Sarah M. Hall
Washington, D.C. Chair, Spotlight on Women
Sarah is senior counsel in the firm’s Business Litigation practice and a member of the White Collar Criminal Practice, Internal Investigations & Government Enforcement group. An experienced former federal prosecutor, she represents corporations and individuals in government investigations and prosecutions of alleged violations of the anti-fraud, procurement, FCPA, criminal tax, health care, securities and commodities laws.
Sarah has deep experience in every phase of a federal criminal case – from investigation to jury trials to appeals. As a prosecutor, Sarah obtained dozens of convictions via trial and plea in six different federal trial courts across the country. She first and second chaired multiple weeks’ long federal criminal trials.
As a defense attorney, Sarah is experienced at running corporate internal investigations and excels at client counseling. She has led internal investigations on a wide variety of subject matters, including financial fraud, FCPA, narcotics in a corporate setting, #MeToo sexual harassment allegations, whistleblower retaliation and other employment-related claims.
Sarah views her role on behalf of both companies and individuals to vigorously advocate for her client’s interests and if the government is investigating, persuade enforcement agencies to decline to pursue criminal prosecution or other enforcement actions.
Additionally, she is frequently sought out by clients for her skills in civil litigation, particularly in 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. Sarah investigated and prosecuted some of the most complex financial crimes on Wall Street as part of the Fraud Section’s Securities and Financial Fraud Unit, focusing on the investigation and prosecution of major global financial institutions. She also has significant experience prosecuting criminal health care fraud, money laundering and kickback offenses, and she was a member of the highly successful nationwide Medicare Fraud Strike Force.
Before her government service with the U.S. Department of Justice, Sarah spent more than eight years with 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, particularly in the areas of securities fraud, accounting improprieties and other types of alleged financial fraud. Her practice also focused on corporate internal investigations.
Prior to her career as a lawyer, Sarah worked as a congressional staffer in the Capitol Hill offices of U.S. Senator Bob Graham of Florida and U.S. Representative Jim Moran of Virginia, where she focused on Finance and Appropriations Committee matters.
Examples of Sarah’s experience include:
In private practice
- Represented a major U.S. company’s former CFO in a criminal investigation, parallel civil and regulatory investigations, and numerous SDNY civil litigations. 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.
- 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 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. No criminal charges were brought against the client.
- Represented, on a pro bono basis, before the September 11th Victim Compensation Fund, a military service member who was seriously injured in the September 11th attack on the Pentagon. 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.
- Obtained multiple convictions after lengthy federal jury trials in several different federal courts; trials lasted three to seven weeks.
- Served as a prosecutor on the Department of Justice team that prosecuted and obtained corporate parent-level guilty pleas and over $2.5 billion in criminal fines from five major global banks in the Foreign Exchange (“FX”) 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.
- Served as lead Fraud Section prosecutor in obtaining the convictions of dozens of defendants, via trial or guilty plea, in health care fraud prosecutions in Brooklyn, New York; Houston, Texas; and Baton Rouge, Louisiana.
- “DOJ Still Pursuing Traders for Spoofing, Despite Thakkar Setback,” Bloomberg Law, September 2019
- “Preparing for a DoD OIG Audit: DoD’s Focus on Small Business Set-Aside Contracts and Certifications,” Pratt’s Government Contracting Law Report, July 2019
- “DOJ Guidelines for Disclosure, Cooperation and Remediation in FCA Matters,” Thompson Hine Government Contracts Update, June 2019
- Quoted, “Criminal Charges Can Creep Up on Clinicians, Administrators,” Healthcare Risk Management, June 2019
- Quoted, “Strict Rules Addressing Opioid Crisis Create Risk for Physicians,” Healthcare Risk Management, April 2019
- Quoted, “Mueller's Obstruction Punt Puzzles Ex-Prosecutors,” Law360, March 2019
- Quoted, “DOJ Pursuing EHR Vendors for False Claims, Kickbacks,” Healthcare Risk Management, March 2019
- Quoted, "Hints of 'Sloppy' Prosecution Could Haunt Esformes Trial," Law360, February 2019
- “DOJ Opioid Warning Letters—Legitimate Law Enforcement Purpose or Prosecutorial Overreach?” Bloomberg Law, February 4, 2019
- “Yates Memo Revised to Provide DOJ Greater Flexibility in Corporate Investigations,” Thompson Hine White Collar/FCPA Update, December 2018
- “Federal Government Signals Continued Aggressive Health Care Fraud Enforcement,” Thompson Hine Health Care Law Update, October 2018
- “Recent FCPA Developments,” Thompson Hine White Collar Update, October 2018
- Quoted, "The Privacy Fight For Digital Data Warrants Is Just Starting," Law360, September 2018
- “DOJ Beefs Up Criminal Health Care Fraud Enforcement with Addition of Newark/Philadelphia Strike Force,” Thompson Hine Health Care Law Update, August 2018
- Quoted, “Indicted Congressman’s Campaign Already Paid $614,000 to Lawyers,” Bloomberg Government, August 24, 2018
- Quoted, “Cohen Plea Reflects High Bar For Cooperators," Law360, August 22, 2018
- “OIG Releases List of Provider Self-Disclosure Settlements for First Half of 2018,” Thompson Hine Health Care Law Update, July 2018
- “Ways Your Company May Be Drawing Criminal Health Care Fraud Scrutiny,” New York Law Journal, March 30, 2018
- “When The FBI Comes Knocking A Guide For In-House Counsel,” Law360, January 30, 2018
- Quoted, “Ex-Katten Atty Conviction A Cautionary BigLaw Tale,” Law360, January 3, 2018
- “U.S. Department of Justice Provides New FCPA Voluntary Self-Disclosure Incentives,” Thompson Hine White Collar Update, December 2017
- Quoted, “Russia Probe Charges Show Mueller In Dive Bomb Mode,” Law360, October 2017
- 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
- Selected for inclusion in Washington, D.C. Super Lawyers, 2019
- Panel Member, Criminal Justice Act (CJA) Felony Panel for the U.S. District Court for the District of Maryland
- Member, Law360's White Collar Editorial Advisory Board
- Nominee, Attorney General’s Award for Fraud Prevention
- Barrister, William B. Bryant Inn of Court
- Women’s White Collar Defense Association
- SMYAL (Supporting and Mentoring Youth Advocates and Leaders)
September 27, 2019
Preparing for a DoD OIG Audit: DoD’s Focus on Small Business Set-Aside Contracts and CertificationsPratt's Government Contracting Law Report
July 10, 2019
Eight Thompson Hine Lawyers Recognized by Washington, D.C. Super Lawyers Thompson Hine LLP
May 13, 2019
Law Enforcement Purpose or Prosecutorial Overreach?Bloomberg Law
February 04, 2019
September 14, 2018
August 22, 2018
July 23, 2018
Ways Your Company May Be Drawing Criminal Health Care Fraud ScrutinyNew York Law Journal
March 30, 2018
January 30, 2018
January 02, 2018
October 30, 2017
September 07, 2017