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Sarah Crowder advises clients on a variety of ethics and compliance matters, including compliance with the U.S. Foreign Corrupt Practices Act and the UK Bribery Act, compliance with anti-money laundering laws, and adherence to international human rights standards. She has helped clients in various industries develop compliance programs, conduct risk assessments, conduct transactional and third party due diligence, navigate post-acquisition compliance integration projects, and deliver compliance training.
Ms. Crowder also helps clients navigate internal and government investigations involving allegations of corruption, export control and sanctions violations, fraud, and money laundering. She has handled numerous white collar 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 supporting investigations and enforcement matters, Ms. Crowder assists clients in suspension and debarment matters before the World Bank and other international financial institutions.
- Conducting internal investigations into potential violations of anti-bribery laws in various countries in Europe, the Middle East, Africa, and Asia, for clients in a range of industries.
- Advising 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 supporting the development of a corporate compliance program.
- Advising 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.
- Advising a European energy company on several FCPA matters, including investigations by the DOJ and the SEC related to oil and natural gas projects in North Africa.
- Advising a multinational pharmaceutical company on interactions with the SFO relating to a whistleblower’s allegations of bribery.
- Supporting an anti-corruption risk assessment of a French pharmaceutical company acquired by a multinational pharmaceutical company.
- Conducting an anti-corruption risk assessment of a multinational telecommunication company’s operations in Central and Eastern Africa.
- Supporting a post-acquisition compliance integration project in countries across Africa for a multinational consumer goods company.
- Providing anti-corruption compliance advice on a range of matters to a mining company operating in West Africa.
- Conducting an internal investigation into potential sanctions violations by a European affiliate of a multinational pharmaceutical company.
- Advising a global financial institution in connection with a review of payment messaging practices and related interactions with UK, U.S., and European regulators.
- Advising U.S. banks in connection with anti-money laundering investigations involving the DOJ, the OCC and FinCEN.
Pro Bono
- Representing a political dissident from the Democratic Republic of the Congo in defensive asylum proceedings.
Previous Experience
- Associate in the white collar practice at an international law firm in New York.
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)