Overview

Sarah Walters is an experienced trial lawyer who focuses her practice on white collar criminal defense, regulatory enforcement and compliance matters, and complex civil litigation. In addition to both criminal and civil trial work, Sarah has substantial experience conducting internal investigations and assists companies in developing compliance policies and training programs.

Sarah has particular expertise in advising companies on compliance with the Foreign Corrupt Practices Act and has handled criminal and civil health care matters for hospital systems, medical device manufacturers and electronic health record providers, including in connection with alleged violations of the Federal Anti-Kickback Statute and matters arising under the Stark law.

Before joining McDermott, Sarah served 10 years as an Assistant United States Attorney in the Boston US Attorney’s office, holding the position of Chief of the Economic Crimes Unit during the last four years of her tenure. Sarah’s work as a prosecutor included leading and supervising successful investigations and numerous jury trials covering a broad spectrum of economic crimes, including violations of the Foreign Corrupt Practices Act, insider trading, market manipulation, investment advisor fraud, Ponzi schemes and tax evasion. She was the lead prosecutor on the first securities fraud undercover operation in the District of Massachusetts, which led to more than 30 convictions in pay-to-play and market manipulation cases. Sarah also served as a liaison to President Obama’s Financial Fraud Enforcement Task Force.

Prior to serving in government, Sarah was a partner in private practice at a large Boston law firm, where her litigation practice covered a diverse range of complex civil litigation and external and internal criminal investigations. Sarah’s experience includes litigation involving allegations of securities fraud, investment fraud, bank fraud, tax and bankruptcy crimes, and antitrust violations.

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Results

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; McDermott 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 (US District Court for the District of Delaware)
Adviser to major U.S. public accounting firm on Foreign Corrupt Practices Act compliance
Successfully advocated on behalf of major hospital system to convince prosecutors to decline to intervene in qui tam litigation, which litigation was ultimately dismissed
Represented high profile witness in Hobbs Act extortion trial
Obtained full acquittal after trial of 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)*

Represented a major pharmaceutical company in government investigation of alleged off-label marketing practices related to an epilepsy drug, which resulted in a very favorable settlement for the client*
Represented the managing director of a private equity firm in connection with civil lawsuits filed upon discovery of fraudulent accounting practices at its portfolio company*

*Matter handled prior to joining McDermott.

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Recognitions

The Legal 500 2019
The Best Lawyers in America 2019 and 2020, Criminal Defense: White-Collar

Credentials

Education
Boston College Law School, JD, magna cum laude, 1997
University of Pennsylvania, BA, cum laude, 1994

Admissions
Massachusetts

Courts / Agencies
US Court of Appeals for the First Circuit
US Court of Appeals for the Fourth Circuit
US District Court for the District of Massachusetts

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