Overview

Sarah is an experienced former federal prosecutor and a member of the firm’s White-Collar Criminal Practice, Internal Investigations & Government Enforcement group. She represents corporations and individuals in government investigations and prosecutions of alleged violations of the anti-fraud, procurement, FCPA, health care, sanctions, export control, securities, commodities and criminal tax laws.  From her many years as a federal prosecutor, Sarah has extensive experience in every phase of a federal criminal case – from investigation to jury trials to appeals.

As a former federal prosecutor, Sarah offers her clients valuable insight into how prosecutors and law enforcement agents think, investigate and try cases. With her firsthand knowledge, she vigorously advocates for her client’s interests -- with the goal of persuading law enforcement agencies to decline to pursue criminal charges or other enforcement actions. Because Sarah’s goal is to resolve government investigations without charges or adverse publicity, many of her most important successes for her clients are not publicized.  Sarah is also ready, willing and able to take a federal criminal case to trial where appropriate.

Additionally, Sarah regularly leads sensitive corporate internal investigations into allegations including financial fraud, FCPA violations, export control violations, narcotics in a corporate setting, #MeToo sexual harassment and whistleblower retaliation. She is frequently sought out by clients for her skills in civil litigation, including False Claims Act matters and high-stakes and emergency matters, such as TROs and preliminary injunctions.

Prior to joining Thompson Hine, Sarah served for seven years with the U.S. Department of Justice, Criminal Division, Fraud Section as a white-collar crime prosecutor. In the Securities and Financial Fraud Unit (now known as the Market Integrity and Major Frauds Unit, or MIMF) Sarah investigated and prosecuted some of the most complex financial crimes on Wall Street.  Her primary focus was the investigation and prosecution of major global financial institutions, executives and financial traders. Sarah also served as a prosecutor on the highly successful nationwide Medicare Fraud Strike Force and has significant experience prosecuting criminal health care fraud, money laundering and kickback offenses. As a prosecutor, Sarah obtained dozens of convictions, via trial and plea, in six different federal trial courts across the country. Her trial experience includes having served as first chair in federal criminal trials lasting from several weeks to as long as nearly two months in duration.

Before her government service as a DOJ prosecutor, Sarah worked for international law firms, where she defended individuals and corporations in high-profile federal white-collar criminal matters, parallel civil and regulatory investigations and complex civil litigation. Her practice focused on securities/financial fraud, accounting improprieties and corporate internal investigations.

Prior to her career as a lawyer, Sarah worked on Capitol Hill for a U.S. senator and a U.S. representative. She focused on Finance and Appropriations Committee matters.

Experience

Examples of Sarah’s experience include:

In Private Practice

Corporate and Financial Fraud

  • Represented a major U.S. company’s former CFO in a criminal investigation, parallel civil and regulatory investigations, and numerous civil litigations filed in the Southern District of New York related to securities and accounting fraud. No charges were brought or civil liability found for the client.

  • Represented a former financial controller of a major U.S. company in a U.S. Attorney’s Office for the Southern District of New York criminal case and parallel SEC investigation. Obtained a non-prosecution agreement for the client.

  • Represented a large U.S. defense contractor in a criminal investigation, internal investigation and civil False Claims Act litigation related to whistleblower allegations of sales of defective combat hardware to the U.S. military. No criminal charges were brought against the client.

  • Represented a former board member in a corporate internal investigation and criminal investigation related to the bankruptcy of a major U.S. company. No criminal charges were brought against the client.

  • Part of a team representing a defendant in a high-profile accounting industry criminal case brought by the U.S. Attorney’s Office for the Southern District of New York.

  • Represented an individual in a criminal wire fraud case brought by the U.S. Attorney’s Office for the Southern District of New York. No criminal charges were brought against the client.

  • Represented an individual in an international investment scheme investigation by the U.S. Attorney’s Office for the District of Maryland.

Health Care Fraud

  • Represented a company in connection with an HHS, Office of Inspector General whistleblower complaint related to alleged violations of the federal Anti-Kickback Statute in the acquisition of a pharmacy. No claims or charges were brought against the client.

  • Represented a pharmaceutical company that was a victim in a federal criminal fraud case in connection with seeking restitution.

