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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.

You are reading Bass, Berry, and Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone who may be interested.

December was a busy month! A highly complex Russian procurement network dismembered, a former Marine indicted, a government contractor sentenced to prison for export violations, and temporary denial orders (TDOs) galore! Let’s get into it.

Continue Reading International Trade Enforcement Roundup – December 2022

We look forward to presenting a webinar titled “FCPA Enforcement Update: Lessons Learned for Best Practices” for the Society of Corporate Compliance and Ethics alongside V. Channing Landreth, AVP Managing Counsel at Labcorp. We will cover:

  1. Overview of FCPA
  2. Key Compliance Challenges
  3. Lessons from Recent Enforcement Actions
  4. Compliance Best Practices

The webinar will be held

The Bass, Berry & Sims international trade team continues to monitor U.S. government action in response to Russia’s invasion of Ukraine. In the final months of 2022, the U.S. government added multiple individuals and entities to the Specially Designated Nationals (SDN) List and the Entity List (EL), froze assets of individuals, issued or revised general licenses, and took enforcement action against individuals and companies. This post summarizes new U.S. sanctions and export restrictions as of Friday, December 30. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Department of the Treasury and Department of State Designations

On December 22, the Department of the Treasury, Office of Foreign Assets Control (OFAC), in consultation with the Department of State, added 10 entities associated with the Russian Navy and/or the Russian maritime industry to the SDN List.

Continue Reading Russia, Ukraine: Update as of Friday, December 30

In the past several years there has been a significant decrease in Foreign Corrupt Practices Act (FCPA) enforcement efforts. Reports suggest that corporate criminal cases have decreased by roughly 50% since 2012. FCPA enforcement has dipped particularly dramatically – from more than 40 actions brought by the DOJ and/or SEC in 2019 to only 15 brought by the DOJ and/or SEC in 2021.

Continue Reading FCPA Enforcement Update: Two Big Settlements to End the Year 

You are reading Bass, Berry, & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone interested.

Following an active October, enforcement actions and regulatory policy changes slowed in November. With that said, the actions taken in November involved some novel topics and provide several insights to glean.

Continue Reading International Trade Enforcement Roundup – November 2022

On September 30, President Biden signed the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Extension Act of 2022, reauthorizing the SBIR and STTR programs through September 30, 2025.
Continue Reading Register Now | SBIR/STTR Program Reauthorization – Changes Are Coming!

You are reading Bass, Berry, and Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles and a bit of our insight to your inbox every month.

October 2022 was an active month for enforcement, with the Department of Treasury updating Committee on Foreign Investment in the United States (CFIUS) guidelines and the Departments of Justice (DOJ) and Commerce (DOC) taking multiple actions. To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our international trade team. We welcome your feedback and encourage sharing this newsletter with anyone who may be interested.

Continue Reading International Trade Enforcement Roundup – October 2022

On October 20, the Committee on Foreign Investment in the United States (CFIUS) released new, non-binding Enforcement and Penalty Guidelines (Guidelines). The Guidelines follow upon last month’s Executive Order linking CFIUS reviews directly to the president’s national security prerogatives. In particular, the Guidelines detail the following:

  • Categories of conduct that constitute violations.
  • Sources of information CFIUS relies upon to determine whether a violation has occurred.
  • The process for developing and imposing penalties.
  • Aggravating and mitigating factors that CFIUS evaluates when deciding whether to impose a penalty.


Continue Reading New CFIUS Guidelines Reflect Shift in Enforcement Posture

I will join Brian Mulier (Bird & Bird LLP) and Keith Huffman (SAP) to present a workshop titled “A Multi-Jurisdictional Discussion of Export Controls on China, Russia and Belarus: Contrasting US, UK and EU Restrictions” on Monday, November 14 from 1:30-5:00 pm at the London Forum on Global Econonic Sanctions being held at the Millennium Gloucester Hotel.

Continue Reading Register Now | A Multi-Jurisdictional Discussion of Export Controls on China, Russia and Belarus: Contrasting US, UK and EU Restrictions

I will join Lexia Krown, Vice President Global Trade Compliance at ESAB Corporation to present a workshop titled “The Ins and Outs of EAR Licensing Exceptions: How to Determine If, When and How They Apply” on Thursday, October 20 from 1:00-4:30 pm  ET as part of the ACI Proficiency Series: Export Administration Regulations.

Continue Reading Register Now | The Ins and Outs of EAR Licensing Exceptions: How to Determine If, When and How They Apply