Sandhya “Sandy” P. Brown

• Handled numerous false advertising and substantiation matters spanning all sectors, such as technology, education, health, and financial services.
• Led the FTC’s first cases against leading app stores for unauthorized billing of kids’ in-app charges.
• Directed the FTC’s first cases involving emergent non-traditional lending products, such as merchant cash advances, income-share agreements, and buy now, pay later (BNPL).
• Directed the FTC’s first cases against the largest for-profit universities for false advertising, unlawful lead generation, and telemarketing violations.
• Directed the FTC’s first cases linking online dark patterns to theories of deception and unfairness.
• Directed the FTC’s COVID-19-era rapid response to false claims about PPP loan offerings.

Sandhya “Sandy” P. Brown concentrates her practice on federal and state consumer protection matters, offering broad experience across advertising, fintech, alternative lending, buy now, pay later (BNPL), payment platforms, digital assets, small business financing, subscription billing, artificial intelligence and AI-connected products, and education technology. Sandy’s two decades at the Federal Trade Commission (FTC) give her first-hand regulatory insight to help clients navigate complicated government investigations and enforcement matters.

Before joining Alston & Bird, Sandy served as an official in the FTC’s Bureau of Consumer Protection, Division of Financial Practices, where she drove strategy for complex investigations and novel cases. She routinely analyzed corporate compliance with federal consumer protection laws, including the FTC Act, Gramm–Leach–Bliley Act, Equal Credit Opportunity Act, Truth in Lending Act, Electronic Fund Transfer Act, Fair Credit Reporting Act, Restore Online Shoppers’ Confidence Act, and Consumer Review Fairness Act.

Sandy also led major FTC initiatives involving in-app choice architecture and dark patterns, small business financing, and online lead generation, and she spearheaded the renewal of FTC enforcement in the education sector. She regularly advised leadership on policy and enforcement and served as a key FTC spokesperson in congressional briefings, to industry groups, and to the media.

Over her career, Sandy has handled dozens of FTC cases and investigations that resulted in the agency securing over $1.5 billion in total judgments.

Bar Admissions

• District of Columbia
• Maryland (Inactive)

Education

• Georgetown University (J.D., 2004)
• Syracuse University (B.A., 1998)

Memberships