Program on Corporate Compliance and Enforcement

PCCE Senior Fellows

Thomas C. Baxter, Jr. headshot

Thomas C. Baxter, Jr.

Thomas C. Baxter, Jr. has served as a financial services lawyer for more than 40 years. He retired from Sullivan & Cromwell at the end of December 2020 after working for more than four years in the position as Of Counsel. Before joining Sullivan & Cromwell, Baxter served as a Federal Reserve lawyer for more than 36 years. From March 1995 until he retired from the Federal Reserve Bank of New York, he served as the Bank's General Counsel and Executive Vice President. He was also the Deputy General Counsel of the Federal Open Market Committee, the Federal Reserve's monetary policy agency. Baxter is widely recognized for his deep knowledge of the regulatory, payments system, and enforcement spaces. 

During the financial crisis of 2008, he served as one of the primary planners of the many lending programs offered by the Federal Reserve Bank of New York. He also spearheaded the Reserve's efforts following the September 11th terrorist attacks to provide liquidity and support to financial markets.

Baxter is active in the legal community as a member of the American Bar Association and the International Law Association. He has received several awards for his work in the legal community. In 2009, he was named one of The American Lawyer's "Dealmakers of the Year" and received an award from the Association of Corporate Counsel for an innovative educational program about legal ethics. He is also a member of P.R.I.M.E. Finance Foundation's Panel of Experts. He serves as Vice Chairman of the Committee on International Monetary Law of the International Law Association, and is a Co-Reporter of a Study Group of the Uniform Law Foundation, looking at whether there needs to be a statute addressing special deposits.

Mark Carawan headshot

Mark Carawan 

Mark Carawan has a wealth of experience in governance, regulatory compliance and ethics, and conduct and culture matters globally. From the late 1980s to 2002, as a partner at Andersen and then Deloitte, he led and managed multi-disciplinary financial sector and individual institution restructuring, resolution, and privatisation programs on behalf of ministries of finance, central banks, regulatory authorities, and restructuring agencies. In developed and developing economies in Asia, Africa, Europe, and Latin America, these programs introduced new legislation, regulation, governance, and risk management requirements, often in response to financial sector crises. In many of these jurisdictions, Mark worked with the International Monetary Fund and the World Bank.

Most recently, from 2017 to 2020, Carawan served as Citigroup’s Chief Compliance Officer with responsibilities spanning Citi’s financial crime, regulatory compliance, conduct, and ethics programs. He was previously the Chief Internal Auditor for Citigroup, and prior to that, the Barclays Group’s Chief Internal Auditor. His earlier consulting career included roles such as Managing Partner responsible for Enterprise-Wide Assurance to wholesale financial services institutions at Deloitte (UK), and Managing Partner for Andersen’s global Privatisation and Emerging Markets practice, overseeing mandates and consulting activities in over fifty non-OECD countries.

Carawan began his professional career within the London Office of Andersen’s accountancy practice before moving into consultancy after qualification as a Chartered Accountant. He received his B.A. from Rutgers University and a Ph.D. from St. Andrews University in the UK. He has received the CFIIA from the Chartered Institute of Internal Auditors, and the CIA and QIAL qualifications from the global Institute of Internal Auditors where he has been a member of the global Board of Directors since 2016, having previously served as Chairman of the IIA’s Financial Services Guidance Committee. Mark has been a member of the Board of Directors of the Greater New York Council of the Boy Scouts of America since 2017 and a member of PCCE’s Advisory Board from 2019 to 2020.

Headshot of Timothy Lindon

Timothy J. Lindon 

Timothy J. Lindon has broad experience in legal and compliance leadership roles in the US, Europe, and, Asia.  From 2011 to 2016, Lindon was Vice President and Chief Compliance Officer of Philip Morris International, based in Switzerland, where he led the global compliance program. Lindon was instrumental in changing employee’s perception and overcoming their resistance to compliance by integrating human psychology, behavioral economics, and systems engineering into the compliance program.  During 2017, Lindon was head of Business Practices, Reduced-Risk Products, where he developed and implemented policies and processes to address business transformation and disruptive technologies. Previously, Lindon served in senior corporate and litigation legal positons for Philip Morris, including as Vice President and Associate General Counsel for the Latin America and Canada Region; Associate General Counsel, Litigation; and Regional Counsel for the Asia and Japan Regions, based in Hong Kong.

Earlier, Lindon was Vice President and General Counsel for MPC & Associates, a real estate development firm owned by Arnold & Porter in Washington DC, starting as an Associate with Arnold & Porter. Lindon clerked for The Honorable John D. Butzner, Jr., in the US Court of Appeals for the Fourth Circuit.  Lindon has been a member of PCCE’s Board of Advisors since 2015, a Corporate Fellow, and Chair of the Behavioral Ethics Working Group, for Ethics Resource Center in Washington, DC.  He holds a JD from New York University School of Law, where he was a Root-Tilden Public Service Scholar, and a BA from Tufts University.

Headshot of Kathryn Reimann

Kathryn S. Reimann 

Kathryn S. Reimann is an executive, consultant and educator who has held multiple global compliance and ethics leadership roles, including leading the global programs at Citibank and American Express. Reimann served on the PCCE Advisory Board for four years, and serves as an Adviser to the American Law Institute's Principles of the Law: Compliance, Risk Management and Enforcement. She is an active thought leader in industry and not-for-profit organizations.  She has focused on compliance and ethics throughout her career, and continues to lecture for organizations including the Practicing Law Institute, American Bankers Association and various law schools. She is an Adjunct Professor of Law at NYU School of Law. Early in her career, Reimann was a litigation associate at Curtis, Mallet, Prevost, Colt & Mosle, which she joined after clerking for Justice Stewart G. Pollock of the New Jersey Supreme Court. She earned her undergraduate degree at from the Woodrow Wilson School of Public & International Affairs at Princeton University, and received her J.D. from NYU School of Law, where she was an editor of the Annual Survey of American Law.

