Sarah Crowder

Sarah Crowder

Associate

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.

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Africa Compliance Minute Series – What Does DOJ’s Recent Guidance on Compliance Programs Mean for Companies Operating in Africa?

In a recent client alert, we explored the U.S. Department of Justice’s (“DOJ”) June 2020 update to its guidance on Evaluation of Corporate Compliance Programs (the “DOJ Guidance”). In this series of posts, our Africa Anti-Corruption Practice will be focusing on the key takeaways from the DOJ Guidance through the lens of companies operating in … Continue Reading

Africa Compliance Minute Series – Acting Early to Save You Later: The Importance of Taking Corrective Action During the Course of an Investigation

In a recent contribution to the CovAfrica blog, our Africa Anti-Corruption Practice outlined key considerations for handling internal investigations in Africa.  Here we take a deeper dive into one of the most important, and challenging, aspects of internal investigations – remediation, drawing on a longer article we recently published in Global Investigations Review’s 2020 Europe, … Continue Reading

Top Issues to Watch in Africa in 2020

Commencement of the AfCFTA. The landmark African Continental Free Trade Area (AfCFTA) is slated to go into force on July 1, 2020. When fully implemented, the trade agreement will eliminate tariff and non-tariff barriers, and substantially increase intra-regional trade to volumes worth over $3.3 trillion. Twenty-nine countries have deposited their instruments of ratification, and Eritrea … Continue Reading

Articulating the Business Case for Investing in Compliance Programs

In our experience, compliance professionals spend a significant amount of time and resources focusing on the “how” – designing, implementing, sustaining, and improving effective compliance programs. This focus is no doubt warranted given recent emphasis by enforcement authorities on the need for corporates to test the effectiveness of their compliance programs. However, we believe it … Continue Reading

Five Key Considerations For Handling Internal Corporate Investigations

Companies today face increasingly complex regulatory frameworks globally and intense levels of corporate scrutiny from government enforcement agencies around the world. As government agencies embrace sophisticated crime-busting technology and the world shrinks through greater inter-agency cooperation, there are more ways than ever for governments to identify misconduct and hold companies to account through criminal prosecutions … Continue Reading

Top Ten Issues to Watch in Africa in 2019

Africa’s Growth Prospects. Africa’s gross domestic product (GDP) is expected to grow at 3.8 percent in 2019, which is a significant improvement over last year’s regional growth rate of 2.6 percent. Excluding the continent’s largest economies (Angola, Nigeria and South Africa), which are growing collectively at an average of 2.5 percent, the aggregate growth rate … Continue Reading

What Companies Need to Know About World Bank and African Development Bank Debarment (and How to Avoid It)

In March 2017, World Bank Group president Jim Yong Kim announced that the World Bank would provide a record $57 billion in financing for projects in sub-Saharan Africa in the 2018–2020 fiscal year period. Consistent with that commitment, the World Bank’s most recent annual report indicates that $19.8 billion was issued to partner countries and … Continue Reading

What Companies Need to Know About France’s Loi Sapin II Anti-Corruption Law

On June 3, 2018, French tycoon Vincent Bolloré warned investors that Groupe Bolloré—a logistics provider with extensive operations in former French colonies in Africa—may suffer negative commercial and financial consequences as a result of a corruption investigation initiated by French authorities. Mr. Bolloré was questioned for two days by French police in April 2018 over … Continue Reading
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