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Morgan Lewis
Sandra Moser

Sandra Moser

Partner

sandra.moser@morganlewis.com

Washington, DC Phone +1.202.739.5393 Fax +1.202.739.3001

1111 Pennsylvania Ave. NW//Washington, DC 20004-2541//United States

Philadelphia Phone +1.215.963.5311 Fax +1.215.963.5001

1701 Market St.//Philadelphia, PA 19103-2921//United States

Sandra Moser is a partner in Morgan Lewis’s white collar litigation and government investigations practice and former chief of the US Department of Justice’s (DOJ’s) Fraud Section in Washington, DC, which has exclusive jurisdiction over the Foreign Corrupt Practices Act (FCPA) and routinely handles many of the world’s most significant economic crime cases. A veteran trial lawyer, she represents companies and executives in a wide range of matters involving the DOJ, the US Securities and Exchange Commission (SEC), US Congress, and various other domestic and international enforcement agencies.

As chief of the DOJ's Fraud Section, Sandra led a team of more than 150 white collar prosecutors and oversaw the FCPA Unit, as well as the section’s healthcare, securities, and financial fraud prosecutions. She led, negotiated, or approved dozens of corporate enforcement resolutions, including global coordinated resolutions involving multiple domestic and foreign authorities, and played a key role in the selection and oversight of corporate monitors. Sandra also helped develop and implement significant policy changes affecting corporate criminal enforcement throughout the DOJ, including the FCPA Corporate Enforcement Policy and various reforms to the Justice Manual. She has tried numerous cases to verdict and played a lead role in investigating and prosecuting many of the world’s largest financial institutions and their employees for manipulating the London Interbank Offered Rate (LIBOR) and foreign exchange (FX) markets. 

In addition to her deep background representing clients in matters related to the FCPA and other complex fraud, Sandra focuses on the False Claims Act (FCA), securities, commodities, and anti-money laundering-related matters. She handles major corporate investigations and crises, including those involving #MeToo claims. She represents companies, boards of directors, and senior executives in investigations, corporate crises, and litigation involving US federal and state governments, and international enforcement agencies.

Sandra regularly speaks in the United States and abroad at forums addressing enforcement policies, trends, and priorities in the white collar space. She also guest lectures at academic institutions including Harvard Law School, Harvard Business School, and the University of Pennsylvania Carey Law School.

Before joining Morgan Lewis, Sandra was a partner at another global law firm, where she co-chaired the investigations, government enforcement, and white collar criminal defense practice. Prior to serving the DOJ's Fraud Section in various leadership positions, Sandra spent several years as an assistant US attorney in the District of New Jersey Special Prosecutions Division.


Selected Representations

  • A multinational conglomerate in an FCPA investigation before the DOJ and SEC 
  • An exchange regarding a market manipulation investigation before the DOJ and Commodity Futures Trading Commission (CFTC)
  • A global bank regarding a financial fraud investigation before the DOJ, CFTC, and SEC
  • A media company in an FCPA investigation before the DOJ and SEC 
  • A pharmaceutical company in connection with a DOJ investigation 
  • An institutional pharmacy in an FCA investigation before the DOJ 
  • An automotive technology supplier in an FCA investigation before the DOJ
  • Pre-investment and pre-acquisition enhanced FCPA/anti-corruption due diligence in numerous significant deals
  • Numerous companies, from startups to Fortune 50 corporations, in assisting with drafting codes of conduct and compliance procedures; conducting risk assessments, gap analysis, and compliance benchmarking; and enhancing existing compliance programs 
  • A former White House employee in an investigation by the House Committee on the Judiciary
  • A former investor relations executive of a public company before the SEC in an accounting fraud investigation 
  • A pharmaceutical company executive in connection with an SEC investigation
  • A publicly traded company in connection with a Federal Trade Commission investigation
  • As head of the DOJ Fraud Section, approval and hands-on responsibility for all corporate enforcement action, significant individual charging decisions and litigation strategy
  • One of the lead attorneys for the United States in the LIBOR investigation for manipulation of the benchmark interest rate resulting in a myriad of corporate enforcement actions and individual charges
  • Prosecution of a financial institution CEO for securities fraud; convicted after a jury trial in 2016
  • One of the lead trial attorneys for the United States in the investigation and prosecution of more than 40 individuals arrested in connection with political corruption, rabbinical money laundering, and black market organ sales in New Jersey and New York