  • Represented a pharmacy in connection with a DOJ and HHS, Office of Inspector General criminal investigation into patient kickbacks and billing fraud. Also represented the company with respect to review of corporate contracts and HIPAA compliance.

  • Represented a medical services company with respect to a criminal investigation, grand jury subpoena and HIPAA compliance matters. Convinced law enforcement agency to withdraw grand jury subpoena.

  • Represented a medical doctor in a DOJ and HHS, Office of Inspector General investigation into alleged kickbacks and violations of the Stark Law. No claims or charges were brought against the client.

  • Represented a medical sales representative in a Maryland Attorney General investigation into kickbacks related to alleged over-prescribing of opioids. No claims or charges were brought against the client.

Foreign Corrupt Practices Act (FCPA)

  • Represented a defendant in FCPA and related offenses prosecution brought by the U.S. Department of Justice, Criminal Division Fraud Section, FCPA Unit and the U.S. Attorney’s Office for the Southern District of Ohio.

  • Led an internal investigation for an international logistics company regarding possible FCPA and Mexican anti-corruption violations.

Government Contract and Grant Fraud

  • Represented a company in a multi-year criminal government contract fraud investigation by the U.S. Attorney’s Office for the Eastern District of Virginia. No charges were brought against the client.

  • Represented a chief operating officer in a criminal government contract fraud investigation by the U.S. Attorney’s Office for the District of Maryland and the FBI. No charges were brought against the client.

  • Represented a company in a criminal government grant fraud investigation by the U.S. Attorney’s Office for the Southern District of Ohio. No charges were brought against the client.

Tax Fraud and Tax Evasion

  • Represented an individual in a tax fraud investigation by the U.S. Attorney’s Office for the District of Maryland and the IRS, Criminal Investigation.

  • Represented an individual in a tax evasion investigation by the U.S. Attorney’s Office for the Western District of Washington and the IRS, Criminal Investigation.

Internal Investigations

  • Led an internal investigation for an international motor vehicle company regarding narcotics smuggling in a corporate environment. Interfaced with DOJ and investigative agencies in the context of a related federal criminal prosecution. No charges were brought against the client.

  • Led an internal investigation for an international logistics company regarding possible FCPA and Mexican anti-corruption violations.

  • Led an internal investigation for a transportation company in connection with possible OFAC violations regarding a Specially Designated National (SDN).

  • Led an internal investigation for a major charitable foundation in regard to #MeToo sexual harassment allegations spanning a 10-year period.

  • Represented a mineral company in an internal investigation into possible whistleblower retaliation and a hostile work environment.

  • Represented the board of directors of an industrial supply company in an internal investigation into a safety incident at an energy facility.

  • Represented a large U.S. defense contractor in a criminal investigation, internal investigation and civil False Claims Act litigation related to whistleblower allegations involving sales of defective combat hardware to the U.S. military.

  • Represented a major U.S. corporation’s Special Committee in an internal investigation related to accounting improprieties following the corporation’s bankruptcy.

  • Represented a former high-level executive in a corporate internal investigation and criminal investigation related to the bankruptcy of a major U.S. company.

OFAC / Sanctions / Export Control / Compliance

  • Represented an international logistics company in an investigation by U.S. Attorney’s Office for the District of Columbia and the FBI in regards to alleged OFAC and other violations regarding transactions with North Korea.

  • Represented a Fintech company with respect to OFAC/sanctions compliance and other corporate compliance matters.

  • Represented clients in government-facing matters regarding alleged OFAC, export control and economic sanctions violations. Client counseling, subpoena response and internal investigations relating to same.

False Claims Act

  • Represented a large U.S. defense contractor in a criminal investigation, internal investigation and civil False Claims Act litigation related to whistleblower allegations of sales of defective combat hardware to the U.S. military. No criminal charges were brought against the client.

  • Represented a company in civil False Claims Act investigation by the U.S. Attorney’s Office for the District of Columbia, and related parallel proceedings.

Securities and Civil Litigation

  • Represented a major U.S. company’s former CFO in a criminal investigation, parallel civil and regulatory investigations, and numerous SDNY civil litigations related to securities, accounting and ERISA fraud. No charges were brought or civil liability found for the client.

