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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.

  • Many medical products can be exported to Iran – so long as a license is obtained
  • Imposition of successor liability underscores importance of pre-transaction due diligence
  • OFAC enforcement, as in the past, continues to take a long time

In December 2017, the U.S. Office of Foreign Assets Control (OFAC) announced a penalty of $1.2 million against DENTSPLY SIRONA Inc. (DSI), one of the world’s largest manufacturers of dental products, for violating U.S. sanctions on Iran.  DSI, which is publicly traded in the United States, is based in York, Pennsylvania, and maintains operations around the world.Continue Reading U.S. Dental Supply Company Penalized for Violating Iran Sanctions

I am presenting a Clear Law Institute (CLI) webinar titled, “Hot Topics in U.S. Sanctions.” The United States continues to use economic sanctions and embargoes to limit trade with countries, entities, and individuals that are deemed to pose a threat to U.S. national security. Yet the sanctions maintained by the U.S. government can change quickly.

Post at a glance:

  • FinCEN imposes $8 million penalty against California’s biggest and oldest card club
  • Club failed to implement and maintain an effective anti-money laundering (AML) program and failed to detect, deter, and report suspicious transactions
  • Enforcement action serves as valuable reminder of scope of Bank Secrecy Act (BSA)

As mentioned in our prior AML Update, the U.S. Financial Crimes Enforcement Network (FinCEN) continues to aggressively enforce anti-money laundering and other financial crimes laws.

The latest target? California’s biggest and oldest card club, Artichoke Joe’s.Continue Reading Anti-Money Laundering Update: California Card Club Clubbed by FinCEN for AML Violations

In a November 10 article published by PaymentsCompliance, I commented on expanded sanctions the United States has imposed against North Korea. These newest sanctions prohibit access to the U.S. financial system for certain entities found to be aiding North Korea. In the article I note that, “the recent U.S. sanctions actions related to North Korea

This Post at a Glance:

  • FinCEN imposes $2 million penalty against community bank
  • Bank failed to conduct appropriate due diligence related to Mexican customer
  • Small banks, other financial institutions need to recognize obligations under Bank Secrecy Act

On October 27, 2017, the U.S. Financial Crimes Enforcement Network (FinCEN) announced a $2 million fine against Lone Star National Bank, an independent community bank in Texas, for “willfully violating” anti-money laundering (AML) requirements of the Bank Secrecy Act (BSA).  FinCEN, which is part of the U.S. Treasury Department, has a primary role in safeguarding the U.S. financial system against money laundering and other illicit uses.Continue Reading Anti-Money Laundering Update: FinCEN Makes Small Texas Bank Pay Big Fine for Violating Bank Secrecy Act

Thad McBride Provides Insight to The New York Times on CFIUS Raised Scrutiny of Foreign Investments in the U.S.In a November 8 article in the New York Times, I provided insight on increased scrutiny of foreign investments in the U.S by the Committee on Foreign Investment in the United States (CFIUS). Lawmakers recently introduced legislation that would expand CFIUS authority, at least in part due to lawmakers’ concerns about continuing Chinese investment

The Future of U.S. Sanctions on Iran | Webinar | Thad McBride: PresenterU.S. Sanctions on Iran continue to be in a state of flux.  Yet the opportunities in Iran mean that more and more companies are considering the possibility of entering the Iranian market.  The continued uncertainty regarding the future of U.S. Sanctions on Iran implies the need for international companies to be prepared for any possible

Thad McBride | Export Controls: Compliance Challenges and Best Practices | WebinarI am presenting a Clear Law Institute (CLI) webinar titled, “Export Controls: Compliance Challenges and Best Practices.” As the government continues to aggressively enforce its export laws, it is increasingly essential for exporters to understand the laws and their corresponding obligations. This webinar will explore the key challenges companies face when engaging in export transactions,

More Acquisitions May Be Blocked in the Future

Last month, asserting national security concerns, President Trump blocked a $1.3 billion acquisition of Oregon-based Lattice Semiconductor by a subsidiary of the Canyon Bridge Fund (Canyon Bridge), a private equity fund backed by Chinese investors.  This is one of the few instances to date in which a sale to a non-U.S. buyer of a U.S. company has been blocked under rules administered by the U.S. Committee on Foreign Investment in the United States (CFIUS).  Yet the facts of this matter suggest that more potential acquisitions are likely to be blocked in the future.Continue Reading CFIUS, POTUS Block Chinese Acquisition of U.S. Semi-conductor Maker

Over the past month, we have closely monitored efforts by the U.S. Congress to tie the president’s hands over sanctions on Russia.  Today, the president signed the Countering America’s Adversaries Through Sanctions Act (CAATSA or the Act), which will have a significant impact on numerous U.S. industries operating in Russia.  And Russia’s response to the legislation indicates that further tensions between the United States and Russia – and possibly additional sanctions on both sides – are likely to follow.
Continue Reading New Law Extends U.S. Sanctions Against Russia