Awards and Affiliations

Recognized, Litigation - Regulatory Enforcement (SEC, Telecom, Energy), Washington, DC, The Best Lawyers in America (2022)

Recognized, Ones to Watch, The Best Lawyers in America (2021)

Top FCPA Practitioner, Global Investigations Review (2021)

Member, White Collar Editorial Advisory Board, Law360 (2021)

Best Lawyers in America, Litigation–Regulatory Enforcement (SEC, Telecom, Energy), US News/Best Lawyers – Best Law Firms (2020)

Emerging Women Leaders in Private Practice, DCA Live (2019)

Top 100 Women in Investigations, Global Investigations Review (2018)

Member, American Bar Association, Women in White Collar Subcommittee

Member, Women's White Collar Defense Association, Monitor/Receiver Initiative Subcommittee

US Attorney General’s Award for Distinguished Service (2016)

US Attorney General’s Award for Distinguished Service (2014)

Assistant Attorney General for Exceptional Service Award (2014)

Articles Editor, Journal of Criminal Law & Criminology, Northwestern University Pritzker School of Law (2002)

Admissions

  • District of Columbia
  • Pennsylvania
  • New Jersey

Clerkships

  • Clerkship to Judge Marjorie O. Rendell of the US Court of Appeals for the Third Circuit (2004 - 2005)
  • Clerkship to Judge Norma L. Shapiro of the US District Court for the Eastern District of Pennsylvania (2002 - 2003)

Education

  • Northwestern University Pritzker School of Law, 2002, J.D., cum laude
  • University of North Carolina at Chapel Hill, 1998, A.B. (Journalism), B.A. (Women’s Studies), Phi Beta Kappa

Sectors

  • Life Sciences
  • Technology
  • Sports

Services

  • White Collar Litigation & Government Investigations
  • False Claims Act & Qui Tam Litigation
  • Crisis Management
  • Financial Services Counseling & Litigation
  • Healthcare & Life Sciences Litigation
  • Securities Enforcement & Litigation
  • Foreign Corrupt Practices Act & Global Anti-Corruption
  • Business and Human Rights Law
  • Corporate Ethics & Compliance
  • Broker-Dealer Regulation & Compliance

Regions

  • North America
  • Asia Pacific
  • Europe
  • Latin America

Events

3/23/2022 - M&A: Expectations and Practicalities of Anti-Corruption Due Diligence through Ethics & Compliance Integration
3/2/2022 - ABA's 37th National Institute on White Collar Crime
12/9/2021 - ABA’s Anti-Corruption Day of Learning 2021
11/30/2021 - ACI'S 38th International Conference On The Foreign Corrupt Practices Act
10/27/2021 - ABA’S 36th National Institute on White Collar Crime
8/4/2021 - White Collar and Government Enforcement Developments Affecting the Automotive and Mobility Industry
7/20/2021 - SIFMA’s C&L Virtual Forum 2021
3/4/2021 - Understanding DOJ’s Enforcement Tools in Collusion and Corruption Investigations
3/3/2021 - Internal Investigations: How to Navigate in a Pandemic World
12/14/2020 - Enforcement Outlook 2021: Fraud & Abuse
12/14/2020 - Navigating the NEXT. Enforcement Outlook 2021
12/9/2020 - GIR Live Interactive: Regional Spotlight - North America
12/2/2020 - ACI'S 37th International Conference on the Foreign Corrupt Practices Act
11/12/2020 - Fast Break: Telehealth Fraud
11/12/2020 - Navigating the Next: Outlook 2021
10/7/2020 - Women’s White Collar Defense Association – London Chapter YPC Meeting
10/6/2020 - Overview of the Foreign Corrupt Practices Act (FCPA) and Anti-corruption Trends in the US and Beyond
9/4/2020 - PLI The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2020
4/5/2019 - Program on Corporate Compliance and Enforcement
3/15/2019 - Eighteenth Annual Institute on Securities Regulation in Europe: Practical Implications
3/6/2019 - ABA's 33rd Annual National Institute on White Collar Crime
11/29/2018 - 35th International Conference on the Foreign Corrupt Practices Act
11/16/2018 - 2018 White Collar Practice Conference
10/25/2018 - National Association of Former United States Attorneys Annual Conference
10/8/2018 - 7th Annual London White Collar Crime Institute
9/14/2018 - 2018 ACFE Fraud Risk Management Summit
5/8/2018 - 7th Annual White Collar Crime Institute
5/8/2018 - Enforcement 2018: Perspectives from Government Agencies
3/22/2018 - 2018 ALB Hong Kong Anti-Corruption Forum
3/1/2018 - 2018 White Collar Crime Institute
2/2/2018 - 17th Annual Institute on Securities Regulation in Europe
11/30/2017 - ACI's 34th International Conference on the FCPA
11/21/2017 - 6th Annual Anti-Bribery & Corruption Forum
11/9/2017 - No Turning Back: 40 Years of the FCPA and 20 Years of the OECD Anti-Bribery Convention
10/6/2017 - Conference on Deterring Corporate Crime: The Promise and Challenge of Multiple Enforcers
7/25/2017 - Conference on Deterring Corporate Crime: The Promise and Challenge of Multiple Enforcers
7/24/2017 - 2nd Executive Roundtable on Anti-Corruption Compliance Programs
6/27/2017 - ACI's 11th Advanced Forum on FCPA & Anti-Corruption in the Life Sciences Industry
6/15/2017 - Women in White Collar Regional Luncheon
4/20/2017 - 19th Annual New York Conference on the Foreign Corrupt Practices Act

