Two recent opinions released by the Department of Justice (DOJ) serve as a reminder that even under the strictly enforced Foreign Corrupt Practices Act (FCPA), payments to government officials are permissible in certain situations. Given how rarely DOJ issues such opinions and because each provides insight into DOJ’s current view of enforcement in particular scenarios, it is worth considering what can be learned from each opinion.Continue Reading FCPA Update: DOJ Opinion Procedure Releases Underscore That Payments to Officials Are Sometimes Permitted

Thad McBride
Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP), and the Foreign Corrupt Practices Act (FCPA). He also advises clients on anti-boycott controls, and assists companies with matters involving the Committee on Foreign Investment in the United States (CFIUS). Thad supports international companies across a range of industries, including aviation, automotive, defense, energy, financial services, manufacturing, medical devices, oilfield services, professional services, research and development, retail, and technology. Beyond advising on day-to-day compliance matters, Thad regularly assists clients in investigations and enforcement actions brought by government agencies, including the U.S. Department of Justice (DOJ), the U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department Directorate of Defense Trade Controls (DDTC), Customs and Border Protection (CBP), the U.S. Commerce Department Bureau of Industry & Security (BIS), and the Securities & Exchange Commission.
Examining the 3M Sanctions Settlement
In an article for Law360, I examined the recent settlement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and the 3M Company for nearly $10 million to resolve apparent violations of U.S. sanctions on Iran. Continue Reading Examining the 3M Sanctions Settlement
International Trade Enforcement Roundup – October 2023 Update

You are reading the October 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.Continue Reading International Trade Enforcement Roundup – October 2023 Update
International Trade Enforcement Roundup – September 2023 Update

You are reading the September 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.Continue Reading International Trade Enforcement Roundup – September 2023 Update
CFIUS Update: A More Refined Focus, Increased Risks
The U.S. government continues to aggressively monitor and impose restrictions on transactions deemed to threaten U.S. national security. Continue Reading CFIUS Update: A More Refined Focus, Increased Risks
International Trade Enforcement Roundup – August 2023 Update

You are reading the August 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.Continue Reading International Trade Enforcement Roundup – August 2023 Update
International Trade Enforcement Roundup – July 2023 Update

You are reading the July 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.Continue Reading International Trade Enforcement Roundup – July 2023 Update
Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury
On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S. sanctions, export controls, and other national security laws. Continue Reading Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury
[WEBINAR] Conducting Clinical Trials Outside the U.S.: U.S. and Foreign Rules, Regulations, and Guidance
We will speak at a Strafford webinar providing guidance to life sciences companies and research institutions that are conducting or considering conducting clinical trials outside the United States.Continue Reading [WEBINAR] Conducting Clinical Trials Outside the U.S.: U.S. and Foreign Rules, Regulations, and Guidance
[WEBINAR] Significant EAR Violations and BIS Policy Shift: Incentivized Voluntary Self-Disclosure, Third-Party Whistleblowing
I am looking forward to speaking on a panel at an upcoming Strafford webinar addressing the U.S. Department of Commerce’s recent policy shift that increases the incentives for companies to voluntarily self-disclose (VSD) possible EAR violations, particularly when “significant,” or risk serious penalties. Continue Reading [WEBINAR] Significant EAR Violations and BIS Policy Shift: Incentivized Voluntary Self-Disclosure, Third-Party Whistleblowing