Jonathan Rusch Headshot

Jonathan Rusch 

Jonathan J. Rusch is a lawyer and consultant on compliance issues, Adjunct Professor at Georgetown University Law Center, editor of Dipping Through Geometries (a blog focusing on law and compliance issues), and retired Senior Vice President and Head of Anti-Bribery & Corruption Governance at Wells Fargo.  Previously, Rusch was a federal prosecutor for 26 years in the Fraud Section of the U.S. Department of Justice’s Criminal Division, most recently as Deputy Chief for Strategy and Policy.  He also served as Director of the U.S. Department of the Treasury’s Office of Financial Enforcement, Counsel to the President’s Commission on Organized Crime, and an associate with a Washington, D.C. law firm.  His awards include the Attorney General’s Distinguished Service Award, the Attorney General’s Award for Fraud Prevention, the United Kingdom Serious and Organized Crime Agency Director General’s Commendation, and the Georgetown University Vicennial Medal.

Charles V. Senatore headshot

Charles V. Senatore 

Charles V. "Chuck" Senatore is a board member and advisor to companies with particular emphasis on compliance, risk and regulatory affairs. His current focus is on companies engaged in Fintech/Regtech, artificial intelligence and cryptocurrency businesses.

Senatore also founded the Boston Regtech Meetup, and is a member of the Massachusetts Secretary of State's Fintech Advisory Working Group.

He teaches Compliance and Regulatory Strategy at the University of Chicago Law School, has guest lectured at Harvard Law School, NYU Law School and Northeastern University, and is a frequent speaker and contributor at industry and academic forums.

Most recently, Senatore was Head of Risk Oversight for Fidelity Investments' Devonshire Investors unit, focusing on compliance, risk and regulatory affairs for Fidelity's private equity, venture and strategic investing efforts.

He also has led the global compliance programs for Fidelity and Merrill Lynch, was the SEC's Southeast Regional Director, and was an Assistant U.S. Attorney and Chief of the Public Corruption Section in the Southern District of Florida.

Senatore received a Bachelor of Arts in Economics from Williams College and earned a J.D. from the University of Chicago Law School.

Headshot of Edward Stroz

Edward M. Stroz

Edward Stroz is an entrepreneur and cyber risk consultant. He has over twenty years of experience from both the private and governmental sectors in risk management arising from technologies and cyber security. Building on a 16 year career in the FBI, Stroz started one of the first cyber forensics firms in 2000, which became known as Stroz Friedberg, LLC. He sold his firm to Aon plc in 2016. While overseeing the firm, Stroz served clients across a broad range of industries including by providing expert testimony in litigation and to regulatory authorities, as well as advising corporate boards and professional firms on cyber risks and incident response. He has also assisted companies subject to regulatory monitorships.

Stroz formed the computer crime squad in the FBI’s New York office in 1996. He drew upon extensive experience in hundreds of white-collar crime investigations including the conviction at trial of the first “financial kingpin” prosecution as well as operating an undercover stock brokerage firm and an internet gambling site.  

He currently sits on the boards of directors of the Citizens Crime Commission of New York, and The Soufan Center, a not-for-profit organization that specializes in research on domestic and international terrorism threats. Stroz has a special expertise in applying behavioral science insights for managing insider risk for institutional clients.

He is a Trustee Fellow of Fordham University, and serves as an advisor to the Center on Law and Information Policy at Fordham Law School. He is a Certified Public Accountant (CPA), former bank examiner, a member of the Association of Former Intelligence Officers, and the National Association of Corporate Directors. He served on the NY State Courts System E-Discovery Working Group and has testified for defense counsel and as an expert for the U.S. Attorney’s Office for the SDNY. 

Maria vullo

Maria Vullo

Maria T. Vullo ’87 is the Principal of Vullo Advisory Services, PLLC, a financial services strategic advisory firm. Ms. Vullo previously served as the superintendent of the New York State Department of Financial Services (NYDFS). In that role, Vullo was responsible for the regulation and supervision of New York’s financial services industry, including New York State chartered banks, branches of foreign banks, and insurance companies and agents licensed to do business in New York.  During Vullo’s tenure as NYDFS Superintendent, she issued a nation-leading cybersecurity regulation applicable to all NYDFS regulated institutions; issued a first-in-the-nation transaction-monitoring regulation; resolved significant enforcement actions regarding violations of the Bank Secrecy Act, and anti-money laundering, sanctions and foreign exchange laws.

Vullo is the recipient of numerous awards, including the 2018 Excellence in Consumer Advocacy Award by the NAIC Consumer Representatives, the 2018 Insurance Woman of the Year Award by the Association of Professional Insurance Women, and the 2017 Mario Cuomo Public Service Award by the National Italian American Foundation.  Vullo also was twice nominated by the New York State Commission on Judicial Nomination to be an associate judge of the New York State Court of Appeals.

Vullo has extensive experience in the private sector as well.  Prior to her government service, Vullo was a partner in the litigation department at Paul, Weiss, Rifkind, Wharton & Garrison LLP, where she litigated civil, criminal and regulatory matters, and led significant pro bono litigation.  Vullo holds a JD from New York University School of Law, an MPA from NYU Wagner Graduate School of Public Service, and a BA and an honorary PhD from the College of Mount Saint Vincent.