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Sara Sundaram

Partner in the Disputes and White Collar Crime Practice at the Mumbai office of Cyril Amarchand Mangaldas. Sara specializes in the areas of 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.

She also advises several foreign and domestic Clients on 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.  She can be reached at sara.sundaram@cyrilshroff.com

From Compliance to Crime: Investigating CSR Misuse and Corporate Accountability in India

Summary: Corporate Social Responsibility (CSR) fraud has emerged as a significant and growing area of corporate misconduct in India, triggering a wave of internal investigations across organisations. This article examines India’s mandatory CSR framework, the patterns of fraud that have surfaced since its enactment and the consequent rise of corporate internal investigations as an essential governance tool.

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Beyond Strategic Autonomy: Is a Blocking Statue the Need of the Hour in the Age of Extraterritorial Sanctions

Summary: China’s recent invocation of its Blocking Rules against U.S. sanctions marks a significant moment in the evolving landscape of global sanctions law. As nations increasingly push back against the extraterritorial reach of unilateral sanctions, the question arises:  What does this mean for India? This article examines China’s move, its implications for the global…

Sanctions Compliance Beyond the 50% Rule: A Practical Guide for Indian Businesses

Summary: The 50% ownership rule has always been the cornerstone of sanctions compliance offering apparent certainty to entities navigating complex cross-border transactions. However, in recent years, global regulators have started looking beyond the ownership percentage, scrutinizing effective control and influence to determine sanctions exposure. This piece examines the evolving sanctions landscape across the US, UK & EU and provides Indian businesses with a practical, risk-based compliance framework to align with international enforcement expectations.

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Summary: This article is the second part of a two-part series, examining the implications of India’s Digital Personal Data Protection Rules, 2025, on internal investigations conducted by organisations and their legal counsel. While Part I addressed the foundational framework and the applicability of exemptions under the DPDP Act, particularly Section 17(1)(c); Part II focuses on the practical compliance obligations that Data Fiduciaries must navigate during internal investigations, including security requirements, breach notification protocols, data retention and erasure mandates, and cross-border transfer complexities.

Continue Reading Implications Of The Digital Personal Data Protection Rules, 2025:  Stoking Internal Investigations – Part II
Implications Of The Digital Personal Data Protection Rules, 2025:  Stoking Internal Investigations – Part I

Summary: India’s Digital Personal Data Protection Rules, 2025, effective November 13, 2025, have fundamentally transformed the regulatory landscape for internal investigations. This analysis is the first part in a two-part series examining the critical compliance challenges facing organisations and law firms navigating data-sensitive proceedings under the new regime.

Continue Reading Implications Of The Digital Personal Data Protection Rules, 2025:  Stoking Internal Investigations – Part I
Navigating the MSME Minefield: When Party Autonomy Meets Statutory Reality

Summary: The recent decision in GEA Westfalia highlights the importance of an exclusive jurisdiction clause in contracts involving MSMEs, particularly for determining the court with the jurisdiction to hear challenges to awards passed as part of the mandatory statutory arbitration under the MSMED Act.

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Summary: This blog examines the increased compliance challenges faced by Indian companies due to the introduction of EU sanctions. European financial institutions and trading partners strictly enforce these measures, often adopting a zero-tolerance approach to secondary exposure. Consequently, Indian businesses with links to European markets must conduct rigorous due diligence as they face the risk of being cut off from euro-denominated transactions or even delisted from European stock exchanges.

Continue Reading Emergence of the EU sanctions regime and their wide-reaching cross-border impact
Waste of an ODR process

Summary: The methods for appointment of arbitrators, as laid down by the Supreme Court, namely, mutual consent of the parties or pursuant to Section 11 of the Arbitration and Conciliation Act, 1996, were reiterated by the Bombay High Court in a Section 34 challenge. The petition relates to a financial institution unilaterally appointing arbitrator(s) through an ODR platform. The Bombay High Court sought statements from two ODR platforms, namely, Presolv360 and ADReS Now, on steps taken to ascertain whether the request for the appointment is lawful. It is imperative to have a carefully drafted arbitration clause to ensure that the outcome of arbitral proceedings involving an ODR platform aren’t nullified.

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The present US administration signed an Executive Order (“EO 14209”) in February, halting the enforcement of the Foreign Corrupt Practices Act (FCPA), pending new guidance to prosecutors. On June 10, 2025, the US Department of Justice (DOJ) issued new guidelines (“Guidelines”) on the enforcement of the FCPA, marking a significant shift in its approach to combating foreign bribery. These changes are a part of a broader strategy to recalibrate US anti-corruption efforts in line with national security interests and economic competitiveness.

Continue Reading Global, India implications of US DOJ resuming scaled-back enforcement against foreign bribery