Christopher J. Walsh
Chris Walsh focuses his practice on white collar criminal defense, government and internal investigations, and related civil litigation. He represents companies and individuals in matters involving allegations of fraud and misconduct, improper marketing of pharmaceutical products and medical devices, as well as potential violations of false claims and anti-kickback laws, anti-corruption laws, consumer protection statutes, and federal securities laws. In 2016, the Financial Times North America Innovative Lawyers report recognized Chris for his successful legal strategy that led to his client being freed after 30 years of wrongful imprisonment.
Chris is a graduate of Yale University and American University Washington College of Law, where he served as managing editor of the American University Law Review and competed as a member of the Moot Court Honor Society. Prior to joining the firm, Chris completed a one-year fellowship with the Honorable Diana E. Murphy, U.S. Court of Appeals for the Eighth Circuit.
False Claims and Anti-Kickback Investigations and Litigation
- Represents leading pharmaceutical manufacturer in declaratory judgment action against HHS-OIG relating to the company’s copay assistance programs.
- Represents private equity firm defending against qui tam suit alleging scheme with firm’s portfolio company to submit claims for medically unnecessary lab tests.
- Represents leading biopharmaceutical company in DOJ investigation alleging various kickback theories related to health care provider consulting arrangements and other company-sponsored programs.
- Represented major biopharmaceutical company in investigations by DOJ and state enforcement authorities alleging various theories of kickbacks to health care providers and false claims violations in connection with the company’s blockbuster Hepatitis C products.
- Represented health care services company and laboratory in qui tam suit alleging use of defective lab tests.
- Represented global health care device and supply company in qui tam suit involving alleged fraudulently obtained government contract.
- Represented pharmaceutical company in qui tam suit alleging payments to pharmacies violated the Anti-Kickback Statute.
- Represented pharmaceutical manufacturer at mediation with potential qui tam relator, settling claims prior to him initiating formal litigation.
- Represents pharmaceutical manufacturer under criminal investigation relating to sales and marketing practices; relationships with health care providers, pharmacies, and distributors/wholesalers; and other issues.
- Represents former Chief Commercial Officer of pharmaceutical manufacturer facing allegations of price fixing and collusion.
- Represented Gordon Caplan in “Varsity Blues” college admissions prosecution.
- Represented George Perrot in post-conviction proceedings resulting in his release after having wrongfully served nearly 30 years in prison. Mr. Perrot’s conviction was based on now-discredited hair microscopy technique, and his conviction was the first in the country to be overturned resulting from the FBI’s historic hair microscopy review. In 2016, the Financial Times North America Innovative Lawyers report recognized Chris for his successful legal strategy in this case.
- Represented former employee of technology company under criminal investigation for alleged scheme to fraudulently obtain US visas for overseas workers.
- Represents former Chief Executive Officer of Fortune 500 company under investigation for alleged accounting violations.
- Represented former General Counsel of public company under investigation alleging disclosure and accounting violations.
- Investigated and defended technology company against various federal securities allegations.
- Investigated and defended investment management firm against allegations surrounding the SEC’s “pay to play” rule.
- Investigated and defended hedge fund against insider trading allegations.
Anti-Corruption Investigations and Diligence
- Performs pre-investment anti-corruption diligence for private equity and venture capital firms, and advises firms regarding global anti-corruption policies.
- Conducted multiple proactive assessments of global anti-corruption risk exposure for life sciences companies.
- Conducted wide-ranging investigation of foreign bribery allegations connected to large multinational pharmaceutical company.
- Conducted investigation of political bribery allegations connected to portfolio company of leading venture capital firm.
- On behalf of investment manager, conducted internal investigation of subsidiary’s potential bribery of local government officials.
Other Representative Matters
- Represents Chief Executive Officer and director of leading agricultural producer and distributor in shareholder derivative action asserting breaches of fiduciary duty.
- Appointed as Special Assistant Attorney General for the Commonwealth of Massachusetts and represented the Department of Children and Families in appeal before the Massachusetts Court of Appeals.
- Represented leading vaccine research and development company in responding to Congressional inquiry relating to development of potential COVID-19 vaccine.
- Represented private school in connection with allegations of historical misconduct by former employee.
- Conducted investigation and represents Massachusetts Board of Bar Examiners in character and fitness evaluation for applicant to the Massachusetts Bar.
- Part of team that filed amicus brief on behalf of industry association in Supreme Court case North Carolina State Board of Dental Examiners v. Federal Trade Commission (U.S. No. 13-534).
- Conducted internal investigation of major consumer goods manufacturer in connection with allegations of fraudulent accounting practices.
- Represented global medical device company in wide-ranging consolidated state consumer protection action brought by various state Attorneys General.
- Advised private equity firm in connection with government subpoena concerning potential violations of false advertising laws.
- "FRE 2014 Amendments: Clarifying Certain Hearsay Exceptions," ABA Section of Litigation, Trial Evidence News & Developments (May 27, 2014).
- "Out of the Strike Zone: Why Graham v. Florida Makes it Unconstitutional to use Juvenile-age Convictions as Strikes to Mandate Life Without Parole Under § 841(b)(1)(A)," 61 American University Law Review 165 (2011).
- JD, summa cum laude, American University Washington College of Law, 2012; Order of the Coif; Managing Editor, American University Law Review; Moot Court Honor Society
- BA (History), Yale University, 2009
Admissions / Qualifications
- New York, 2013
- Massachusetts, 2012
- U.S. Court of Appeals for the First Circuit, 2017
- U.S. Court of Appeals for the Eleventh Circuit, 2020
- U.S. District Court for the District of Massachusetts, 2014
- The Best Lawyers in America (2022)