Thaddeus Rogers McBride: Lawyer with Sheppard, Mullin, Richter & Hampton LLP

Thaddeus Rogers McBride


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Experience & Credentials

Practice Areas

  • Government Contracts, Investigations & International Trade
  • Bid Protests
  • Claims
  • Contract Cost Accounting
  • Exports and Export-Related Controls
  • Foreign Corrupt Practices Act - FCPA
  • Intellectual Property Rights Under Government Contracts
  • Multiple Award Schedule Contracting
  • The False Claims Act and Related "White Collar" Issues
  • Aerospace and Defense
  • Energy
  • Financial Services
University Princeton University, B.A., 1995 Captain, Men's Soccer Team
Law SchoolBoston College Law School, J.D., cum laude, 2000 Editor, Third World Law Journal
Admitted2001, Maryland and District of Columbia

Mr. McBride is a partner in Sheppard Mullin's Government Contracts, Investigations & International Trade Practice Group and is resident in the firm's Washington, D.C. office.

Areas of Practice

Mr. McBride represents U.S. and non-U.S. companies and individuals in international trade regulatory, compliance, investigative, and enforcement matters involving:

· U.S. economic sanctions and economic embargoes (OFAC)

· U.S. export controls (ITAR, EAR, and others)

· The Foreign Corrupt Practices Act (FCPA)

· U.S. Anti-boycott controls (OAC and U.S. Treasury Department)

· The Committee on Foreign Investment in the United States (CFIUS)

· U.S. Customs and other import controls

· Anti-money laundering and other banking controls (FinCEN)

· USA Patriot Act requirements and compliance

· U.S. international trade enforcement and regulatory actions, including countervailing duties, antidumping, and other trade remedy proceedings



· Advised non-U.S. bank on compliance with U.S. sanctions on Iran, Sudan, and other countries and individuals

· Assisted non-U.S. offshore drilling company conduct internal investigation of potential U.S. sanctions violations, including preparing a voluntary disclosure to OFAC

· Performed compliance due diligence for U.S. private equity company seeking ownership of non-U.S. energy company with interests in Iran

· Counseled U.S. insurance company on procedures for minimizing U.S. sanctions compliance risks related to non-U.S. insured parties

· Advised U.S. medical devices company on obtaining OFAC licenses for exports to Iran under the Ag-Med program

· Represented non-U.S. financial institution in applying for and obtaining OFAC license

· Assisted U.S. financial services company understand and address sanctions compliance issues related to overseas lease of U.S. aircraft

· Counseled U.S. oilfield services company on compliance with U.S. sanctions on Burma (Myanmar)

· Represented U.S. research university in submitting voluntary disclosure to OFAC related to Cuba travel

· Counseled non-U.S. oil company on compliance with UN sanctions on Iran

Export controls

· Counseled automobile manufacturer on export compliance, including developing and presenting comprehensive compliance training to company's U.S. and non-U.S. personnel

· Advised U.S. defense contractor in conducting internal investigation and making voluntary disclosure of export violation to U.S. State Department Directorate of Defense Trade Controls (DDTC)

· Represented U.S. manufacturer in responding to and negotiating penalties in BIS enforcement matter

· Assisted non-U.S. engineering company understand and comply with technology export issues under ITAR and EAR

· Counseled U.S. oilfield services company on U.S. export law issues related to maintaining equipment on offshore drilling rigs

· Advised U.S. research university on technology and deemed export issues related to non-U.S. students and faculty

· Represented non-U.S. hotel operator on U.S. export and sanctions law implications of developing and operating hotel in Syria

· Assisted U.S. defense contractor in internal review and revision of export compliance policies

FCPA and anti-bribery

· Represented U.S. energy company in investigation by U.S. Justice Department (DOJ) and Securities and Exchange Commission (SEC)

· Assisted U.S. logistics company conduct internal review of corruption compliance issues in company's Asia operations

· Advised U.S. private equity firm on conduct of and response to internal investigation of potential corruption issues

· Represented U.S. defense contractor in internal investigation of alleged corruption in company's office in Turkey

· Counseled U.S. health care company on developing comprehensive anti-corruption compliance policy and procedures

· Advised oilfield services company on FCPA compliance due diligence related to acquisition of non-U.S. company in West Africa

