Anne K. Walsh Director 202-737-4592
Anne K. Walsh

Overview

With nearly 30 years of experience advising clients in the pharmaceutical and medical device sectors, Ms. Walsh is widely recognized as a national authority on FDA enforcement, compliance, and regulatory strategy. Her practice centers on guiding companies through the most complex and high-stakes challenges at the intersection of FDA law and government investigations.

Ms. Walsh regularly counsels clients navigating FDA inspections, warning letters, and product recalls, but her greatest strength lies in helping companies proactively prevent—or skillfully respond to—government investigations. She is a trusted advisor in high-risk matters involving the Federal Food, Drug, and Cosmetic Act, the False Claims Act, the Federal Trade Commission Act, and HHS-OIG’s exclusion authority. She has led dozens of internal investigations and negotiated successful resolutions with FDA, the Department of Justice, the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG), and other enforcement authorities.

In a testament to her expertise and reputation, Ms. Walsh was recently selected by HHS-OIG to serve as an Independent Compliance Expert—prevailing in a highly competitive selection process. In this role, she will conduct rigorous assessments of the subject company’s compliance systems and engagements over a five-year period.

Ms. Walsh’s regulatory acumen also informs her work on corporate transactions involving life sciences companies. She leads multidisciplinary teams in conducting regulatory due diligence for mergers, acquisitions, financings, and licensing deals. She frequently advises on valuation-related risks, negotiates favorable terms, and draws upon a global network of regulatory experts to address international concerns.

Before joining Hyman, Phelps & McNamara, Ms. Walsh served as Associate Chief Counsel at FDA’s Office of Chief Counsel. Her distinguished government service was recognized with numerous awards from FDA, DOJ, HHS-OIG, FDA’s Office of Criminal Investigations, and U.S. Attorney’s Offices nationwide.

Outside of work, Ms. Walsh is an avid Peloton rider (find her on the leaderboard as arlington_annie), a dedicated sports fan for professional and her daughters’ college teams, and a proud dog mom to her loyal cockapoo Cubbie.

Education & Admissions

Education

J.D., William & Mary Law School
B.A., Economics, College of William & Mary

Admissions

District of Columbia
New York

Experience

Successful Outcomes in Government Investigations

  • Settlement of a False Claims Act suit at an amount that was a 10-fold decrease from the government’s initial demand, on behalf of a contract manufacturer of medical devices marketing surgical instruments without FDA approval.
  • Dismissal of a civil qui tam matter against Orthofix, a medical device manufacturer, for marketing pain pumps outside the scope of its 510(k) clearance.
  • Declination of criminal prosecution for an OTC drug manufacturer related to allegations of off-label promotion of its product.
  • Declination to exercise exclusion authority by the HHS Office of Inspector General for a drug manufacturer based on a conviction related to off-label promotion.

Internal Investigations

  • Conducted a review of a global, publicly traded company’s response to allegations in the media involving the safety of the company’s medical devices, and prepared findings and recommendations for the corporate Board of Directors.
  • Led a multi-phased investigation in response to data falsification activities that occurred during an FDA inspection, including preparing responses to the FDA Form 483, conducting on-site interviews of current and former employees, and retaining and managing remediation activities by technical consultants.
  • Piloted an internal investigation at a mid-sized medical device manufacturer that was triggered by a disgruntled, former employee alleging nonconformances during the manufacturing process, prepared recommendations for improvements to the quality system and corporate culture, and advised on regulatory reporting obligations to FDA.

Corporate Transactions

  • Advised middle-market private equity firm on multiple acquisitions of contract research organizations, component manufacturers, and finished medical device manufacturers, and capitalized on strong international network of experts to conduct efficient foreign regulatory diligence
  • Advised Nichi-Iko Pharmaceutical Co., Ltd., the largest generic drug manufacturer in Japan by sales, in a $736 million deal to acquire Sagent Pharmaceuticals, Inc.
  • Provided advisory services to Owens & Minor on regulatory matters in acquisition of Halyard Health, Inc.’s Surgical & Infection Prevention business, at a purchase price of $710 million in cash.
  • Managed FDA diligence and prepared representations in credit agreements on behalf of lenders financing acquisitions involving life sciences companies.

Thought Leadership

Women’s White Collar Defense Association

    • Social Media Committee (2018 to present)
    • Washington DC Chapter Social Media Coordinator (2021 to present)
  • Food and Drug Law Institute
    • Compliance and Enforcement Conference, Planning Committee and Chair (2019) (2015 to 2020)
    • Annual Conference, Planning Committee (2021-2023)
    • 75th Anniversary Steering Committee (2023-2024)
  • International Bar Association, Co-Chair, Healthcare and Life Sciences Law Committee (2024-2026); Vice Chair (2022-2023); North American Regional Forum Liaison (2021)

Expert Witness

  • Successfully testified as an expert witness in arbitration involving the importation of medical devices into the United States.

