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Sarah Crowder advises companies on compliance best practices and enforcement risks arising under the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, U.S. and UK anti-money laundering laws, and other financial crime laws. Qualified in the United States and as a Solicitor of England & Wales, she is able to help companies navigate risks arising in both jurisdictions. She also has experience of other anti-corruption laws (e.g., France’s Loi Sapin II) and works with trusted local partners to deliver coordinated advice that takes into account the requirements of multiple legal regimes. Ms. Crowder’s compliance advisory practice includes helping multinational corporations develop and test the robustness of compliance programs, conduct risk assessments, conduct transactional and third party due diligence, navigate post-acquisition compliance integration projects, and deliver compliance training.

Anti-Corruption and Anti-Money Laundering Compliance

  • Led a year-long anti-corruption risk assessment of a healthcare business acquired by a Fortune 50 company, including in-depth reviews and site visits in key markets in the Middle East, South Asia, and Latin America.
  • Supported a post-acquisition compliance integration project in countries across Africa for a multinational consumer goods company.
  • Providing regular anti-corruption and anti-money laundering compliance advice to a multinational energy company, including in relation to several market entry assessments and M&A transactions.
  • Providing ongoing anti-corruption compliance support to a multinational pharmaceutical company, including by supporting anti-corruption risk assessments, advising on compliance policies and procedures, and providing advice on discrete issues.
  • Providing regular anti-corruption compliance advice to a mining company operating in West Africa.
  • Collaborating with French counsel and accounting firms to support coordinated anti-corruption compliance projects taking into account the U.S. FCPA, UK Bribery Act, and France’s Loi Sapin II.
  • Advising a global financial institution in connection with a review of payment messaging compliance controls and related interactions with UK, U.S., and European regulators.
  • Assisted companies at various levels of compliance program maturity in either developing and implementing new compliance programs or updating existing compliance programs to account for enforcement developments, evolving guidance from key enforcement authorities, emerging best practices, and new anti-corruption laws.

Business and Human Rights

  • Assisted a European-headquartered energy company in conducting human rights due diligence in relation to a significant joint venture, negotiating related contractual provisions, and developing broader human rights due diligence procedures for future M&A transactions.
  • Delivered human rights training to key personnel of a mining company operating in Central Africa, helped the company develop a plan of action to address key human rights issues, and provided advice on several related follow-up queries.
  • Advised companies on reporting requirements under the UK Modern Slavery Act and best practices for identifying and mitigating modern slavery risks in supply chains.

Internal and Government-Facing Investigations

  • Led an investigation into whistleblower allegations of improper practices for a multinational pharmaceutical company under investigation by the U.S. DOJ and SEC.
  • Advised a multinational pharmaceutical company on interactions with the UK SFO relating to whistleblower allegations of bribery.
  • Advised a European energy company on several FCPA matters, including investigations by the U.S. DOJ and SEC related to projects in North Africa.
  • Supported an internal investigation into a large-scale employee fraud for a European-headquartered consumer goods company.
  • Conducted an internal investigation into a whistleblower’s allegations of bribery in a Middle Eastern subsidiary of a multinational technology company.
  • Conducted an internal investigation into potential sanctions violations by a European affiliate of a multinational pharmaceutical company.

World Bank Suspension and Debarment Matters

  • Advised a European engineering company on interactions with the World Bank’s Integrity Vice Presidency and Integrity Compliance Office, including by supporting several internal investigations into World Bank-financed projects and advising on the development of a corporate compliance program.
  • Advised a Southeast Asia-based energy company on interactions with the World Bank’s Integrity Vice Presidency in connection with an investigation into alleged fraudulent practices, including by conducting an investigation into the allegations and developing a compliance remediation plan.
  • Global Investigations Review, "Women in Investigations" (2018)