Sarah represents companies and individuals in criminal and civil investigations involving all types of alleged financial fraud, including honest services or commercial fraud, accounting and disclosure issues and public corruption. She conducts independent investigations on behalf of Audit and other Board committees and has handled criminal and civil healthcare 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.

Sarah has particular expertise in advising companies on compliance with the Foreign Corrupt Practices Act. She also works with companies to design, implement and audit compliance programs consistent with the U.S. Department of Justice’s, and other relevant, guidance.

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 financial crimes, including violations of the Foreign Corrupt Practices Act, insider trading, market manipulation, investment advisor fraud, Ponzi schemes and tax evasion.  Sarah also served as a liaison to President Obama’s Financial Fraud Enforcement Task Force and was responsible for the Office’s prosecution of cases arising out of misuse of Troubled Asset Relief Program (TARP) funds.

Sarah also maintains an active pro bono practice and is a member of the Criminal Justice Act (CJA) panel for the US District Court for the District of Massachusetts, representing indigent defendants in criminal matters.

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• Represented Board of Directors in internal investigation concerning accounting disclosures
• Represented electronic health records provider in False Claims Act investigation, which led to a very favorable settlement
• 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 partners and employees of major US accounting firm in connection with criminal investigation and prosecution arising out of alleged investment fraud at prominent hedge fund
• Represented high profile witness in Hobbs Act extortion trial
• Represents major health care systems in False Claims Act, Anti-Kickback Statute, and controlled substance diversion investigations

Trial Experience

• 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 (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 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)

Compliance Advice

• Conducted compliance review for EU-based multi-national auto parts manufacturer
• Conducted risk assessment and compliance review for major US accounting firm
• Advising major US public accounting firm on Foreign Corrupt Practices Act and other compliance matters
• Advising recipients of Paycheck Protection Program (“PPP”) and other CARES Act funding on compliance matters
• Advised cryptocurrency firm on anti-money laundering compliance
• Conducts compliance due diligence and compliance reviews for clients in a wide variety of industries

*Matter handled prior to joining McDermott.

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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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