Sarah S. Mallett
Overview
Sarah is an expert in her field and a highly trusted adviser.” - Chambers USA
Sarah Mallett is a partner in the Government, Regulatory & Internal Investigations Practice Group in the Dallas office of Kirkland & Ellis LLP. Sarah is a former Assistant Director in the United States Securities and Exchange Commission’s (SEC) Division of Enforcement and an experienced litigator who focuses on advising and representing public companies, private equity firms, asset managers, financial institutions, and other entities and individuals facing government, regulatory, or internal investigations, examinations and enforcement proceedings. Sarah brings clients a current and insider’s view on how to best navigate SEC investigations, examinations and rulemaking.
During her more than seven years at the SEC, Sarah supervised or served as the primary attorney on countless investigations, including multiple complex and high-profile enforcement actions, national priority investigations, sweep investigations and parallel investigations with the Department of Justice, FINRA, and other federal or state regulatory and law enforcement authorities. She also served on multiple of the Division’s national working groups. The SEC has recognized Sarah with numerous awards for her work. In 2022, Sarah was an individual recipient of the Division’s Ellen B. Ross Award for “exemplary commitment, enthusiasm and performance” and a team recipient of the Chair’s Award for Investor Protection. In 2021, Sarah received an inaugural performance award for an “extraordinary and rare level of performance,” and she received a Director’s Award in 2017. Sarah’s understanding of the SEC’s processes and priorities and her broad experience with federal securities laws make her uniquely positioned to offer key insights to prevent or minimize clients’ regulatory exposure and to work productively with SEC staff to protect her clients’ interests.
Experience
Representative Matters
While at Kirkland, Sarah has worked on the following selected matters:
Government Defense
- Defense of a large eCommerce company in parallel investigations by the SEC and DOJ regarding financial reporting.
- Defense of a transportation and logistics company in parallel investigations by the SEC and DOJ related to accounting practices and financial reporting.
- Defense of a Fortune 50 company in an SEC investigation.
- Defense of a global chemical and materials company in an SEC investigation relating to financial disclosures and accounting practices.
- Defense of a global technology company in parallel investigations by the SEC and DOJ.
- Defense of a pharmaceutical company in an SEC investigation concerning potential insider trading.
- Defense of a major technology firm in a False Claims Act investigation by the DOJ.
- Representing a public relations firm in connection with an SEC investigation related to cryptocurrency.
- Defense of a former senior officer in an SEC investigation related to accounting and disclosure practices.
- Defense of a large eCommerce company in an investigation by the New York Attorney General’s office related to financial reporting and consumer protection issues.
Internal Investigations
- Conducted an internal investigation and advised on governance issues for a Fortune 50 company regarding certain vendor practices.
- Conducted an internal investigation and advised on governance issues for a Fintech company regarding compliance with various FTC and NYDFS requirements.
- Conducted an internal investigation and advised on governance issues for a multinational software provider regarding accounting practices at a subsidiary.
- Conducted an internal investigation and advised on governance issues for a Fintech company related to corporate compliance and vendor practices.
- Conducted an internal investigation and advised on governance issues for a large software company.
- Advising an infrastructure company on cybersecurity framework and enhancements and crisis response.
While at the SEC, Sarah worked on the following selected matters:
- Supervised SEC investigation and settled enforcement action of registered investment advisers in connection with more than $50 million in undisclosed fees and other alleged conflicts of interest.
- Supervised SEC investigation and litigated action alleging certain entities and individuals operated as unregistered broker-dealers that facilitated more than $1.2 billion of securities trading.
- Co-supervised SEC investigation and settled enforcement action against international audit firm, firm CEO, and engagement quality review partner for professional misconduct, reporting violations, and proxy fraud violations in connection with de-SPAC transaction.
- Supervised SEC investigation and settled enforcement action in connection with international Fortune 500 company's violation of Rule 21F-17 under the Dodd-Frank Whistleblower Rules.
- Supervised SEC investigation and litigated action against international entities and an individual alleged to have fraudulently raised more than $1 billion of crypto asset securities.
- Co‐lead counsel in SEC complex fraud investigation of battery-electric and hydrogen-powered vehicle transportation company resulting in settled enforcement action against the company and litigated action and parallel criminal prosecution of former founder and CEO.
- Supervised numerous investigations regarding public company issuers, executives, and their auditors, regarding alleged violations of antifraud, internal accounting controls, disclosure controls and procedures, and internal control over financial reporting provisions of federal securities laws.
Clerk & Government Experience
Assistant DirectorUnited States Securities and Exchange Commission, Division of Enforcement2021–2024
Senior CounselUnited States Securities and Exchange Commission, Division of Enforcement2016–2021
Judicial InternMagistrate Judge Irma C. RamirezUnited States District Court for the Northern District of Texas2010
Prior Experience
More
Thought Leadership
Publications
Co-Author, “White-Collar Crime Practice Guide – U.S. Chapter,” Chambers & Partners, October 2024
Speaking Engagements
“A ‘New Day’ at the SEC (400+ Days Later) – The Impact of Changes in Leadership and Priorities,” Securities Enforcement Forum West, May 2026
“The SEC’s Role in Cyber and Emerging Technologies: Rulemaking, Disclosures, and Enforcement,” Securities Enforcement Forum West, May 2025
“SEC Enforcement: Key Takeaways from 2024 and What to Prepare for in 2025,” SMU Corporate Counsel Symposium, October 2024
“SEC Panel: Hot Topics and Recent Updates,” University of Texas Government Enforcement Institute, September 2024
“SEC Practice — Developments in Administrative Proceedings, Trials, Testimony, Wells Process, Settlements and More,” Securities Enforcement Forum West, May 2024
“Navigating SEC Cyber Disclosure Rules,” Society for Corporate Governance, December 2023
“Broker-Dealers - SEC & FINRA Enforcement Trends,” NSCP National Conference, October 2023
“Executive Compensation, Clawbacks, and Other Compensation Concerns,” Government Enforcement Institute, September 2023
“Crypto Assets and the Regulatory Landscape,” University of Houston-Houston Money Week, April 2023
“SPACs: Enforcement Techniques and Liability Theories,” Southwest Securities Conference, November 2022
“Conversations on Women’s Financial Literacy,” U.S. Securities and Exchange Commission’s Podcast, September 2022
“Developments in Alternative Investments panelist,” Southwest Securities Conference, March 2021
“How to Succeed in SEC Administrative Proceedings,” Bloomberg BNA Live Webinar, November 2015
Recognition
Since joining Kirkland, Sarah has been:
- Recognized by Chambers USA for Litigation: White-Collar Crime & Government Investigations (Texas), 2026
While at the SEC, Sarah was honored with the following awards:
- Individual Recipient, Ellen B. Ross Award, 2022
- Team Member Recipient, Chair’s Award for Investor Protection, 2022
- Inaugural Performance Incentive Bonus Award, 2021
- Annual Enforcement Director’s Award, 2017
Memberships & Affiliations
Fellow, Texas Bar Foundation
Associate Member, Higginbotham Inn of Court, 2014–2015
Credentials
Admissions & Qualifications
- Texas
Courts
- United States District Court for the Northern District of Texas
- United States District Court for the Eastern District of Texas
Education
- Southern Methodist University Dedman School of LawJ.D.cum laude2011
SMU Law Review, Comment and Casenote Editor, 2010–2011; Staff Member, 2009–2010
Dean’s Honors Scholarship Recipient
- University of Texas at Austin, McCombs School of BusinessB.B.A., Finance2006