· Delivered anti-corruption compliance training to employees and board of directors of U.S. educational organization


· Helped major U.S. manufacturer understand and respond to potential boycott requests in letters of credit from Gulf States

· Advised U.S. construction services firm on preparing and submitting voluntary disclosure to U.S. Commerce Department, Office of Anti-boycott Compliance (OAC)

· Assisted non-U.S. investment firm understand and comply with U.S. Anti-boycott obligations

· Counseled U.S. oilfield services company on conducting internal review of compliance with U.S. Anti-boycott law

· Represented U.S. financial institution in reviewing, responding to potential boycott requests

CFIUS and other experience

· Represented publicly traded Hong Kong entity in making CFIUS submissions in connection with acquisition of interests in U.S. natural resources

· Counseled large European security company on CFIUS process in acquisition of U.S. security firm

· Advised publicly-traded Canadian company on CFIUS implications of U.S. acquisition of defense contractor

· Assisted U.S. nuclear fuel company understand compliance obligations related to sharing nuclear technology with developing country government

· Counseled U.S. semiconductor manufacturer in NAFTA duty classification matter

· Advised U.S. policy and advocacy firm on registration requirements under Foreign Agents Registration Act (FARA)


· Leading international trade lawyer, Chambers USA, 2013

· Board of Directors, First Tee of Washington, DC


· American Bar Association - International Section, Committee on Export Controls and Economic Sanctions

· Society for International Affairs


· Co-author with Scott Maberry and Fatema Merchant, "FCPA Overreach? Courts Address Personal Jurisdiction In Cases Against Foreign Defendants," The Metropolitan Corporate Counsel, May 2013

· Chinese Outbound Newsletter - March 2013, March 11, 2013

· Co-author with Scott Maberry and Matthew Riemer, "U.S. sanctions on Iran: an update," World Export Control Review, March 2013

· Quoted in "Supply chain concerns rejected in CFIUS review of A123," Financial Times, February 12, 2013

· Co-author, "What Every Canadian Business that Exports Can No Longer Afford to Ignore: Canadian and U.S. Export Control Law Compliance," Bloomberg BNA International Trade Reporter, January 24, 2013

· Quoted in "A123/Wanxiang: CFIUS mitigation labeled a 'technical fiction' by advocacy group," Policy and Regulatory Report, January 14, 2013

· Quoted in "Anti-Bribery Bible: Experts Offer Advice for Making the Most of the FCPA Guidelines," InsideCounsel Magazine, January 1, 2013

· Quoted in "Sany Exec Hints Lessons Learned from Ralls Deal to be Implemented in Pending Transaction," Policy and Regulatory Report, December 11, 2012

· Co-author with Scott Maberry, "U.S. Sanctions Update: The Freeze Deepens In Iran And Syria; The Thaw Continues In Burma," The Metropolitan Corporate Counse l, October 2012

· Quoted in "Chinese Wind-Farm Group Sues Obama," The Wall Street Journal Asia, October 3, 2012

· Quoted in "Little-Known Regulator Takes Centre Stage," Financial Times, August 7, 2012

· Quoted in "7 Risks and Compliance Threats Facing In-House Counsel," InsideCounsel Magazine, July 1, 2012

· Quoted in "SEC Targets Execs, Auditors in Biomet FCPA Case," InsideCounsel Magazine, May 30, 2012

· Quoted in "Entertainment Lawyers Advise FCPA Review," Daily Journal, April 26, 2012

· Co-author with Mark Jensen, "Continuing The Trend: Biomet's FCPA Settlement," Law360, April 9, 2012

· Co-author with Cheryl Palmeri, "A Noble Pursuit? SEC Brings FCPA Charges Against Individual Oil Services Executives," Law360, March 20, 2012

· Co-author with Brian Weimer and Dan Brooks, "Key details of CFIUS 2010 annual report," Law360, January 25, 2012

· Co-author with Mark Jensen, "Clarity Required: US V. Banki," Law360, January 9, 2012

· Co-author with Bethany Hengsbach, "Prosecutorial Misconduct Stymies Justice Department in FCPA trials," Daily Journal, January 9, 2012

· Co-author with Curt Dombek and Reid Whitten, "Early Steps Toward a Streamlined Export Control System," World Export Control Review, December 2011

