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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 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

Please note that the content below was posted on October 2, 2025. We have since provided updated guidance on the topics discussed in this post here.

On September 29, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a new interim final rule that significantly expands the scope of U.S. export controls. Entitled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities and referred to by BIS as the “Affiliates Rule,” the rule is designed to close a longstanding loophole by extending restrictions to foreign affiliates of parties already subject to export restrictions, including those parties designated on the Entity List and the Military End-User (MEU) List.Continue Reading BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities

On July 28, various arms of the U.S. government announced concurrent export enforcement resolutions involving Cadence Design Systems, Inc. (Cadence), a California-based software and technology firm. Cadence will pay over $140 million in combined net criminal and civil penalties and forfeiture.Continue Reading Huge Export Penalty for U.S. Technology Company