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About Sarah Caruana

Sarah represents clients seeking efficient and strategic solutions to complex legal problems that span multiple jurisdictions.

As an Associate in Freshfields’ litigation and global investigations groups, Sarah represents clients in complex civil and criminal litigation in federal court.  She advises clients in connection with regulatory inquiries by various enforcement agencies, including the DOJ and the SEC. She also counsels clients with global operations on compliance with US statutes, including the Foreign Corrupt Practices Act and the Bank Secrecy Act.

Recent work

  • Joining Freshfields’ antitrust team to successfully litigate and defeat the FTC’s challenge to Evonik’s proposed acquisition of PeroxyChem (D.D.C.);
  • Defending corporate directors in shareholder securities class actions, shareholder derivative suits, and follow-on SEC investigations;
  • Advising a multinational hospitality group on its multijurisdictional response to an unprecedented cybersecurity breach;
  • Successfully resolving without penalty a DOJ inquiry into allegations of bribery by a multinational hospitality company in connection with government contracts in Latin America;
  • Representing multinational automobile and pharmaceutical companies in regulatory corruption probes;
  • Advising corporate monitor on compliance with the Bank Secrecy Act; and
  • Representing clients pro bono in immigration proceedings, including petitions for asylum and refugee status.


  • JD, Yale Law School
  • BA, summa cum laude, History, The University of Georgia


  • Served as a law clerk to the Honorable Richard Gergel of the United States District Court for the District of South Carolina in Charleston, South Carolina.
  • Admitted to practice in the District of Columbia, the State of New York, the United States Court of Appeals for the Fourth Circuit, and the US District Courts for the Southern District of New York, the District of Columbia, and the District of Maryland.