Sarah has deep expertise in the areas of Bank Secrecy Act (BSA) and anti-financial crimes compliance. She regularly represents financial institutions, financial services companies, and fintechs in designing and deploying payment technologies, including those related to money transmission, virtual currencies, electronic payments, and stored value. Sarah also counsels clients in assessing and measuring risks arising from financial practices in environmental, social, and governance (ESG) disclosures.
Sarah works with established and emerging fintech and crypto companies to determine the applicability of the BSA, U.S. anti-money laundering (AML), securities, and commodities laws to their business activities. Her clients include non-U.S. companies trying to understand how U.S. civil and criminal regulations might apply to their businesses, especially if they have a U.S. customer base. Sarah provides end-to-end counseling, advising her clients on the front end by flagging regulatory obligations and helping create effective compliance infrastructure to address these obligations and other risks. She also assists in licensing and registration applications, where necessary, including the New York State Department of Financial Services BitLicense. Sarah assists these same companies on the back end to respond to regulatory inquiries or Wells notices from federal and state financial regulators and law enforcement.
Sarah’s practice covers a wide spectrum of financial instruments, including convertible virtual currency (CVC), farm, utility, governance, security tokens, decentralized finance (DeFi), decentralized exchanges (DEX), decentralized autonomous organizations (DAO), staking, yield farming, nonfungible tokens (NFTs), and fractional NFTs (F-NFT). She has also helped clients evaluate cybersecurity and customer data privacy regulatory risks with the use and application of decentralized identities (DID) and decentralized governance, and attendant customer due diligence (CDD) and know your customer (KYC) considerations for BSA compliance. Sarah has evaluated regulatory implications for these products in the metaverse context.
Sarah’s securities enforcement practice encompasses market regulation, foreign registration and disclosure requirements, supervisory procedures, and sales practices. Her clients include corporations, financial services companies, and associated individuals with investigations and regulatory matters before multiple state and prudential regulators and law enforcement, including the U.S. Department of Justice, the Securities and Exchange Commission, the Office of the Comptroller of the Currency, the New York State Department of Financial Services, and the New York Attorney General’s Office. Sarah’s investigative experience covers a wide variety of criminal issues, including corporate and insider fraud, immigration fraud, mortgage fraud, insider trading, market manipulation, money laundering, terrorist financing, cybercrimes, and data privacy violations. She has litigated cases arising under the False Claims Act (FCA) and has experience with criminal tax investigations.
Admissions & Certifications
- New York
- Benjamin N. Cardozo School of Law, Yeshiva University, J.D., 2009
- The University of Chicago, B.A., 2003