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Sarah Crowder advises companies seeking counsel 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 global 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.
As a member of Covington’s Business and Human Rights practice group, Ms. Crowder advises companies on evolving developments and best practices related to the corporate responsibility to respect human rights, including in relation to supply chain due diligence and responsible sourcing, reporting and transparency obligations, and strategies for integrating human rights elements into existing compliance programs.
Ms. Crowder also helps clients navigate internal and government-facing investigations involving allegations of bribery and corruption, money laundering, export control and sanctions violations, fraud, and other forms of misconduct. She has handled matters before major international enforcement authorities, and she has been recognized by the Global Investigations Review as being among the leading women investigations practitioners worldwide. In addition to government enforcement matters, Ms. Crowder assists clients in suspension and debarment matters before the World Bank and other international financial institutions.
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.
July 10, 2020, Covington Alert
On 6 July 2020, the UK Government announced the creation of a new UK human rights sanctions regime, which is the first independent UK sanctions regime to be established under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA 2018”).
July 6, 2020, Covington Alert
On July 3, 2020, the U.S. Department of Justice’s (“DOJ” or the “Department”) Criminal Division and the U.S. Securities and Exchange Commission’s (“SEC”) Enforcement Division quietly released A Resource Guide to the U.S. Foreign Corrupt Practices Act, Second Edition (the “Second Edition”). The first edition of the Resource Guide (the “First Edition”) was ...
June 27, 2020
WASHINGTON—Covington represented Piramal Enterprises Limited (PEL) in the sale of a 20% stake in Piramal Pharma Limited (Piramal Pharma), a wholly owned subsidiary of PEL that will contain its pharmaceutical businesses, to CA Clover Intermediate II Investments, an affiliated entity of CAP V Mauritius Limited, an investment fund managed and advised by affiliated ...
June 2020, Global Investigations Review
June 3, 2020, Covington Alert
On June 1, 2020, the U.S. Department of Justice (“DOJ” or the “Department”) Criminal Division released an updated version of its Evaluation of Corporate Compliance Programs document (the “Guidance”), which serves as a reference for prosecutors in assessing corporate compliance programs in the context of DOJ investigations. The Department last revised the ...
April 27, 2020, Bloomberg Law
January 30, 2020, Covington Alert
It has been another strong year in anti-corruption enforcement, with 2019 meeting or beating the high-water mark for enforcement across a number of measurements.
August 23, 2019, Covington Alert
The Serious Fraud Office (SFO) released its much-anticipated cooperation guidance on August 6, 2019. The five-page document sets out the steps an organization can take to assist the SFO in an investigation and thereby maximise the organization’s chances of avoiding prosecution. The publication represents a welcome change in direction on the part of the SFO, ...
July 22, 2019
NEW YORK—Covington advised Bayer in a definitive agreement to sell the Dr. Scholl’s™ business to Yellow Wood Partners for a purchase price of $585 million. Bayer is a global enterprise with core competencies in the life science fields of health care and nutrition. Its products and services are designed to benefit people by supporting efforts to overcome the ...
June 2019, GIR Insight - Europe, The Middle East and Africa Investigations Review 2019
Accreditation: An extract from the 2019 edition of Europe, The Middle East and Africa Investigations Review. The whole publication is available at https://globalinvestigationsreview.com/edition/1001341/europe-the-middle-east-and-africa-investigations-review-2019.
April 3, 2019, Covington Alert
In March 2019, the U.S. Department of Justice introduced several changes to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“the Policy”). The Policy, originally incorporated into the Justice Manual in November 2017, outlines the Department’s position on mitigation credit that companies may receive for voluntary self-disclosure, full ...
Q1 2019, Covington Alert
It was business as usual for FCPA enforcement in 2018. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) collected a total of $1 billion from seventeen corporate defendants, including through their share of two high-value, multi-jurisdictional enforcement actions. DOJ also announced thirteen new FCPA prosecutions ...
Winter 2019, Covington Alert
It was business as usual for FCPA enforcement in 2018. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) collected a total of $1 billion from seventeen corporate defendants, including through their share of two high-value, multi-jurisdictional enforcement actions. DOJ also announced thirteen new FCPA prosecutions ...
Sarah Crowder Named to GIR's "Women in Investigations"
July 17, 2018
LONDON—Global Investigations Review has named Covington’s Sarah Crowder to the second edition of “Women in Investigations,” highlighting 100 female practitioners from across the globe. Nancy Kestenbaum and Mythili Raman were selected to the list’s first edition in 2015. The survey highlights a variety of women not previously recognized by the magazine—from ...
Women in Investigations 2018: Sarah Crowder
June 21, 2018, Global Investigations Review
Sarah Crowder was named to Global Investigations Review's "Women in Investigations 2018" list. Her profile can be found here.
May 17, 2018, Global Investigations Review
January 25, 2018, Covington Advisory
Our message this year is simple: FCPA enforcement is here to stay. Despite pre-election statements to the contrary, various senior officials in the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) have, over the past year, consistently reaffirmed DOJ’s and the SEC’s commitment to FCPA enforcement.
The Changing FCPA and CFPOA Landscape
April 27, 2016, Global Anti-corruption and Compliance in Extractive Industries: London
August 7, 2014, Covington E-Alert
- Global Investigations Review, "Women in Investigations" (2018)