Sarah Razaq Sallis



Sarah Razaq Sallis advises broker-dealers, investment advisers, investment companies, financial institutions and public companies in private litigation and arbitration matters, as well as examinations, internal investigations and prosecutions by the Financial Industry Regulatory Authority (FINRA), the U.S. Securities and Exchange Commission (SEC), and state securities regulators.

As a former attorney in FINRA’s Department of Member Regulation, Sarah offers clients deep experience in FINRA and SEC rules, including those related to Exchange Act Rule 15a-6 exemption from registration for foreign broker-dealers, FINRA membership application rules, firm and individual disclosure obligations, suitability analyses, firm supervisory obligations, and the statutory disqualification of FINRA firms and individuals. While at FINRA, Sarah was also extensively involved in matters related to senior and other vulnerable investors, including the drafting of FINRA Rule 2165 (Financial Exploitation of Specified Adults). Her in-depth understanding and extensive experience allows her to guide clients through various complex sales practice issues, regulatory matters and general compliance with federal securities laws.

Sarah’s previous experience includes serving as an associate in the global financial services regulatory practice of a large international law firm. There, she advised foreign financial institutions on U.S. broker-dealer registration requirements. Sarah also interned in the Financial Institutions and Public Sector Fraud Unit of the Criminal Division of the U.S. Department of Justice, as well as with the Securities Industry and Financial Markets Association (SIFMA).


Legal Alerts

Legal Alert: Proposed Regulation BI coverage of retirement investors (March 5, 2019)
There is some debate about the intended scope of proposed Regulation BI (Best Interest) coverage in the case of retirement investors.The SEC explicitly contemplated that the proposal would be ...

Legal Alert: The best interest standard under FINRA’s suitability rule (February 26, 2019)
In connection with the US Securities and Exchange Commission’s proposed Regulation Best Interest, the Financial Industry Regulatory Authority (FINRA) has asserted (with some case law support from the ...

Legal Alert: Broker-dealers selling annuities - preparing for the best interest standard under New York’s amended Insurance Regulation 187 (February 14, 2019)
Broker-dealers selling annuity products in New York will soon need to comply with New York's recently amended Insurance Regulation 187 ( Suitability and Best Interests in Life Insurance and Annuity ...

Legal Alert: FINRA’s 529 plan share class initiative (February 7, 2019)
On January 28, 2019, the Financial Industry Regulatory Authority, Inc. (FINRA) launched its 529 Plan Share Class Initiative (the Initiative) to encourage member firms to self-report potential ...

Legal Alert: The SEC’s litigation against a firm for allegedly inadequate disclosure of shareholder service fees and 12b-1 fees (January 28, 2019)
During the past several years, the US Securities and Exchange Commission (SEC) has settled more than a dozen cases where the SEC alleged (with the firms neither admitting nor denying the charges) ...

Legal Alert: The other shoe has dropped - The SEC follows up with firms that didn’t self-report under the share class initiative (December 12, 2018)
The Share Class InitiativeOn February 12, 2018, the Division of Enforcement of the US Securities and Exchange Commission (SEC) announced the Share Class Selection Disclosure Initiative ...

Legal Alert: FinCEN, federal banking regulators push for private sector innovation in BSA/AML compliance (December 12, 2018)
On December 3, 2018, the US Department of the Treasury’s Office of Terrorism and Financial Intelligence, the federal depository institutions regulators1 and the Financial Crimes Enforcement Network ...

Legal Alert: Sleuthing Through State Elder Financial Exploitation Laws-A Morass for Broker-Dealers (June 7, 2017)
I. Introduction This legal alert is the first in a series addressing the ever-changing regulatory landscape relating to senior investors, state law, and a broker-dealer’s legal obligation, if any, ...

Legal Alert: Senior Investors Are the Focus of New “Principal Consideration” in FINRA Sanctions (May 8, 2017)
On April 10, 2017, the Financial Industry Regulatory Authority’s (FINRA) National Adjudicatory Council (NAC) introduced new Sanction Guidelines (Guidelines) which allow the NAC and FINRA staff to ...

Legal Alert: FINRA Is Ready to Lace-up and Focus on “Blocking and Tackling”: FINRA’s 2017 Priorities and Related Enforcement Actions (January 30, 2017)
As the football season was winding down, on January 4, 2017, the Financial Industry Regulatory Authority (FINRA) published its 2017 Annual Regulatory and Examination Priorities Letter.1 According to ...


Guardians of the (Compliance) Galaxy: Lessons from SEC and FINRA Enforcement (November-December 2018)
Practical Compliance and Risk Management
Compliance officers may not wear magic capes, don futuristic armor or waive supernatural hammers, but they do serve as generals in a firm’s army of compliance professionals (even if that army is ...

Getting Ready for the FINRA Seniors Rule (June 28, 2017)
Corporate Secretary
The SEC in March gave its approval for the Financial Industry Regulatory Authority (FINRA) to adopt FINRA Rule 2165 and related amendments to FINRA Rule 4512 to tackle the increasingly high-profile ...

FINRA Continues to Step Up Focus on Senior Investors (June 27, 2017)
In April 2017, the Financial Industry Regulatory Authority’s (FINRA) National Adjudicatory Council (NAC) introduced new sanction guidelines that allow the NAC and FINRA staff to consider the ...

FINRA Is Ready To Focus On 'Blocking And Tackling' (February 3, 2017)
As the football season was winding down, on January 4, 2017, the Financial Industry Regulatory Authority (FINRA) published its 2017 Annual Regulatory and Examination Priorities Letter. According to ...


In the News

B-Ds Cautioned to Eye Senior Investors, State Rules (June 9, 2017)
Compliance Reporter
Eversheds Sutherland (US) attorneys Holly Smith and Sarah Razaq Sallis are featured in this Compliance Reporter article discussing that compliance professionals working in the broker-dealer space ...

Areas of Practice (6)

  • Litigation
  • Broker-Dealer
  • Financial Services
  • Financial Services Litigation
  • Investment Adviser
  • Securities Enforcement & Litigation

Education & Credentials

Contact Information:
202.383.0874  Phone
University Attended:
The University of Texas at Austin, B.A., ampla cum laude
Law School Attended:
George Washington University Law School, J.D., with honors
Year of First Admission:
2013, District of Columbia; Virginia

Professional Activities

Steering Committee Member; Middle East Committee of the Section of International Law of the American Bar Association (2016-2017); and Member; International Financial Products and Services Committee of the Section of International Law of the American Bar Association

Member and Vice-Chair; Young Professionals Committee, Women in Housing & Finance, Inc. (2016-2017)

Spanish and French

Peer Reviews

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*Peer Reviews provided before April 15, 2008 are not displayed.

Documents (7)

Documents by this lawyer on

Washington, District of Columbia

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