Honors & Awards

  • Best Lawyers
    2024-2026
  • Who’s Who Legal: Life Sciences
    2021 2022 2024
  • Best Specialist Food & Drug Law Firm – USA
    North America Business Elite Awards
    2021
  • Leading Legal Mind in Life Sciences Licensing 
    Acquisition International Legal Awards
    2021
  • DOJ Attorney General’s Award for Exceptional Service
    DOJ’s highest award for employee performance
    2010
  • Award of Appreciation
    FDA Office of Criminal Investigations
    2010
  • Award of Recognition
    U.S. Attorney’s Office, E.D.N.Y.
    2010
  • Cooperative Achievement Award
    HHS Office of Inspector General
    2010
  • Group Recognition Award
    FDA
    2010
  • Commissioner’s Special Citation
    FDA
    2009
  • Award of Recognition and Appreciation
    U.S. Attorney’s Office, N.D. Cal.
    2009
  • Outstanding Service Award
    FDA
    2008

Speaking Engagements

  • Leadership Panelist, Women’s White Collar Defense Association Annual Meeting, March 3-5, 2025
  • Co-chair and Speaker on various panels, IBA Annual Conference, September 15-20, 2024
  • Panelist, ACI’s Summit for Women Leads in Life Sciences Law, Navigating Today’s Life Sciences M&A Landscape: Charting the Latest Trends and Challenges in Pharma and Biotech Dealmaking, July 25-26, 2024
  • Co-Chair and Speaker, 10th Annual IBA World Life Sciences Conference, May 29-31, 2024
  • Moderator, FDLI Webinar: Social Media Spotlight: FDA Compliance for TikTok, X, LinkedIn, and Other Content, April 18, 2024
  • Speaker, DIA Advertising and Promotion Regulatory Affairs Conference: Global Ad Promo and Enforcement Insights, March 12-13, 2024
  • Panelist, Women’s White Collar Defense Association Leadership Retreat and Annual Meeting: Around the World Hot Topics, March 4-5, 2024
  • Faculty Member, UVA Law School Annual National Trial Advocacy College, January 6-11, 2024
  • Speaker, FDLI Enforcement, Litigation, and Compliance Conference For the Drug, Device, Food, and Tobacco Industries, Breakout Session:  Mitigating Securities Violation Risks for Emerging Life Science and Novel Food Companies, December 6-7, 2023
  • Moderator, IBA Annual Conference, Promotion of Medical Products on Social Media, October 29 – November 3, 2023
  • Co-Chair/Participant, International Bar Association World Life Sciences Conference, 31 May – 2 Jun 2023
  • Speaker, FDLI 2023 Annual Conference, Corporations, DOJ, and Criminal Enforcement: Avoiding Pitfalls and Managing Risks, May 17-18, 2023
  • Co-Presenter,  FDANews Webinar: Medical Device Enforcement: Are You Up-to-Date on the Latest Developments?, April 20, 2023
  • Speaker, Women’s White Collar Defense Association 2023 Annual Meeting, February 28-March 1, 2023
  • Moderator, Holiday Networking for IBA Healthcare and Life Sciences Law Committee Members, December 14, 2022
  • Speaker, FDLI Enforcement, Litigation, and Compliance Conference: For the Drug, Device, Food, and Tobacco Industries, The Relationship Between Outside Counsel Investigations and Quality System Investigations, and What to Do when they Conflict, December 7-8, 2022
  • Session Chair and Panelist, International Bar Association Annual Conference, How Covid-19 has turned out to be a major accelerator for change in the healthcare and life sciences industries, October 30-November 4, 2022
  • Moderator, IBA Healthcare and Life Sciences Committee, Interacting with Governmental Agencies: Best Practices Around the World, September 9, 2022
  • Speaker, FDLI Annual Conference: Exploring Advanced Topics in Food and Drug Law,  Trends and Risks in Medical Device Enforcement and Litigation, June 14-15, 2022
  • Panelist, FDLI Annual Conference: Exploring Advanced Topics in Food and Drug Law, Unwinding Temporary Measures from COVID-19, including Emergency Use Authorizations (EUAs), May 18-20, 2021
  • Panelist,  IBA Healthcare and Life Sciences Committee, Promoting and Selling Healthcare Products During COVID: International Guideposts and Ethical Considerations, April 29, 2021
  • Panelist, FDLI Enforcement, Litigation and Compliance Conference: For the Drug, Device, Food and Tobacco Industries, The Future of EUAs: What Happens Post-Crisis, December 15-16, 2020
  • Panelist, International Bar Association: IBA 2020 – Virtual Together Conference, Med-tech M&A, November 23, 2020
  • FDLI 2020 Annual Conference, Top Cases in Food and Drug Law, October 6-8, 2020
  • FDLI Enforcement, Litigation, and Compliance Conference, December 11-12, 2019
  • DIA Global Clinical Trials Disclosure & Data Transparency Conference, US Regulatory and Policy Updates: FDA and Clinicaltrials.gov Developments, September 19-20, 2019
  • RAPS, Ask Me Anything, Risk Management Principles: A Global Perspective, March 2019
  • Q1 Pharmacovigilance & Drug Safety Conference, Compliance: Post-Market Approaches to Drug Safety from Adverse Event Reporting to Mandated Studies, March 12-13, 2019
  • Moderator, Food and Drug Law Institute Enforcement, Litigation, and Compliance Conference for the Drug, Device, Food and Tobacco Industries, Top FDA Enforcement Cases in 2018, December 12, 2018
  • Customer Centric Medical Information Conference, Interpreting New Guidance Based on Risk Tolerance, July 24-25, 2017
  • Customer Centric Medical Information Conference, Product Communication Consistent  With Label & First Amendment Considerations, July 24-25, 2017
Education

J.D., William & Mary Law School
B.A., Economics, College of William & Mary

Admissions

District of Columbia
New York

Practice Areas
Industries
FDA Regulatory Categories