- Investigation experience in 70+ countries
- ACFE Hall of Fame Recipient
- Founder of the Microsoft’s Financial Integrity Unit
- Former Federal agent and criminal investigator
- Certified Fraud Examiner (CFE)
- Certified Compliance and Ethics Professional (CCEP)
- Author of 6 books on Fraud Investigation, Foreign Corrupt Practices Act, Corporate Compliance Programs, Credit Card Fraud, Identity Theft
- Honorary Doctor of Laws, Utica College
- Cressey Award Recipient, Association of Certified Fraud Examiners
Martin is a Managing Director with SunHawk Consulting LLC. He has spent a lifetime detecting, investigating, and preventing fraud and corruption in various leadership roles in law enforcement, consulting, and the corporate sector. Martin’s work on behalf of corporate management and boards includes conducting internal investigations alleging fraud, corruption, Foreign Corrupt Practices Act violations, conflicts of interest, whistleblower retaliation, and other employee and vendor misconduct. Martin’s work also includes developing, assessing, and enhancing corporate compliance and ethics programs including internal investigative and anti-bribery compliance programs, as well as performing fraud risk assessments. He has conducted and managed complex and high-risk investigations and engagements in more than 70 countries.
Prior to his role at SunHawk, Martin served as a Managing Director in the Risk and Financial Advisory Practice at Deloitte Financial Advisory Services LLP where he partnered with clients to help them navigate disruption, resolve business controversy, and build resilient organizations. He previously worked as a Managing Director in the Global Investigations and Compliance Practice at Navigant Consulting and then as Executive Vice President of the Anti-Bribery and Litigation Support Practices at IPSA International.
In 2002, Martin founded Microsoft Corporation’s Financial Integrity Unit, a highly acclaimed global business conduct investigations and compliance program that continues to serve as a model for other companies. He led that program until 2011. Martin is also a former federal agent having served as a United States Postal Inspector for over 22 years in a variety of investigative and management assignments across the United States. His last government role was as the Inspector in Charge of the Phoenix, AZ Field Office where he oversaw law enforcement operations for the Postal Inspection Service in Arizona, New Mexico, and Nevada. Earlier in his career, he was a criminal investigator with the San Francisco District Attorney’s Office where he investigated economic crime, official corruption, and bribery.
Martin is both a Certified Fraud Examiner and a Certified Compliance and Ethics Professional. He is also a licensed Private Investigator in Arizona. He is the author of six books on topics such as fraud investigation and prevention, the Foreign Corrupt Practices Act, corporate compliance programs, credit card fraud and identity theft, and is a frequent speaker on these subjects. Martin is the former Chair and now Advisor Emeritus of the Board of Advisors for the Economic Crime and Cybersecurity Institute (ECCI) at Utica College. He served on the ECCI Board of Advisors since 2003 and as Chair of the Board for ten years. In 2008, he was appointed to serve on the Washington State Executive Ethics Board with his term ending in 2011.
Since 2007, Martin has been a faculty member for the Society of Corporate Compliance & Ethics’ Basic Academies where he teaches sessions on conflicts of interest, bribery, corruption, and other compliance subjects. Martin is also an adjunct professor at the Sandra Day O’Connor College of Law at Arizona State University where he teaches courses on conducting internal investigations and the examination of fraud.
Throughout his career, Martin has received numerous awards and recognition from law enforcement, financial institutions, anti-fraud groups and professional organizations. In 2008, he was the recipient of the Cressey Award bestowed annually by the Association of Certified Fraud Examiners for lifetime achievements in the detection and deterrence of fraud. In 2010, Martin received an Honorary Doctor of Laws from Utica College for his leadership on behalf of students and faculty of the college as well as lifetime contributions to fraud prevention and anti-corruption compliance.
Select Engagement Experience
Internal Independent Investigation of a Global Technology Company
Martin led an internal independent investigation of a global technology company under scrutiny by the SEC for accounting irregularities. In addition to the internal investigation, he conducted remediation involving the assessment and improvement of the company’s compliance and internal audit functions.
