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Juliette Gust


Corporate Investigations, Internal Audit, Certified Fraud Examiner



Career Highlights


  • Certified Fraud Examiner since 2007
  • Has led more than 2,000 investigations across 75 countries, and responded to more than 10,000 hotline reports
  • Founder of the Ethics Suite digital whistleblower hotline and case management system
  • Project Manager and core member of Starwood Hotels & Resorts Worldwide Anti-Corruption Compliance Program
  • Winner of Starwood Hotels & Resorts Worldwide Finance Partner in Excellence award
  • Member of PwC’s core regulatory team focused on regulatory reform and the impact of Dodd-Frank legislation; appointed Project Manager for PwC’s Dodd Frank Derivatives Services Planning Group
  • PwC’s Chairman’s Award winner 2008, 2009, 2010
  • Winner of the Wall Street Journal Award for Excellence in Accounting

Juliette is a Certified Fraud Examiner and a Director at SunHawk Consulting, LLC, with over 20 years of experience in building out global Ethics and Compliance Programs in the Financial Services, Manufacturing, Hospitality, Gaming, and Retail industries. Ms. Gust currently assists global clients with internal investigations and ethics and compliance matters. She is also the founder and President of Ethics Suite, a company that helps businesses identify, investigate and remedy alleged misconduct, fraud, or theft at their organization by providing a comprehensive and modern solution for internal whistleblower reporting and case management.

As a former Director of Internal Audit at Starwood Hotels & Resorts Worldwide, Ms. Gust developed and led the Global Fraud & Investigations team for the company, which employed over 180,000 employees in more than 100 countries at the time. Ms. Gust also served as the Project Manager and core member of the company’s Anti-Corruption Compliance Program, leading the development of a best-in-class global anti-corruption risk assessment and audit program.

Throughout her career, Ms. Gust has personally conducted or managed more than 2,000 investigations spanning 75 countries and advised on more than 10,000 employee ethics line reports. 

Ms. Gust served previously as a subject matter specialist within PwC’s Regulatory, Forensics, and Hospitality practices, where she led investigations and engagements in the U.S. and abroad on a variety of matters including anti-money laundering, corruption and bribery, embezzlement, and financial statement fraud – presenting her findings and recommendations to executive boards, federal and state regulatory agencies and audit committees.

Select Engagement Experience

"Ghost Employees" Investigation
Juliette conducted an investigation involving “ghost employees” added to a company’s payroll by a department supervisor. The supervisor was responsible for the department’s timekeeping and, over a three-year period, falsified time records for 33 nonexistent employees, resulting in a $3.5M loss to the company. Juliette successfully concluded the investigation with a near-complete return of losses from the company’s insurers after it conducted an independent audit of the investigation. In addition, the investigation resulted in a criminal referral to federal law enforcement authorities.
Financial Fraud Investigation in Mexico
Juliette participated in an investigation in Mexico that resulted in the identification of a financial statement fraud of more than $100M. The investigation identified improper asset valuations, concealed liabilities and expenses, and fictitious revenues.
Financial Investigation in South America
As a Certified Fraud Examiner Juliette led an investigation in South America that uncovered a $1.5M embezzlement led by the finance teams in two separate businesses owned by the same parent company. These teams colluded to embezzle from one business while using the other business to hide the losses in an extensive intercompany scheme.
Purchasing Department Investigation in Europe
Juliette investigated a purchasing department allegation in Europe, resulting in the identification of a kickback scheme involving the head of the purchasing department and various suppliers.
Caribbean Corporate Misconduct Investigation
Juliette led an investigation in the Caribbean that uncovered misconduct by a number of the company’s employees, managers, and senior leaders. The schemes included various conflicts of interest, corrupt payments, vendor kickbacks, falsified timekeeping, expense fraud, and fictitious vendors.


"SunHawk demonstrated a commendable commitment to precision and compliance throughout our engagement. Their expertise in navigating complex healthcare regulations was evident, providing us with a thorough and insightful audit. We required assistance with a complex billing audit that required statistical analysis. As a smaller healthcare system, SunHawk provided us a level of audit expertise that we are not able to staff in-house. The team’s responsiveness and industry knowledge make them a valuable partner for healthcare organizations seeking rigorous and reliable auditing services."

Sara Coverstone

Chief Compliance & Privacy Officer
Northern Arizona Healthcare

"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
Garnet Health

"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!"

Natasha Cogdill

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."

Gerry Roy

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!"

Nancy Lipman

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."

Michelle Missal

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.”

Zachary Fain

Chief Technology Officer (CTO)
Signature Performance

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