Sara Sundaram

Sara is part of the white-collar crimes and dispute resolution practice of the Firm and has over 10 years of experience and focuses on the areas of disputes, internal investigations and compliance training, white-collar crimes, corporate and financial investigations, fin tech and financial matters and international sanctions.

She has assisted and advised several foreign investors, corporates and financial institutions on anti-corruption, anti-bribery issues, anti-money laundering, sanctions violations, and serious fraud investigations Sara advises multinational corporations and financial institutions on a wide range of cross border issues including regulatory compliance and setting up their payment’s operation in India.

She regularly advises several foreign and domestic clients on AML/ABAC compliance, regulatory compliance and trade sanctions and has handled internal investigations into compliance violations and whistle-blower complaints for corporations and financial institutions. She has considerable expertise in corporate governance, international sanctions, and international fraud related issues and regulatory compliance issues and financial crimes and Fintech.

Relevant Experience

• Assisted and advised one of the largest swiss aerospace technology corporations in an investigation concerning cross-border internal compliance and major corporate governance issues the regarding allegations concerning a tender with a government body alongside UK and UAE Counsels and advised on whistle-blower allegations into employee misconduct; including misappropriation, and kickbacks from vendors, FCPA violations.
• Advised a Swedish manufacturing company in a compliance investigation of its Indian operations and strategy into whistle-blower complaint for management misconduct. Assisted the Client in drafting a comprehensive ABAC Policy, Sanctions Policy and Compliance Training for the Indian Subsidiary and key managerial persons.
• Advised a Japanese media company in Anti-Bribery and Anti- Corruption diligence; for the acquisition of Tag Worldwide Holdings.
• Advised a leading US gas/chemical company in an ethics and compliance investigation w.r.t, a whistle-blower complaint covering issues ranging from governance, anti-corruption, to anti-trust violations in India. Advised on gaps in the client’s internal code of conduct as well as provided Policy framework on addressing governance and ABAC policy concerns and assistance in drafting Fair Disclosure Policy and Practice Guidance on Internal Controls, Ethics, and Compliance.
• Advised an Indian company in carrying out internal sanctions investigation and assisting the US DOJ in an investigation pertaining to transactions carried out in alleged violation of OFAC Sanctions targeting North Korea.
• Advised and assisted a German Client in respect of the Client’s suppliers in India and governance concerns arising from a new supply chain regulation law in Germany mandating setting up of a grievance mechanism/whistleblowing system in India.
• Advising a large pharmaceutical company on an internal investigation and whistle-blower complaint and assisting the AERB pertaining to Standard Operating Procedures qua Quality Assurance Tests.
• Regularly advising several large corporates and Banks on their ABAC Policy, Sanctions Policy and Compliance Training for their Indian Subsidiary and Key Managerial Persons
• Advising a Brazilian Fintech company to set up their payment operations in India. Advising an American corporate card and expense management company to set up their payment and business operations in India
• Regularly advised corporations and senior executives on dawn raid management and regulatory compliance qua ongoing criminal investigation by Central Bureau of Investigation (CBI), and Enforcement Directorate (ED).
• Advised and assisted a US based petrochemical company in carrying out internal investigation with into business practices of its Indian subsidiary in relation to potential regulatory and compliance issues under Indian local laws and to check the Indian subsidiary’s internal policies and compliance with the local laws.
• Advised several Indian business conglomerate, e-commerce companies and Banks on investigation process under the Prevention of Money Laundering Act, FEMA by Directorate of Enforcement on potential investigation and compliance strategy, dawn raids and risk management
• Regularly advise American Express, Cred, Google on e-commerce, fintech, and RBI/regulatory compliance issues and emerging technology aspects and a wide range of cross border issues including regulatory compliance.
• Advised and represented an investment bank in a criminal prosecution before the Special Company Court in the Serious Fraud Investigation Office (SFIO) investigations and trial in a case of a multi-crore corporate fraud and corruption.
• Advised an Indian stock exchange and representing its wholly owned subsidiary, against a foreign stock exchange and its subsidiaries before the Bombay High Court and before an arbitral tribunal in a dispute pertaining to unauthorised use of the stock exchange’s Index Derivative.
• Advised an Indian stock exchange before the Supreme Court against Securities and Exchange Board of India in a dispute pertaining to the interpretation of SECC Regulations 2012 and 2018
• Assisted and advised an Irish investor on issues arising out of a Seizure Order passed by the Directorate of Enforcement under FEMA and a subsequent order by Hon’ble High Court of Telangana at Hyderabad on possible recourses available to it with regards to under the Indian law.

Awards & Recognition

• Legal 500 Key Individual/Recommended 2023 (White Collar Crime)
• Legal 500 Key Individual/Recommended 2023 (Litigation)

Memberships

• Bar Council of Delhi, India
• Permanent Member, Delhi High Court Bar Association
• Member, Woman in White Collar Defense Association, India Chapter (WWCDA)

Publications

• Anti-Money Laundering Report 2023 (India)International Comparative Legal Guide ICLJ (India Chapter), 2023, Anti-Money Laundering Laws and Regulation India 2023’
• Anti-Money Laundering Report 2022 (India), International Comparative Legal Guide – Global Legal Group, May 2022
• Internal Investigation during Covid-19 and Understanding Cross Border Legal Assistance (August 2020, Doing Justice in a Post-Covid World)