Internal Investigation on Behalf of a Private Equity Investing Firm
Martin conducted an internal investigation on behalf of a private equity investing firm. The allegation was that an executive had embezzled funds through the submission of phony invoices to vendors. The investigation involved review of disbursement activity and relevant documents and records, a search of the subject’s office, forensic computer analysis, interviews of knowledgeable individuals including the subject, and other related services. Besides the confirmation of the embezzlement, it was discovered that the executive fraudulently submitted significant personal expenses as business expenses. Martin interviewed the subject and obtained admissions on all the relevant issues. Martin also assisted in the preparation of the commercial crime policy claim for recovery of the defrauded proceeds as well as the cost of the investigation.
Compliance Project for a Major Financial Institution
Martin led a compliance project for a major financial institution conducting an end-to-end assessment of the organization’s hotline and other reporting and investigation processes, providing compliance program enhancements and the creation of a remediation roadmap for business conduct improvements.
Identity Theft - Investigation on Behalf of a Law Firm and Its Employees
Martin led an investigation on behalf of a law firm and its employees who were victimized by identity theft. The law firm reached out to Martin because of his subject matter expertise and law enforcement experience investigating identity theft. The investigation determined how the identity theft breach occurred, the extent of the breach, and the individuals involved. SunHawk performed dark web and deep web Internet scans that determined the stolen information came from major data breaches that occurred years earlier. The evidence developed was referred to federal law enforcement resulting in the arrests of members of the identity theft ring responsible for the breach of the law firm and other victims. As a result of the quick response and investigation results, the law firm suffered no financial loss and no further acts of identity theft have occurred.
FCPA and Anti-Corruption Risk Assessment and Audit
Martin led a FCPA and anti-corruption risk assessment and audit of a global retail chain’s operations in Mexico.
Investigation on Behalf of a Transportation Industry Company
Martin Biegelman led an investigation on behalf of a transportation industry company involving the alleged misconduct of an employee in the theft of company-owned goods. The investigation confirmed the theft of inventory and that the subject of the investigation was a manager at the company. Knowing that his direct reports were being interviewed, this manager tried to persuade the employees not to cooperate with SunHawk’s investigators. The investigation also revealed that the manager was sexually harassing his employees and he was terminated. Martin also provided recommended enhancements to the company’s code of conduct and business ethics policy in furtherance of their corporate compliance program.
Representation - Client Targeted by the DOJ in an FCPA Probe
Martin Biegelman and defense counsel represented a client targeted by the DOJ in an FCPA probe. As a result of the investigation performed in defense of the client and demonstrating the lack of supporting evidence of the allegations, no FCPA-related charges were ever filed by the DOJ.
Forensic Investigation on Behalf of an Ultra-high Net Worth Individual
Martin conducted a forensic investigation on behalf of an ultra-high net worth individual whose accountant was suspected of fraudulently diverting funds from the victim’s family office. The investigation confirmed that millions of dollars were embezzled by the accountant with the assistance of an external associate. Other misconduct committed by the accountant was also discovered. As a result of the timely and effective investigation, the accountant and his accomplice returned all but a small amount of the loss to the victim.
Assessment of the Compliance and Ethics Program of a University System
Martin led an assessment of the compliance and ethics program of a university system providing program strengths and opportunities for improvement.
Internal Investigation of a Loan Officer at a U.S. Credit Association
Martin led an internal investigation of a loan officer at a U.S. credit association involved in a long-running, multi-million-dollar loan fraud scheme and conspiracy with loan recipients. The investigation resulted in a criminal referral to federal law enforcement authorities.
Internal Investigation of a U.S. Subsidiary of a Global Manufacturer
Martin led an internal investigation of a U.S. subsidiary of a global manufacturer resulting from whistleblower allegations of financial and other impropriety by corporate executives.
FCPA Compliance Assessment and Internal Control Review
Martin led an FCPA compliance assessment and internal control review for a global oil and gas company.
Ethics Program Evaluation - Major U.S. Municipality
Martin led an ethics program evaluation for a major U.S. municipality. Developed a new and enhanced ethics training curriculum. Conducted training for all 13,000 city employees.
"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."
"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!"
"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.
"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."
"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."
"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!"
"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."
“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.”
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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.