital romantic relationship and that the manager promoted that direct report over more qualified members on his/her team, Jerry Bamel led an internal investigation. Jerry’s investigation confirmed their relationship as well as confirmed that the direct report had considerably less experience than others who applied for the position and that the promotion was based upon favoritism. During their individual interviews both the manager and the direct report denied being involved in a romantic relationship which the evidence refuted. As both individuals lacked candor and truthfulness they were terminated.
Jerry Bamel received an allegation directly from an external company owner alleging that a technology company employee had been soliciting kickbacks from him in order to ensure his company was the sole regional distributor for the technology company’s products. Jerry’s investigation confirmed that the company owner decided to come forward after becoming frustrated with the employee’s increasing kickback demands. Jerry’s investigation confirmed the company owner gave the technology company employee gifts which included a luxury watch, admission to Disneyland for the employee and his/her family as well as confirming the employee solicited other gifts to maintain the sole distributorship of the company’s products. Prior to being interviewed the employee resigned.
Misuse of Procurement Authorization
During a routine technology company audit which identified procurement anomalies Jerry Bamel led an internal investigation regarding purchases of office products by an employee at a technology company. Jerry’s investigation determined that an employee had procurement authorization and was purchasing large quantities of non-inventoried office products to include copy machine paper, batteries, computer printer cartridges and other office products which were then delivered to his home address. Jerry’s investigation determined that the employee then included those items for sale at a booth the employee maintained at a weekend flea market. The employee was terminated. Jerry also recommended implementing additional procurement controls over non-inventory items.
Misuse of Company Issued Credit Card Issued For Travel
As part of a remote audit of a technology company’s credit card issued to employees for travel to determine if personal items were being purchased and expensed as having been incurred for business purposes, Jerry Bamel identified an employee with a significant number of expenses which appeared to be personal rather than business travel related which were submitted and approved for reimbursement. Those expenses included amongst other things as meals, transportation and entertainment which he/she could not have incurred during normal work hours as well as routinely upgrading hotel rooms to larger multi room suites. During the employee’s interview, the employee admitted to Jerry that he routinely took his spouse and child on his international travel and expensed all of their travel expenses they incurred as his and submitted them for reimbursement. The subject employee paid back all of the expenses inappropriately submitted as his/hers and a disciplinary letter was placed in his/her personnel file. The manager(s) responsible for reviewing and approving the subject’s expense reports were admonished for automatically approving expense reports upon receipt without reviewing them for accuracy.
Misuse of Marketing Gift Cards
Regional CFO of a technology company received information that a marketing manager was corruptly using his position for personal gain, Jerry Bamel led an investigation which determined that the marketing manager gave corporately purchased gift cards which were to be distributed to attendees at marketing events instead to his wife who then used them to make personal purchases of handbags and other items. Subsequent investigation determined that the manager also owned a marketing promotional product company he used to create large orders for promotional items to be distributed with the company’s logo at marketing events and then approved those invoices upon receipt; however, those products were never delivered for distribution at marketing events and the manager kept those funds. The manager was terminated.
"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.
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SunHawk Consulting is a team of highly skilled and experienced subject matter experts with substantial backgrounds in:
* Healthcare compliance, coding education, audit services, evaluation and design of compliance programs, review and monitoring of CIAs and IROs, compliance support, HIPAA compliance, physical security assessment, and
* Corporate fraud, corporate investigations, forensic accounting, mergers regulatory due diligence, acquisitions regulatory due diligence, interim investigations support, fractional investigations support.