Sarah Walters is a former federal prosecutor and 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 representing clients in securities, healthcare and other government enforcement matters. She also assists companies in developing compliance policies and programs.
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 telehealth providers, 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 and conducting investigations in matters involving anti-bribery laws. 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. 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.
Government and Internal Investigations
- Defends a broad spectrum of organizations, including accounting firms, publicly traded companies, and healthcare providers and systems in connection with civil and criminal government investigations and related litigation
- Represented Audit Committee of major publicly traded company in investigation concerning alleged accounting fraud and handled related inquiries by the Securities & Exchange Commission, which terminated its investigation without bringing any claims
- 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 counsel for the plaintiff, leading provider of de-identified electronic health records (Real World Data), in breach of contract action; won jury verdict for breach of contract and prevailed in post-trial injunction proceeding (District of Massachusetts)
- 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)
- 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
- Conducts compliance due diligence and compliance reviews for clients in a wide variety of industries
*Matter handled prior to joining McDermott.
- The Best Lawyers in America, 2019 to 2023, Criminal Defense: White-Collar and Litigation – Securities
- Chambers USA, 2021 and 2022, Litigation: White-Collar Crime & Government Investigations
- Legal 500 US, 2019
Boston College Law School, JD, magna cum laude, 1997
University of Pennsylvania, BA, cum laude, 1994
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