Sarah Benbow

Herbert Smith Freehills (Melbourne)
Lawyer (Partner)

Sarah has more than 14 years’ experience advising on Australian, UK and European competition and consumer law matters. This includes representing clients subject to investigations, enforcement action and litigation and negotiating settlements with the ACCC. During her time in HSF’s London office, Sarah was a key competition law and regulatory adviser to Virgin Atlantic Airways, including in respect of its joint venture with Delta Airlines and the ground breaking securitisation of its regulated slot portfolio at Heathrow Airport. Sarah has advised a broad range of companies on the Australian consumer law, including ACCC enforcement action relating to misleading and deceptive conduct, breaches of the consumer guarantee provisions and unfair contract terms. She has particular expertise in relation to financial services matters including advising on cartel conduct relating to foreign exchange trading, precious metals trading and other financial services activities.Sarah has a Bachelor of Laws and a Bachelor of Economics from Murdoch University and a Master of Competition Law from New York University. Having a Post-Graduate Diploma in European Competition Law from Kings College and spending 3 years on secondment in London, Sarah has intimate knowledge of the EU competition landscape. Sarah originates from Western Australia but is currently based in our Melbourne office. She advises clients across both Victoria and Western Australia.

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Herbert Smith Freehills (Melbourne)
Herbert Smith Freehills (Melbourne)
Herbert Smith Freehills (Sydney)
Herbert Smith Freehills (Brisbane)
Herbert Smith Freehills (Sydney)
Herbert Smith Freehills (Melbourne)


130 Bulletin

Kaman Tsoi, Kate French, Sarah Benbow The Australian Competition Authority releases its final report on customer loyalty schemes with implications for all businesses that collect and use personal information


The recommendations in the ACCC’s final report on loyalty schemes have implications for all businesses that collect and use personal information The Australian Competition and Consumer Commission (ACCC) has released the final report and recommendations coming out of its market study into (...)

Liza Carver, Matthew Bull, Patrick Gay, Sarah Benbow The Australian Competition Authority issues an appeal against the Federal Court’s decision which try to dismiss the Competition authority proceeding in a acquisition (Pacific National / Aurizon)


On 27 June 2019, the ACCC announced that it has lodged an appeal to the Full Federal Court against the Federal Court’s decision. The ACCC stated that its appeal will focus on the ability of courts to accept undertakings given the ACCC’s concerns about the ability of access undertakings to resolve (...)

Patrick Sands, Sarah Benbow, Patrick Gay The Australian Federal Court dismisses an appeal by the Competition Authority against a judgement establishing market power in the pharmaceutical sector (Pfizer)


The Full Court of the Federal Court of Australia has dismissed an appeal by the ACCC against an earlier judgment in relation to pharmaceutical company Pfizer. While the Full Court upheld the single judge decision that Pfizer had not misused its market power or engaged in prohibited (...)

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