Sarah is responsible for global compliance and ethics operations at Booking Holdings, the world’s leading provider of online travel and related services in 220+ countries and territories through six primary brands:, KAYAK, Priceline, Agoda, and OpenTable.  Sarah’s areas of focus include overseeing the global compliance risk assessment process, managing the Compliance Standards and KPIs, and building the accountability framework at each of the Booking Holdings brands.

Prior to joining Booking Holdings, Sarah held senior level positions for several Fortune 500 companies, including serving as the first-ever Chief Compliance Officer for Arthur J. Gallagher & Co., as Senior Counsel for McDonald’s Corporation, and as Assistant General Counsel for Sears Holdings.  In her 20+ years as legal and compliance counsel, Sarah has developed and managed compliance and ethics programs designed to address global compliance risks with special focus on high risk markets.  Her areas of expertise include the following: anti-corruption/FCPA and UK Bribery Act; third party due diligence program creation and oversight; global sanctions/OFAC; self-disclosures to regulators and response to regulatory inquiries; data protection and privacy programs to meet GDPR requirements; enterprise-wide risk assessment and mitigation; global internal investigations; compliance hotline oversight, and global conflict of interest management programs. 

Sarah is a regular speaker on issues of international compliance and regulatory matters including anti-corruption and global sanctions, and acts as a guest lecturer at the University of Illinois, at both the undergraduate level and the College of Law.  Sarah received her J.D. from Indiana University School of Law and her bachelor’s degree from St. Louis University.