Jonathan J. Rusch is the Principal of DTG Risk & Compliance LLC. Mr. Rusch has an unsurpassed breadth of expertise and experience in corporate risk and compliance issues, including legal and compliance expertise with criminal, civil, and regulatory offenses in the United States and other jurisdictions that are applicable to the financial services sector:
- From 2015 to 2018, Mr. Rusch was Senior Vice President and Head of Anti-Bribery & Corruption Governance with Wells Fargo. In that capacity, he built and implemented a world-class global anti-bribery and corruption (ABC) governance program for the company. That program included revisions of the corporate ABC Policy to ensure effective first- and second-line oversight and implementation of internal controls; establishment of an annual enterprise-wide online ABC Inherent Risk Assessment; creation and implementation of ABC country risk ratings; monthly enterprise-wide reporting on ABC-related trends and developments; and a 500+ percent increase in delivery of corporate-wide ABC-related training to appropriate executives, managers, and other team members, as well as delivery of biweekly training on bribery and corruption trends by experts to key executives and managers.
- From 1988 to 2015, Mr. Rusch was a federal prosecutor with the United States Department of Justice, in the Fraud Section of the Criminal Division, eventually serving as Deputy Chief for Strategy and Policy. During his tenure, he rose through the ranks of line prosecutors to become the lead prosecutor of complex fraud, public-corruption, and money-laundering cases, including successful prosecutions of former Members of the United States House of Representatives, a former United States Treasurer, a former Sergeant at Arms of the United States House of Representatives, and ringleaders of international mass-marketing and commodities fraud schemes. He also coordinated multiple multinational law enforcement operations against fraud schemes, chaired the national-level Interagency Bank Fraud Working Group and Securities and Commodities Fraud Working Group, created the Department’s Internet Fraud Initiative, represented the United States as a member of the United Nations Office on Drugs and Crime’s Core Group of Experts on Identity-Related Crime; and served as Executive Director of the Department’s Disaster Fraud Task Force.
- Previously, Mr. Rusch was the first Director of the Office of Financial Enforcement at the United States Department of the Treasury, where he conducted the Department’s Bank Secrecy Act civil-enforcement program; Counsel to the President’s Commission on Organized Crime, where he drafted model money-laundering legislation that led to the enactment of the United States’ federal money laundering offenses (18 U.S.C. §§ 1956 and 1957); and an associate with the law firm of Cleary Gottlieb Steen & Hamilton in Washington, D.C.
Mr. Rusch is an active member of the District of Columbia Bar, as well as a member of the bar of the United States Supreme Court and various United States Courts of Appeals. He also has extensive experience in teaching and lecturing. He currently is Adjunct Professor at Georgetown University Law Center, where he teaches both Corporate Compliance in the Financial Sector: Anti-Money Laundering and Counter-Terrorism Financing and Questioning Witnesses; Adjunct Professor at American University Washington College of Law, where he teaches Anti-Corruption Law; and a Senior Fellow in the Program on Corporate Compliance and Enforcement at New York University Law School. He also has been Lecturer in Law at the University of Virginia Law School and the China University of Political Science and Law, where he taught Cybercrime. He is a frequent speaker on legal and compliance issues at bar and compliance conferences, and edits a blog on law, compliance, and ethics issues, Dipping Through Geometries.