Sharon A. Rose

… is an experienced regulatory counsel and advocate in enforcement and litigation matters. She regularly represents corporations and individuals in investigations and proceedings before federal and state regulatory agencies and in related litigation, including the Department of Labor, Department of Justice, the Securities and Exchange Commission, the Commodity Futures Trading Commission, the Equal Employment Opportunity Commission, and the Federal Energy Regulatory Commission. She has extensive experience advising clients on issues related to compliance with the federal securities and commodities laws and other laws and regulations that impact corporate entities, including federal contractor obligations, the Employee Retirement Income Security Act (ERISA), the False Claims Act (FCA), the Foreign Corrupt Practices Act (FCPA), and federal and state employment laws. She has represented clients worldwide in matters involving alleged fraud, market manipulation, disruptive trading practices, insider trading, accounting and internal controls irregularities, and other financial and trading issues. In addition to matters before the federal government, she represents clients in enforcement proceedings and other inquiries by state regulatory agencies, regulated exchanges, the Financial Industry Regulatory Authority (FINRA), and foreign government agencies.

Sharon previously served as Senior Counsel in the Office of the Solicitor at the Department of Labor, where she advised the Office of the Secretary and Department agencies on a variety of regulatory, enforcement, and litigation matters. She was integrally involved in several key rulemakings and litigation actions within the Employee Benefits Security Administration (EBSA) and the Office of Federal Contract Compliance Programs (OFCCP), including those concerning fiduciary investment advice, ESG investing, proxy voting, QPAM exemptions, health and welfare benefit plans, and important reforms to OFCCP's procedures for non-discrimination enforcement actions. She routinely liaised with DOJ and other executive branch departments on joint litigation matters and amicus briefs requested by the Supreme Court addressing first amendment and ERISA issues.

Prior to entering government service, Sharon practiced in the Washington, D.C. and Singapore offices of an international law firm. She subsequently co-founded a litigation boutique firm representing plaintiffs and defendants in government enforcement and litigation matters. She joined Berliner Corcoran & Rowe in 2022.

In her personal time, Sharon enjoys devoting time to several nonprofit organizations, including serving on the Board of Trustees of a private liberal arts college.

Representative Cases

• Advising U.S. companies on compliance with ERISA and federal contractor compliance obligations;
• Representing clients in investigations by the Department of Labor into alleged ERISA violations;
• Representing a national bank in an investigation by and settlement with the Department of Justice and Department of Housing and Urban Development's Office of Inspector General related to alleged False Claims Act and Financial Institution Reform, Recovery, and Enforcement Act violations, in connection with the bank subsidiary's servicing of federally insured reverse mortgage loans;
• Representing a corporate executive in an investigation involving alleged trade sanction violations;
• Defending a foreign private issuer in DOJ and SEC investigations and settlement negotiations involving alleged FCPA violations; 
• Representing an energy trading company in FERC investigations into alleged market manipulation and tariff violations, successfully concluding the investigations without enforcement action; 
• Obtaining permanent injunctions against mandatory FINRA arbitration for a broker-dealer;
• Representing senior executives of foreign corporations in DOJ and SEC investigations into potential FCPA violations; 
• Representing a public corporation and its executives in securities fraud litigation related to an accounting restatement, successfully obtaining dismissal with prejudice and defending against plaintiffs’ appeal to the Fifth Circuit;
• Representing financial institutions and commodities trading companies in investigations and proceedings by CFTC’s Division of Enforcement and the Intercontinental Exchange Market Regulation Staff;
• Representing ExxonMobil Pipeline Company in proceedings before the Federal Energy Regulatory Commission regarding rates for transportation of crude oil over the Trans Alaska Pipeline System;
• Advising U.S. and foreign issuers on compliance with the FCPA and various securities laws;
• Advising energy and commodities trading firms on market manipulation and regulatory issues under the Federal Power Act, the Natural Gas Act, and the Commodity Exchange Act;
• Advising energy clients on state regulatory issues, including divorcement statutes.

Prior to her legal career, Sharon was a Partner and Managing Principal of a multi-state registered investment advisor and estate planning firm and held registered securities principal and general securities representative licenses.