Sarah Heaton Concannon
Partner, Quinn Emanuel Urquhart & Sullivan
Sarah Heaton Concannon is a nationally recognized first-chair trial and appellate lawyer who serves as Co-Chair of Quinn Emanuel’s SEC Enforcement Defense practice and is resident in the firm’s Washington, D.C. and New York offices. Sarah has over two decades’ experience representing and advising public companies, private funds, hedge funds, investment advisers, boards, audit committees, senior executives, and other individuals in bet-the-company litigation and governmental investigations. Sarah brings together a practical, results-driven, client-centric focus, outstanding academic credentials, and a unique depth of knowledge regarding how to best navigate governmental and regulatory processes to achieve results for clients.
Sarah recently held senior positions at the U.S. Securities and Exchange Commission (SEC). As Senior Trial Counsel at the SEC, Sarah litigated and investigated a wide array of securities matters, including actions for fraud, market manipulation, breaches of fiduciary duty, insider trading, violations of the Foreign Corrupt Practices Act (FCPA), excessive mark-ups, and disclosure and books and records violations. Sarah’s federal district court litigations included high-profile and ground-breaking matters of key significance to the Commission, hundreds of millions of dollars recovered on behalf of investors, and multiple parallel criminal actions with the U.S. Department of Justice and U.S. Attorneys’ Offices. Sarah was undefeated in dispositive motions, at trial, and on appeal.
While at the SEC, Sarah provided strategic advice and counsel in crypto and digital asset matters and also worked closely with both the Office of General Counsel and the Co-Directors of Enforcement on crypto-policy and the application of the Howey Test to evolving technologies. Sarah has extensive experience handling matters involving cross-border enforcement, blocking statutes, and the IOSCO Multilateral Memorandum of Understanding. She was a key member of a cross-divisional SEC team focused on uncovering potential violations of U.S. securities laws by entities and individuals located in the People’s Republic of China (PRC), and a go-to resource for the SEC’s coordinated enforcement response to legal developments in the PRC.
Sarah also served as a member of the executive staff of the SEC’s Division of Enforcement as Senior Counsel to the Directors. In that capacity, she advised the Directors on enforcement matters and regularly liaised with the Chairman and Commissioners. Sarah prepared Congressional correspondence and testimony and aided Congress in considering and drafting legislation, including related to insider trading, statutes of limitations, disgorgement, and restitution. As a result of having served on the Division’s executive staff, Sarah is uniquely situated to help clients navigate the SEC’s Wells process and cooperation program. In 2020, Sarah received the SEC’s Douglas Adams Award for significant contributions to improving the effectiveness of the National Examination Program through personal leadership, and, in 2019, she received the Division Directors Award for her efforts securing tens of millions of dollars in unlawful trading assets in SEC v. Longfin Corp., et al., 18 Civ. 2977-DLC (S.D.N.Y.).
Before joining the SEC, Sarah was a senior partner at a premier international law firm, where she led the representation of Global 500 companies and financial institutions in a broad range of complex securities and business disputes. Sarah also represented clients in criminal and quasi-criminal proceedings brought by federal and state authorities, including the SEC, FINRA, the U.S. Department of Justice, and various state attorneys general. She advised clients in connection with enforcement matters, private lawsuits, multi-party and shareholder class actions, and on subject-matters including securities, contract law, antitrust, energy, products liability, cybersecurity, data privacy, SAR compliance, anti-money laundering, and insurance, risk, and compliance matters. Sarah has been certified as an anti-money laundering specialist by the Association of Certified Anti-Money Laundering Specialists (ACAMS).
Sarah is a frequent speaker at industry and legal conferences, both within her substantive areas of expertise and on trial and practical litigation skills. Sarah’s recent public engagements include speaking on developments in governmental investigations and enforcement at the DC Bar Association and the American Bar Association’s conferences. She often speaks on cross-border regulation and enforcement.