You are reading the April 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.
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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.
FCPA Enforcement: New Corporate Enforcement Policy, Aggressive Enforcement, and Lessons Learned From Recent Resolutions
Please join us for a lively and timely discussion of recent FCPA enforcement activity on Tuesday, May 23, 2023 at 1pm ET/12pm CT.…
International Trade Enforcement Roundup – March 2023
You are reading the March 2023 edition 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 – March 2023
Department of Defense to Require Contractors Proactively Provide DCMA with Export Authorizations
On March 22, the Department of Defense (DOD) issued a proposed rule that would amend the Defense Federal Acquisition Regulations (DFARS) to require certain contractors to provide the Defense Contract Management Agency (DCMA) with relevant export authorizations (i.e., export licenses, exemptions, or exceptions). Currently, contractors are only required to make their export authorizations available for DCMA personnel to review at the contractor’s site. This rule would change that by shifting the burden to federal contractors.
Continue Reading Department of Defense to Require Contractors Proactively Provide DCMA with Export Authorizations
International Trade Enforcement Roundup – February 2023
You are reading Bass, Berry & Sims’ February 2023 edition of our Monthly 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.
February saw several interesting enforcement actions. From a Chinese “spy balloon’s” cross-country journey to the first anniversary of the war in Ukraine, the news of the day seemed to drive much of the enforcement activity. Let’s get into it!…
Continue Reading International Trade Enforcement Roundup – February 2023
International Trade Enforcement Roundup – January 2023
You are reading 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 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.
January saw a bevy of interesting enforcement actions and regulatory policy changes. A high-level former FBI agent was charged with sanctions violations, for the first time ever a North Korean national was extradited to the U.S. for money laundering to benefit designated persons, and yet another instance of Chinese espionage was thwarted. Let’s jump in!…
Continue Reading International Trade Enforcement Roundup – January 2023
International Trade Enforcement Roundup – December 2022
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 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
Register Now | FCPA Enforcement Update: Lessons Learned for Best Practices Webinar
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:
- Overview of FCPA
- Key Compliance Challenges
- Lessons from Recent Enforcement Actions
- Compliance Best Practices
The webinar will be held…
Russia, Ukraine: Update as of Friday, December 30
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.…
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FCPA Enforcement Update: Two Big Settlements to End the Year
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.…
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