Sarah E. Kim
Lawyers

Provides regulatory and compliance advice to investment managers in connection with their ongoing operations and investment activities.
Sarah provides regulatory and compliance advice to investment managers in connection with their ongoing operations and investment activities, including compliance with the Investment Advisers Act and Investment Company Act. She also advises corporations, banks, insurance companies and other financial institutions regarding exemptions under the Investment Company Act and Investment Advisers Act.
She served as a contributing editor for International Comparative Legal Guide: Public Investment Funds 2021, and co-authored the “USA” chapter.
Experience highlights
Recent Representations
- Millicom International Cellular $746 million global rights offering
- PayPal $3 billion notes offering and concurrent tender offer
- Morgan Stanley $2 billion subordinated notes offering
- Morgan Stanley $5 billion senior notes offering
- Arcos Dorados $350 million notes offering and cash tender offers
- Masco $1.5 billion credit facilities
- Natura $600 million notes offering
- PT Freeport Indonesia $3 billion notes offering
- AN2 Therapeutics $69 million IPO
- Banco Santander $2.75 billion senior preferred and non-preferred notes offering
- Reliance Industries $4 billion senior notes offering
- Mastercard €750 million senior notes offering
- Aptiv $2.5 billion senior notes offering
- Brookfield Properties $360 million refinancing for mixed-use Nashville complex
- Arcis Golf $375 million credit facilities
- Cellnex Telecom $600 million senior notes offering
Insights
Education
J.D., Harvard Law School
- cum laude
B.A., History, Yale University
Professional history
- Counsel, Davis Polk, 2015-present
- Senior Counsel, PNC Asset Management Group, PNC Bank, 2013-2015
- Regional Legal Counsel, Citi Private Bank, Citibank, Hong Kong Branch, 2002-2013
- Associate, Davis Polk, 1996-2002
Qualifications and admissions
- State of New York