  • Represented a former financial controller of a major U.S. company in a SDNY criminal investigation and parallel SEC investigation. Obtained a non-prosecution agreement for the client.

  • Represent a wide variety of companies and individuals in high-stakes and emergency civil litigation in federal and state courts. Seek Temporary Restraining Orders (TROs) and Preliminary Injunctions for clients.

Trials

  • Represented a witness in a high-profile criminal trial involving alleged unlawful surveillance and conspiracy.

Pro Bono

  • Represented pro bono a military service member who was seriously injured in the September 11th attack on the Pentagon before the September 11th Victim Compensation Fund. Obtained a large financial settlement for the client.

  • Provided award-winning pro bono representation for a D.C. resident convicted of felony murder and sentenced to 25 years in federal prison. Successfully represented the client in a constitutional post-conviction challenge to his sentence, securing his release.


At the U.S. Department of Justice

  • Investigated and prosecuted a broad range of complex federal white-collar offenses, including wire fraud, commodities and securities fraud, health care fraud, money laundering, spoofing, bank fraud, bankruptcy fraud, conspiracies, major fraud against the government, kickbacks, advance fee schemes, bribery and gratuities.

  • Served on the DOJ team that prosecuted and obtained corporate parent-level guilty pleas and more than $2.5 billion in criminal fines from five major global banks in the Foreign Exchange investigation.

  • Served as the lead line prosecutor in the investigation of multiple global banks for wire fraud, commodities fraud and spoofing.

  • Served as the lead line prosecutor in the investigation of a former Wall Street trader who pleaded guilty to a conspiracy to commit wire fraud, spoofing and market manipulation.

  • Served as the lead Fraud Section prosecutor in a $77 million health care fraud, kickback and money laundering prosecution; obtained 13 convictions and substantial criminal sentences of up to 15 years’ incarceration and approximately $50 million in restitution orders.

  • First and second chaired federal jury trials in several different federal courts; all trials resulted in convictions and lasted three to seven weeks.

  • Obtained dozens of convictions via trial and plea in six different federal districts: Brooklyn, New York; Connecticut; Phoenix, Arizona; Miami, Florida; Houston, Texas and Baton Rouge, Louisiana.
Publications

Sarah is frequently quoted in the media on white-collar crime issues. Additionally, she is published regularly in media outlets including the New York Law Journal; the American Bar Association’s Criminal Justice Magazine; The National Association of Criminal Defense Lawyers (NACDL) magazine, The Champion; Law360; Bloomberg Law; Pratt’s Government Contracting Law Report; and Healthcare Risk Management.

Presentations
  • Panel Member, "FBI and Other Raids: Guidance for Counsel," Strafford Webinar, November 2019
  • Moderator, “Negotiating False Claims Act Settlements and Mediation,” American Bar Association, National Institute on Health Care Fraud, May 2019
  • Panel member, “Regulations, Compliance and Responsibilities for Government Contractors,” Government Contracting Symposium, University of Dayton, January 2019
  • Presenter, “Best Practices for Company Investigations in the Era of #MeToo,” Thompson Hine’s Annual Labor & Employment Seminar, October 2018
  • Panel member, “#MeToo Allegations: Are You Prepared for Complaints Against Your Senior Executives?” Thompson Hine Premier Client Summit, May 2018
  • Panel member, “Current Issues in Government Investigations,” Federal Bar Association, District of Columbia Chapter, April 2018
Distinctions
  • Selected for inclusion in Washington, D.C. Super Lawyers, 2019 and 2020
  • Panel Member, Criminal Justice Act (CJA) Felony Panel for the U.S. District Court for the District of Maryland, 2018-present
  • Member, Law360’s White Collar Editorial Advisory Board, 2018
  • Nominee, Attorney General’s Award for Fraud Prevention, 2013
Professional and Civic

Professional Associations

  • Barrister, the Edward Bennett Williams American Inn of Court
  • Barrister, the William B. Bryant American Inn of Court
  • Public Relations Team, Women’s White Collar Defense Association

Community Activities

  • SMYAL (Supporting and Mentoring Youth Advocates and Leaders)
News