Sarah Walters is a partner in Ropes & Gray’s global litigation and enforcement practice group. A former federal prosecutor and experienced trial lawyer, she is highly recognized by Chambers USA for her “sophisticated representation” of health care and financial services clients in the white-collar criminal defense, regulatory enforcement, compliance counseling, and complex civil litigation space.
Valued for her thoughtful approach and firsthand knowledge of the prosecutorial mindset, Sarah conducts independent and sensitive investigations on behalf of audit and other board committees and counsels companies and individuals across industries on investigations and other civil and criminal matters involving:
- High-profile allegations of misconduct and other serious wrongdoing;
- Financial fraud, including honest services or commercial fraud, accounting and disclosure issues, and public corruption;
- Health care fraud, including alleged violations of the False Claims Act (“FCA”) and the federal Anti-Kickback Statute (“AKS”);
- Compliance with the Foreign Corrupt Practices Act (“FCPA”) and anti-bribery laws; and
- The design, implementation, and audit of compliance programs consistent with the U.S. Department of Justice’s (“DOJ”), and other relevant guidance.
Sarah served 10 years as an Assistant United States Attorney in the U.S. Attorney’s Office for the District of Massachusetts, holding the position of Chief of the Economic Crimes Unit during the last four years of her tenure. She successfully led investigations and numerous jury trials covering a broad spectrum of financial crimes and notably, served as a liaison to President Obama’s Financial Fraud Enforcement Task Force.
Widely recognized as a thought leader, Sarah regularly presents at major industry-leading conferences and is an active member of the Women’s White Collar Defense Association. She maintains a robust pro bono practice and is a member of the Criminal Justice Act panel for the U.S. District Court for the District of Massachusetts.
Experience
Government, Internal and Sensitive Investigations
- Conducted an in-depth sensitive investigation on behalf of an elite university into an athletic team in connection with allegations of misconduct in violation of NCAA rules.
- Represented an executive of a major defense contractor in an FCA investigation.
- Represented an executive of a major publicly traded company in an FCPA investigation.*
- Represented major health care systems, e-brokers, and telehealth companies in FCA, AKS, and controlled substance diversion investigations.*
- Represented the Audit Committee of a major publicly traded company in an investigation concerning alleged accounting fraud and handled related inquiries by the Securities and Exchange Commission (“SEC”).*
- Represented the Audit Committee of a major publicly traded company in an investigation into sensitive personnel matters.*
- Represented a major electronic health record provider in an FCA investigation, leading to a very favorable settlement.*
- Successfully advocated on behalf of a major hospital system to convince prosecutors to decline to intervene in a qui tam litigation, which was ultimately dismissed.*
- Represented partners and employees of a major U.S. accounting firm in connection with a criminal investigation and prosecution arising out of alleged investment fraud at a prominent hedge fund.*
- Represented a high-profile witness in a Hobbs Act extortion trial.*
Compliance
- Conducted a compliance review for an EU-based multinational auto parts manufacturer.*
- Conducted a risk assessment and compliance review for a major U.S. accounting firm.*
- Advised a major U.S. public accounting firm on FCPA and other compliance matters.*
Trial and Appellate
- Argued and won a decision regarding the proper award of attorneys’ fees under the FCA, an issue of first impression in the circuit (First Circuit).*
- Served as trial counsel for the plaintiff, a major accounting firm, in litigation in Delaware Chancery Court, resulting in a significant spoliation order against the defendant (Delaware Chancery Court).*
- Served as trial counsel for the plaintiff, a leading provider of de-identified electronic health records (Real World Data), in a breach of contract action; won jury verdict for breach of contract and prevailed in a post-trial injunction proceeding (District of Massachusetts).*
- Served as trial counsel for the defendant, the leading maker of office headsets, in a Sherman 1, Sherman 2 and Clayton Act antitrust action between direct competitors; trial team was brought in to try the case shortly before trial and, despite an adverse inference instruction on spoliation that was ordered prior to the firm’s involvement, the jury deliberated for an hour before returning a complete defense verdict (District of Delaware).*
- Tried numerous complex financial fraud cases before juries as a prosecutor, including as lead counsel in securities fraud, tax fraud and investment fraud cases (District of Massachusetts).*
- Obtained full acquittal after trial of the general counsel of a start-up company charged with securities fraud arising out of that company’s collaboration with a high-profile internet service provider (Eastern District of Virginia).*
*Experience prior to joining Ropes & Gray