· Quoted in "U.S. Professor Loses Tech Transfer Appeal," World Export Control Review, November 2011

· Co-author with J. Scott Maberry and Mark Jensen, "Getting Specific About FCPA Compliance," Law360, June 29, 2011

· Co-author with Mark Jensen, "Buyer, when foreign, beware," The Deal Magazine, June 27, 2011

Global Trade Law Blog Postings

· "The FCPA in the News: Big Scoops, Real Fallout," September 5, 2013

· "State Department Issues Nuts and Bolts Guidance on Libya," June 6, 2013

· "U.S. Sanctions Target Russian Corruption, Human Rights Violations," May 7, 2013

· "Census Changes Foreign Trade Regulations: New Filing Requirements," April 2, 2013

· "Line in the Sand: Siemens Argentina Case Limits Personal Jurisdiction Under the FCPA,"March 8, 2013

· "Is China Getting Serious or Redirecting Responsibility? New guidance on Chinese Anti-Bribery Enforcement," February 14, 2013

· "Iran, China, and Prison: A Recap of 2012's Major Export Enforcement and Embargo-Related Criminal Cases," January 9, 2013

· "What's In the New FCPA Resource Guide: Some Welcome Clarity and Unexpected Muddling," December 6, 2012

· "Smaller FCPA Story But We're Sure You're Following It: DOJ Issues New Opinion Procedure Releases," December 6, 2012

· "Update on U.S.-Myanmar Relations: The Thaw Continues," October 19, 2012

· "CFIUS Update: President Blocks Ralls Transaction," October 19, 2012

· "CFIUS Sued by Chinese Investors," September 27, 2012

· "Iran, Syria Sanctions Strengthened by New U.S. Law," August 17, 2012

· "Department of Justice Obtains First Forfeiture Judgment Under the Kleptocracy Asset Recovery Initiative," July 11, 2012

· "BIS Creates a Temporary Holding Classification Number on the CCL," June 7, 2012

· "OFAC's (Very) Long Arm: GAM Settlement May Illustrate the ITR's Expanding Reach,"June 7, 2012

· "Peak Pressure: CISADA and NDAA Timeline," May 1, 2012

· "Continuing the Trend: Medical Device Maker Biomet Settles FCPA Charges For More Than $22 million," April 5, 2012

· "Myanmar Update: Recent Actions Increase Likelihood Sanctions Will Be Eased,"February 21, 2012

· "CFIUS Submits Annual Report to Congress," January 30, 2012

· "The FCPA in 2011: Five Answers and a Looming Question," January 18, 2012

· "State Department (Finally) Proposes Amendments to ITAR Brokering Provisions,"January 18, 2012

· "International Sanctions - Updates to U.S. Sanctions Laws in 2011," January 17, 2012

Government Contracts, Investigations & International Trade Blog Postings

· "Clarity Required: Iran Sanctions Convictions Reversed in U.S. v. Banki," December 9, 2011

· "Longest Prison Sentence Yet in FCPA Case," November 16, 2011

· "DOJ Targets FCPA and Anti-Trust Violations Jointly," November 16, 2011

· "Mind Your Own Businesses: UK Court Decision May Signal Pushback On Extraterritorial Enforcement of US Trade Laws," October 24, 2011

· "OFAC, BIS Double Up Flow Serve: What the Flowserve Settlement Says About Corporate Compliance Programs," October 24, 2011

· "Prison Time and Export Controls: University Professor's Case Illustrates Dangers of Ignoring Export Compliance," October 24, 2011

· "OFAC Settles Alleged Sanctions Violations for $88.3 million," September 19, 2011

· "Syria Update: Significant New Sanctions Imposed," September 19, 2011

· "Proposed Rule Details Major Changes to U.S. Export Controls," August 4, 2011

· "Trading Up: Newly Implemented North Korea and Libya Sanctions," July 15, 2011

· "Technology Exports: Uncertainty Around Form I-129 Persists," June 16, 2011

· "Federal Judge Upholds DOJ's Expansive Application Of FCPA," May 10, 2011


· "FCPA Compliance in Latin America," Practicing Law Institute Webinar, August 1, 2013

