Sandra Moser

Sandra focuses on results for clients, whether large public companies or individuals under scrutiny or in crisis. She has obtained declinations from multiple sections of the DOJ’s Criminal and Civil Divisions in FCPA, fraud, crypto, FCA, and healthcare-related cases, and obtained similar favorable results from the SEC, the CFTC, and international regulators, such as the UK Serious Fraud Office.

As chief of the DOJ’s Fraud Section, Sandra led a team of 150-plus 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. She currently serves as the co-chair of the Women in White Collar Defense Association’s Monitor Committee.  

Sandra also helped develop and implement significant policy changes affecting corporate criminal enforcement throughout the DOJ, including the Corporate Enforcement Policy and various reforms to the Justice Manual.

Sandra speaks across 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.

• Secured criminal declination and civil termination of years-long investigation of a multinational, publicly traded conglomerate in an FCPA investigation before the DOJ and SEC
• Secured criminal declination for publicly traded company pursuant to the DOJ Mergers & Acquisition Policy
• Favorably resolved market manipulation investigation before the DOJ and CFTC for major exchange
• Secured victim status for a global bank in a sprawling financial fraud investigation before the DOJ, CFTC, and SEC
• Secured a criminal declination for publicly traded media company in an FCPA investigation before the DOJ and SEC, along with case closure by the UK Serious Fraud Office
• Secured closure of investigation for global, public pharmaceutical company in connection with a DOJ FCA investigation
• Secured dismissal for a publicly traded automotive technology supplier in an FCA investigation before the DOJ
• Regular representation of executives in DOJ investigations, resulting in avoidance of charges
• Conducted reinvestment and pre-acquisition enhanced FCPA/anti-corruption due diligence in numerous significant deals
• Assisted 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
• Negotiated no appearance or testimony for a former White House employee in an investigation by the House Committee on the Judiciary
• Represented a former investor relations executive of a public company before the SEC in an accounting fraud investigation
• Represented a pharmaceutical company executive in connection with an SEC investigation
• Represented 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

Results may vary depending on your particular facts and legal circumstances.