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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.

On April 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Press Release describing a Notice of Proposed Rulemaking that would significantly reshape anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements across a wide range of financial institutions. Comments are due by June 9, 2026. 

Continue Reading FinCEN Proposed Rulemaking: Significant Revisions Centered on Risk, Effectiveness, and Supervisory Consistency

Recent “Made in USA” enforcement actions show that U.S.-origin claims continue to be an active enforcement priority for the Federal Trade Commission (FTC). On April 14, the FTC announced three enforcement actions and the closure of two investigations involving companies alleged to have overstated the domestic origin of their products. The announcement followed a March 13 Executive Order (the “EO”) calling for heightened scrutiny of purportedly false “Made in America” representations.

Continue Reading FTC Signals Renewed “Made in USA” Enforcement Focus Following Trump Executive Order

At the end of March, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a new Advisory urging financial institutions to heighten scrutiny of transactions potentially tied to healthcare fraud schemes targeting Medicare, Medicaid, and other federal and state healthcare benefit programs. The Advisory is accompanied by this press release.

Continue Reading FinCEN Advisory Warns Financial Institutions of Healthcare Fraud Targeting Medicare and Medicaid

On March 6, the Financial Crimes Enforcement Network (FinCEN) announced a historic $80 million civil money penalty against Canaccord Genuity LLC for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. FinCEN, which is part of the U.S. Treasury Department, has principal responsibility for administration of U.S. anti-money laundering (AML) and terrorist financing laws.

Continue Reading FinCEN Update: Huge Penalty on Broker-Dealer for Willful AML, SAR, and Due Diligence Failures

On February 11, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Applied Materials, Inc. (AMAT) and Applied Materials Korea, Ltd. (AMK) resolving allegations that the companies illegally reexported U.S.-origin semiconductor manufacturing equipment to China.

Continue Reading Export Enforcement Update: Huge Penalty Imposed for Semiconductor Re-Exports to China

On February 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $1.72 million settlement with IMG Academy, LLC (IMG) arising from apparent violations of OFAC’s counternarcotics sanctions program. OFAC is the U.S. government agency with primary responsibility for administering economic sanctions.

Continue Reading OFAC Enforcement Update: $1.72M Settlement Highlights Screening Gaps in Education, Similar Sectors

On January 7, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Order resolving allegations that Exyte Management GmbH (Exyte), a Germany-based company, committed 13 violations of the Export Administration Regulations (EAR) in China. The violations were committed by Exyte’s Chinese affiliate, Exyte Shanghai Ltd (Exyte China).

Continue Reading Export Enforcement Update: EAR99 “In-Country” Transfers Lead to Penalty

We hope everyone had a great holiday. 2026 is now officially off and running, and particularly in light of recent events, we want to briefly summarize current trade restrictions related to Venezuela. The landscape will almost certainly shift soon – and often – and we will provide updates as often as possible. Importantly, at present, there continue to be significant restrictions when doing business in and with Venezuela.

Continue Reading Update on Venezuela: Significant Trade Restrictions and Risks Continue

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently announced two separate enforcement actions against IPI Partners, LLC and Gracetown, Inc. for violations of Ukraine-/Russia-related sanctions. OFAC is the agency responsible for administering and enforcing U.S. economic sanctions programs.

These actions highlight OFAC’s willingness to scrutinize private equity and other investment