News

2/15/2022 - DOJ Fraud Section Roars Back from Pandemic Conviction Dip, Law360
2/15/2022 - Luck, Ties Drives Lucrative Big Law Corporate Monitoring for U.S., Bloomberg Law
1/3/2022 - 3 White Collar Trends To Watch In 2022, Law360
12/16/2021 - New Policies and Tough Talk: How the Biden Administration Is Turning Up Heat on Corporate America, The National Law Journal
12/15/2021 - Compliance Hot Spots: Biden Administration Takes Aim at Global Corruption, Law.com
12/6/2021 - US Launches “Ambitious” New Anti-Corruption Strategy, Global Investigations Review
6/14/2021 - FCPA Top Practitioners of 2021, GIR
6/14/2021 - Morgan Lewis Partner Sandra Moser Recognized by GIR as Leading FCPA Practitioner
4/30/2021 - Morgan Lewis Lawyers, Professional Staff Named to Law360 2021 Editorial Advisory Boards
1/28/2021 - A Hire Gear: Big Law's Top Laterals of 2020, The American Lawyer
1/6/2021 - 2020 in Review: More Coordination, Fewer Monitors, Anti-Corruption Report
12/16/2020 - 2020 in Review: Big FCPA Numbers Despite a Pandemic, Anti-Corruption Report
11/19/2020 - OECD Lauds Past Decade of FCPA Enforcement, with Caveats, Law360
11/18/2020 - Former Government Officials Weigh In on What To Expect from Presidential Administration Shift
11/18/2020 - OECD Praises U.S. Global Anti-Bribery Enforcement Efforts, Compliance Week
10/30/2020 - Leading Questions: Morgan Lewis Litigation Partner Sandra Moser, Bloomberg Law
9/2/2020 - Morgan Lewis Nabs Two Top Washington, DC Litigators, Sandra Moser and Robin Nunn

Publications

4/7/2022 - Due Diligence, Ethics, and Compliance Considerations for Dealmakers
2/16/2022 - DOJ Ramping Up Fraud Enforcement Efforts: 2021 Year in Review Report
1/26/2022 - Automotive Industry: Year in Review 2021
12/6/2021 - DOJ Discusses Enforcement, Reiterates Biden-Harris Anti-Corruption Commitment at ACI FCPA Conference
11/2/2021 - New DOJ Corporate Crime Approach May Deter Self-Reporting, Law360
11/1/2021 - DOJ Deputy Attorney General Pledges New Approach to Corporate Crime
8/10/2021 - Enforcement Issues and Trends Affecting the US Automotive and Mobility Industry
3/4/2021 - LawFlash: A Fraud Section Year in Review for a Year Like No Other
2/26/2021 - A Fraud Section Year in Review for a Year Like No Other
1/27/2021 - Equity-Focused Executive Orders Telling for Businesses Interacting with US Government
11/23/2020 - What to Expect from DOJ Enforcement Under Biden, Law360
11/19/2020 - The Outlook for Enforcement Actions Under a Biden Administration