· "ITAR and EAR Compliance Review and Investigations - Conducting Internal Audits and Evaluating Whether to Disclose Potential Violations to Mitigate Penalties," Strafford Publications Webinar, June 26, 2013

· "Lost in the Clouds: How Do You Control the Export of Data to Anywhere When It's Stored Everywhere?" Moderator, ABA Section of International Law 2013 Spring Meeting, Washington, DC, April 24, 2013

· "Export Controls and Cloud Computing: Legal Risks - Complying with ITAR, EAR and Sanctions Laws When Using Cloud Storage and Services," Strafford Publications Webinar, April 2, 2013

· "Complying with ITAR Requirements Amid Increased Enforcement," Strafford Publications Webinar, February 19, 2013

· "Vetting Third Parties for Export Control Risks," American Conference Institute, Toronto, Canada, January 22, 2013

· "Iranian Sanctions Compliance Strategies," Strafford Publications Webinar, December 20, 2012

· "Foreign Corrupt Practices Act Pitfalls: How to Spot Them; How to Avoid Them," Government Contractor Dinner Series, San Diego, California, November 28, 2012

· "How to Comply with New Foreign, Dual and Third Country National Rules: Reconciling ITAR Requirements with Foreign Anti-Discrimination and Privacy Law Restrictions," American Conference Institute, Chicago, Illinois, October 24, 2012

· "Making Sense of Current and Proposed Brokering Rules: How to Comply with Part 129 of the ITAR," American Conference Institute, Chicago, Illinois, October 23, 2012

· "OFAC Sanctions on Syria, Iran, Yemen and Burma: Compliance Strategies," Strafford Publications Webinar, August 28, 2012

· "Identifying ITAR and EAR - Controlled Technical Data," American Conference Institute's National Forum on International Technology Transfers & Deemed Export Compliance, Washington, DC, September 2011

· "Global Competition," Chafee Center for International Business World Trade Day 2010, Smithfield, Rhode Island, June 2010

· "U.S. Trade Controls: Staying Compliant in a Challenging Economic Climate," Co-chair, ABA Section of International Law 2010 Spring Meeting, New York, New York, April 2010

· "Contract Provisions Addressing Compliance & International Boycotts," International Association of Drilling Contractors Risk Management Conference, Houston, Texas, October 2008


· Foreign Corrupt Practices Act: Focus on Latin America, February 15, 2013

· Lunch with your Government Contracts Lawyer, November 13, 2012, Compliance with the FCPA

· OFAC Sanctions on Syria, Iran, Yemen and Burma: Compliance Strategies, August 28, 2012, Meeting Strict and Rapidly Changing U.S. Sanctions Requirements

· Lunch With Your Government Contracts Lawyer, June 19, 2012, Current Export Control Compliance Issues

· FCPA Risks for the Private Equity Industry, June 13, 2012


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Shedding Light on CFIUS: Appeals Court Holds That CFIUS Review Lacks Constitutional Due Process
Mark L. Jensen,J. Scott Maberry,Robert L. Magielnicki,Thaddeus Rogers McBride,Brian D. Weimer, July 24, 2014
In a stunning ruling issued on July 15, 2014, the U.S. Court of Appeals for the D.C. Circuit held that review by the Committee on Foreign Investment in the United States (“CFIUS”) and the subsequent unwinding of the investment deprived the foreign investor of due process under the 5th...

Starving the Bear: The United States Restricts Exports to Russia
Thaddeus Rogers McBride,Cheryl Palmeri, April 11, 2014
The pressure on Russia continues to build. As we previously reported, throughout March, the United States and other Western powers implemented a series of sanctions against individuals and entities deemed to be involved in the political destabilization of Ukraine. Those sanctions were restricted...

Tech Company Shares Tech, Makes Self-Disclosure, Pays Penalty
Mark L. Jensen,Thaddeus Rogers McBride, April 11, 2014
On February 19, 2014, the U.S. Commerce Department announced that it had reached an agreement with Santa Clara-based Intevac, Inc. to settle allegations that Intevac violated U.S. export regulations governing exports of technology. Under the agreement, Intevac agreed to pay a civil penalty of...

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Thaddeus Rogers McBride

Eleventh Floor East, 1300 I Street, NW
WashingtonDC 20005-3314


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