Sandra Moser

Sandra is business minded and results oriented, recently obtaining declinations from the DOJ’s FCPA Unit, the SEC, and the UK Serious Fraud Office for a global public company in one matter and a full dismissal of a False Claims Act (FCA) complaint for a public automotive technology supplier in another.

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.

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 matters related to the FCA, securities, commodities, and anti-money laundering. She handles major corporate investigations and crises, including those involving #MeToo claims. Sandra 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.

• A multinational conglomerate in an FCPA investigation before the DOJ and SEC 
• An exchange in a market manipulation investigation before the DOJ and CFTC
• A global bank in 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 lawyers 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 lawyers 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