Biography

Corporations and individuals alike turn to Sarah M. Hall, an experienced former federal prosecutor, to represent them in government investigations and prosecutions of alleged violations of the health care, anti-fraud, procurement, Foreign Corrupt Practices Act (FCPA), sanctions, export control, securities, commodities, and criminal tax laws. From her many years as a prosecutor with the U.S. Department of Justice (DOJ), Sarah has extensive experience in every phase of a federal criminal case—from investigation to jury trials to appeals.

Clients benefit from Sarah’s insight into how prosecutors and law enforcement agents think, investigate, and try cases. With her firsthand knowledge, Sarah 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.

As a former health care fraud prosecutor, Sarah devotes a significant part of her practice to representing companies and individuals in criminal and civil health care enforcement matters, including False Claims Act and state Attorney General investigations. Her health care clients include long-term care facilities, pharmacies, medical practices, independent diagnostic testing facilities, medical consulting companies, doctors, other licensed medical practitioners, medical industry executives, and sales reps.

Clients also look to Sarah to lead sensitive corporate internal investigations into allegations involving health care, financial fraud, FCPA violations, export control violations, narcotics in a corporate setting, #MeToo sexual harassment, and whistleblower retaliation. She is also frequently sought out by clients for her skills in civil litigation, including high-stakes and emergency matters, such as temporary restraining orders and preliminary injunctions.

Sarah previously served for seven years as a white-collar crime prosecutor with the Fraud Section of DOJ’s Criminal Division. Sarah began her DOJ career as a prosecutor on the highly successful nationwide Medicare Fraud Strike Force, and she has significant experience prosecuting criminal health care fraud, money laundering, and kickback offenses. In the Securities and Financial Fraud Unit (now known as the Market Integrity and Major Frauds Unit), 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.

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

Health Care Fraud

  • Represented a company in connection with an HHS Office of Inspector General (OIG) 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 pharmacy in connection with a DOJ and OIG 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 doctor in a DOJ and OIG investigation into alleged kickbacks and violations of the Stark Law. No claims or charges were brought against the client.

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.
  • 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.

Corporate and Financial Fraud

  • Represented a major U.S. company’s former chief financial officer 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.

Foreign Corrupt Practices Act

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

Government Contract and Grant Fraud

  • Represented a company in a criminal government contract fraud case indicted by the U.S. Attorney’s Office for the Eastern District of Virginia.
  • 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.

Internal Investigations

  • Led an internal investigation for an international motor vehicle company regarding narcotics smuggling and possible FCPA violations. 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 a major charitable foundation in regard to #MeToo sexual harassment allegations spanning a 10-year period.
Education
  • The George Washington University Law School (J.D., with honors, 2001)
    • Member, The George Washington International Law Review
  • College of William and Mary (B.A., 1997)
    • Monroe Scholar
Bar Admissions
  • District of Columbia
  • Maryland
Court Admissions
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. Court of Appeals for the Second Circuit
  • U.S. Court of Appeals for the Fourth Circuit
  • U.S. District Court, District of Columbia
  • U.S. District Court, District of Maryland
Memberships
  • Edward Bennett Williams American Inn of Court, Barrister
  • Women’s White Collar Defense Association, Public Relations Team
  • SMYAL (Supporting and Mentoring Youth Advocates and Leaders)
Recognition
  • Washington, D.C. Super Lawyers, Criminal Defense: White Collar, Civil Litigation: Defense, Health Care, Securities Litigation (2019, 2020 and 2021)
  • Criminal Justice Act (CJA) Felony Panel for the U.S. District Court for the District of Maryland, Panel Member (2018 to present)
  • Law360, White Collar Editorial Board (2018)
  • Attorney General’s Award for Fraud Prevention, Nominee (2013)