Samantha Barrett Badlam
Samantha Barrett Badlam is counsel in the Litigation and Enforcement group of Ropes & Gray. She joined the firm in 2006. Samantha’s practice focuses in the area of white collar defense in criminal and civil matters. Samantha represents clients in the pharmaceutical, medical device, diagnostic laboratory, and dental industries who are facing Federal and State government investigations, in addition to providing extensive compliance advice to these clients. Samantha conducts internal investigations in all types of government and regulatory compliance matters including: potential violations of false claims act whistleblower and anti-kickback statutes and of anticorruption and anti-bribery statutes, including the U.S. Foreign Corrupt Practices Act, alleged health care fraud, alleged improper marketing of pharmaceutical products and medical devices for uses for which they have not been approved by the FDA (off-label marketing, pre-approval promotion), and alleged violations of deceptive trade practice statutes. She also dedicates a significant portion of her practice providing advice to clients on compliance matters, and has worked with clients in many sectors including health care, life sciences, energy, and financial services.
- Representing a major pharmaceutical manufacturer in a proactive litigation against HHS-OIG regarding the government’s interpretation of the Anti-Kickback Statute and patient assistance programs.
- Defending a major biotech company in a prosecution by the U.S. Attorney’s Office for District of Massachusetts alleging AKS and FCA violations related to patient assistance programs.
- Representing a major pharmaceutical manufacturer in a Texas State Attorney General consumer protection matter relating to the manufacturing and promotion of certain drugs.
- Leading multiple internal investigations for a medical device company focused on false claims act whistleblower matters, anti-kickback statutes, and alleged improper marketing and sale of devices.
- Representing a major pharmaceutical manufacturer in an investigation by U.S. Attorney’s Office for the Southern District of New York regarding the production and manufacturing of certain drugs including.
- Represented an international pharmaceutical company in a multi-state Attorneys General investigation into consumer protection violations related to alleged fraudulent marketing and promotional practices.
- Conducted an internal investigation for a major pharmaceutical company related to clinical trials.
- Defended a major pharmaceutical company in a federal health care fraud investigation alleging FCA and AKS violations.
- Advised a major pharmaceutical company on various compliance initiatives, including designing and executing an extensive U.S. compliance monitoring program.
- Represented major pharmaceutical manufacturer in multi-year wide ranging criminal and civil investigation into Food, Drug and Cosmetic Act allegations and kickback allegations.
- Represented Assistant General Counsel of a major pharmaceutical company in DOJ prosecution of obstruction and false statements charges.
- Leading multiple internal investigations for a major pharmaceutical company into alleged FCA and AKS violations.
- Represented a U.S.-based multinational medical device company in an industry-wide FCPA investigation.
- Represented Chairman and CEO of medical device manufacturer in DOJ investigation of potential off-label promotional activities.
- Defended a major medical device company in connection with alleged FCA claims, including obtaining a summary dismissal of a qui tam action filed in federal court in the Southern District of Texas.
- Conducting an internal investigation on behalf of a multinational oil & gas services company into allegations stemming from the Operation Car Wash Lava Jato investigation, which has attracted the interest of domestic and foreign regulators.
- Representing a senior executive of a professional services company in the energy sector in a DOJ and SEC investigation into the company’s activities in the Middle East and Africa for potential FCPA violations.
- Developed a comprehensive global anti-corruption compliance program for a multi-national exploration and production energy company based on global corporate-level and market-level anti-corruption risk assessments.
- Represented the former CFO of a multinational oil and gas company during a DOJ and SEC investigation into the company’s activities in Argentina through a Joint Venture Company for FCPA violations.
- Conducted compliance investigations related to the FCPA, UK Bribery Act, and internal compliance policies and procedures for a multinational oil & gas services company.
- Conducted proactive compliance reviews into anti-corruption related matters for a multi-national exploration and production energy company.
- Co-author, “A Guide To FCA Cooperation Credit For Life Sciences Companies,” Law360 (June 18, 2019)
- Co-author, “Anti-Corruption In Mexico: Reasons For Cautious Optimism,” Law360 (November 29, 2017)
- Panelist, “Modernization of Third-Party Risk Management,” Virtual Twenty-Second Annual Pharmaceutical and Medical Device Ethics and Compliance Congress (November 2, 2021)
- Speaker, “Data Analytics and AI to Detect and Defend Fraud,” HCCA Healthcare Enforcement Compliance Conference, Virtual (November 18, 2020)
- Speaker, “Key Considerations and Best Practices in Operationalizing Speaker Programs,” 21st Annual Pharmaceutical and Medical Device Compliance Congress, Virtual (November 4-6, 2020)
- Speaker, “Compliance Challenges Posed by Emerging Organizations,” 21st Annual Pharmaceutical and Medical Device Compliance Congress, Virtual (November 4-6, 2020)
- Speaker, “Patient Support Programs – Helping Patients Access Products” 20th Annual Pharmaceutical and Medical Device Compliance Congress, Washington, D.C. (November 7, 2019)
- Speaker, “Next Generation Anti-Corruption Compliance Programs: Transforming a Policy-Based Program to a Controls-Based Program,” Society of Corporate Compliance and Ethics 18th Annual Compliance & Ethics Institute, National Harbor, MD (September 17, 2019)
- Speaker, “Round Table Discussion: Anti-Corruption Initiatives in Mexico,” Ropes & Gray, Von Wobeser y Sierra and ICC México Round Table Discussion, Mexico City, Mexico (September 18, 2017)
- Co-Host, “The Trump Administration’s First 100 Days,” Roundtable Discussion, Washington, D.C. (May 9, 2017)
- Co-Host, “A Private Conversation About Data Privacy,” Roundtable Discussion, Washington, D.C. (March 22, 2017)
- Co-Host, “Challenges of Serving as In-House Counsel,” Roundtable Discussion, Washington, D.C. (March 1, 2016)
- JD, High Honors, University of North Carolina School of Law, 2006; Order of the Coif; communications editor, First Amendment Law Review
- BA (Political Science), Highest Honors, University of California, Berkeley, 2003
Admissions / Qualifications
- District of Columbia, 2007
- California, 2006
- U.S. Court of Appeals for the Second Circuit
- U.S. District Court for the District of Columbia
- U.S. District Court for the Southern District of Texas
- Washington, D.C. Super Lawyers Rising Stars (2016-2021)