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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.

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For a virtual panel discussion on March 23, I shared insight on issues facing in-house counsel relating to the increasing trade restrictions stemming from Russia’s invasion of Ukraine.

While sanctions and export controls have largely focused on Russia to date, companies should also prepare for the possibility of U.S. sanctions against China.  I explained that the U.S. has already put in place “broad authority to start imposing sanctions” against China, and could introduce sanctions and other restrictions to dissuade China from supporting Russia.Continue Reading Sanctions and Export Compliance Tips for Corporate Counsel Panel on Russia and Ukraine

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of April 11. This post supplements our previous summaries, which are available by following the links at the bottom of this page.

Commerce Expands Export Restrictions Against Russia and Belarus; Adds to List of Countries Exempt from the Foreign Direct Product (FDP) Rule.

On April 9, the U.S. Commerce Department, Bureau of Industry & Security (BIS) announced that it has expanded the license requirement for exports to Russia and to Belarus of Categories 0, 1, and 2 of the Commerce Control List (CCL). BIS also removed Belarus from eligibility for license exception AVS. BIS had previously established a license requirement for Russia and Belarus for categories 3 through 9 of the CCL.  See our posts from February 25 and March 3 on previous license requirements.Continue Reading Russia, Ukraine: Update as of April 11

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of April 7. This post supplements our previous summaries, which are available by following the links at the bottom of this page.

Commerce Issues Temporary Denial Orders Against Three Russian Airlines

Today, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued Temporary Denial Orders (TDOs) denying the export privileges of three Russian airlines – Aeroflot, Azur Air, and UTair.  In announcing this action, BIS stated that the three airlines are continuing to violate comprehensive U.S. export controls imposed on Russia.  The TDOs extend for 180-days and may be renewed.  The TDOs terminate the right of these airlines to participate in transactions subject to the Export Administration Regulations (EAR), including exports from the United States and re-exports from abroad.Continue Reading Russia, Ukraine: Update as of April 7

I recently provided comments for an article in Law.com examining how foreign companies that are continuing to operate in Russia can continue to pay employees while world leaders are imposing economic sanctions making the transfer of funds into Russia difficult. Making the situation more tenuous is the possible retribution that companies or individual employees may face by the Russian government if the company ceases operations entirely.

“We’re trying to read the tea leaves of what the Russian government is most concerned about when they have threatened foreign companies that have halted operations or pulled out of Russia,” I explained in the article. “I’m just not that concerned that Russia thinks, ‘Oh, no, society is going to break down if people can’t buy Coca-Cola anymore.’ But they may be concerned that if Coca-Cola has … 10,000 employees in Russia, and all of a sudden those people are unemployed, that those people … are going to be a threat to social order.”Continue Reading Impact of Economic Sanctions for Russian Companies and Employees

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of April 6. This post supplements our previous summaries, which are available by following the links at the bottom of this page.

United States Issues Expansive Restrictions on Russian Entities, Expected to Ban New Investment

On April 1, the Commerce Department added 120 entities in Russia and Belarus to the Entity List based on their activities in the Russian and Belarusian defense, aerospace, maritime, and other strategic sectors. Of these entities, 95 are designated military end-users, which makes them subject to the Russia Military End-User Foreign Direct Product Rule (Russia-MEU FDP Rule). As discussed in a previous update, the Russia-MEU FDP Rule significantly broadens U.S. export jurisdiction over items made outside the United States using U.S.-origin technology.Continue Reading Russia, Ukraine: Update as of April 6

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of April 1. This post supplements our previous summaries, which are available by following the links at the bottom of this page.

Commerce Department Updates List of Tainted U.S.-Origin Aircraft

On March 30, the U.S. Commerce Department, Bureau of Industry & Security (BIS) issued a press release to update the restrictions and prohibitions it announced on March 18 pertaining to U.S.-origin aircraft operated in violation of the Export Administration Regulations (EAR). Please see our blog post here for more details on that March 18 notice.Continue Reading Russia, Ukraine: Update as of April 1

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of Thursday, March 31 concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our previous analysis all of which are linked at the end of today’s content.

United States Targets Russian Sanctions Evaders in the Latest Round of Designations

On March 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the designation of still more entities and individuals as it expands sanctions against Russia. These parties have been designated as Specially Designated Nationals (SDN); as a general matter, U.S. persons are prohibited from conducting any transaction with an SDN.Continue Reading Russia, Ukraine: Update as of March 31

I am looking forward to presenting a panel titled “US Sanctions Update: Russia and Other Hot Topics” alongside Phil Smith of Booking.com on April 12, 2022.

The US government continues to aggressively implement and enforce economic sanctions. Russia is the current focal point, and has been the subject of an unprecedented, coordinated series of actions…

I am looking forward to joining Marc Latman and John McCarthy from SGR’s Aviation Team for another engaging webinar on Russian Sanctions for the Aviation sector. The webinar will take place on Thursday, March 31, 2022 from 8 A.M – 9 A.M PT / 11 A.M – 12 P.M. ET / 4 P.M – 5 P.M London and Dublin Time.

Through its March 18, 2022 press release, the U.S. Commerce Department, Bureau of Industry and Security (BIS) put the world on notice that it intends to vigorously administer the export restrictions it announced February 24 and again on March 2, 2022 related to aircraft and aviation-related items destined for Russia/Belarus. While the March 18 press release only lists 100 aircraft, it sets the stage for future listings that could cover a much larger number of aircraft and potentially aircraft engines. These restrictions could be applied to companies and individuals, regardless of nationality, anywhere in the world. Further, March 28, 2022 marks the end of the EU-mandated wind-down period for terminating existing aviation transactions with Russian airlines.Continue Reading [WEBINAR] Live Follow-Up Q&A on Revisiting Russian Sanctions for the Aviation Sector Post-March 28

From the Bass, Berry & Sims Blog Network
From the Bass, Berry & Sims Blog Network

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