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Primary Care Providers Win Challenge of CMS Interpretation of Enhanced Payment Law

With the help and support of the Tennessee Medical Association, 21 Tennessee physicians of underserved communities joined together and retained Bass, Berry & Sims to file suit against the Centers for Medicare & Medicaid Services to stop improper collection efforts. Our team, led by David King, was successful in halting efforts to recoup TennCare payments that were used legitimately to expand services in communities that needed them. Read more

Tennessee Medical Association & Bass, Berry & Sims

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Thought Leadership

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Thought Leadership Spotlight

Healthcare Transactions: Year in Review 2018Last year, CVS Health Corp. (NYSE: CVS) announced it would purchase health insurer Aetna Inc. (NYSE: AET) for $67.5 billion, a transaction that would be one of the biggest healthcare mergers in the past decade. The transaction raises an intriguing question: is this the beginning of a transformational shift in healthcare?

Recently, members of our healthcare group authored the Healthcare Transactions: Year in Review outlining 2017 M&A activity and drivers in the following hot healthcare sectors:

• Managed Care
• Hospitals
• Post-Acute Care—Home Health & Hospice
• Ambulatory Surgery Centers (ASCs)
• Healthcare Information Technology (HIT)
• Behavioral Health
• Physician Practice Management

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Thaddeus R. McBride


Washington, D.C.
+1 (202) 827-2959 TEL
+1 (202) 826-9864 FAX

Thaddeus R. McBride


Washington, D.C.
+1 (202) 827-2959 TEL
+1 (202) 826-9864 FAX
Washington, D.C.
+1 (202) 827-2959 TEL
+1 (202) 826-9864 FAX

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, and the Foreign Corrupt Practices Act (FCPA). He also handles matters in the increasingly regulated area of importation (CBP), 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, 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), the U.S. Commerce Department Bureau of Industry & Security (BIS), the Securities & Exchange Commission, and Customs and Border Protection.

Thad's practice includes:

  • International Trade – Counseling and training clients on compliance processes and procedures related to U.S. economic sanctions and embargoes, U.S. export controls, the FCPA and other anti-bribery regulations, U.S. anti-boycott controls, U.S. customs and other import controls, and U.S. anti-money laundering regulations.
  • Compliance & Government Investigations – Advising clients on internal investigations and due diligence, as well as representing clients in government investigations and enforcement actions involving issues related to economic sanctions and embargoes, export policies and practices, the FCPA and other anti-bribery laws, and anti-boycott regulations.


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

Society for International Affairs

First Tee of Washington, D.C. — Board of Directors


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Representative Experience

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Past Events

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Media Mentions

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Additional Thought Leadership


  • "How to Conduct Due Diligence with the FCPA in Mind," Corporate Counsel (November 3, 2014)
  • "Russia Sanctions: Iran Déjà Vu or Jamais Vu?," The Metropolitan Corporate Counsel (April 21, 2014)
  • "FCPA Overreach? Courts Address Personal Jurisdiction In Cases Against Foreign Defendants," The Metropolitan Corporate Counsel (May 2013)
  • "U.S. Sanctions on Iran: An Update," World Export Control Review (March 2013)
  • "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)

Media Mentions:

  • "Peregrine's Acquisition by Murata Unlikely to Generate CFIUS Static," PaRR Global (August 29, 2014)
  • "U.S. Agents Start Hunting for Sanctioned Russians' 'Shiny Toys'," Bloomberg News (May 14, 2014)
  • "New SEC Iran Sanctions Requirements to Ensnare Non-US Firms," PaRR Global (March 26, 2013)
  • "AT&T's Iran Link via America Movil Unlikely to Violate OFAC Regulations," PaRR Global (March 6, 2013)
  • "Supply Chain Concerns Rejected in CFIUS Review of A123," Financial Times (February 12, 2013)
  • "A123/Wanxiang: CFIUS Mitigation Labeled a 'Technical Fiction' by Advocacy Group," Policy and Regulatory Report (January 14, 2013)
  • "Anti-Bribery Bible: Experts Offer Advice for Making the Most of the FCPA Guidelines," InsideCounsel Magazine (January 1, 2013)

Speaking Engagements:

  • "How to Minimize Facilitation Risks Stemming from Related Parties, Foreign Affiliates, Joint Ventures and Subsidiaries," ACI's 5th Annual Economic Sanctions Boot Camp (December 4, 2014)
  • "Mergers & Acquisitions Under the FCPA: Adequately Addressing Due Diligence," Convercent Webinar (November 5, 2014)
  • "Brazil's New Anti-Corruption Law: Compliance and Enforcement Trends," Strafford Publications Webinar (October 21, 2014)
  • "International Encryption Control: Navigating Differing Regulations and Exceptions," Strafford Publications Webinar (August 19, 2014)
  • "Trade Controls Due Diligence: When, Where, and How to Review Business Partners and Transactions," Momentum Events Webinar (June 26, 2014)
  • "Doing Business in India: Anti-Corruption Best Practices," Momentum Events Webinar (May 29, 2014)
  • "U.S. Sanctions on Russia: What is Prohibited and How to Comply," Momentum Events Webinar (May 8, 2014)
  • "Export Controls and Cloud Computing: Complying with ITAR, EAR and Sanctions Laws," Strafford Publications Webinar (April 23, 2014)
  • "FCPA Risk Exposure in Your Compliance Program? An Inside Out Examination of the Gaps and Pitfalls That May Be Lurking in Your Compliance Program," Momentum Event's 2nd Annual Global Anti-Corruption Congress (March 21, 2014)
  • "Latest Iran Sanctions: Leveraging New Opportunities While Meeting Strict, Rapidly Changing Requirements," Strafford Publications Webinar (March 19, 2014)
  • "Complying with ITAR Requirements Amid Increased Enforcement," Strafford Publications Webinar (February 5, 2014)
  • "Brazil's New Anti-Corruption Law: FCPA Compliance is No Longer Enough," Strafford Publications Webinar (December 12, 2013)
  • "The Fundamentals of Complying with U.S. Sanctions Against Iran: An In-Depth Review of the Most Significant Restrictions, Case Law, Prosecutions and Settlements Affecting U.S. and Foreign Entities," Pre-Boot Camp Working Group at American Conference Institute's 4th Economic Sanctions Boot Camp (December 3, 2013)
  • "Brazil's New Anti-Corruption Law: Overview and Analysis," Practising Law Institute (November 12, 2013)
  • "Latest OFAC Sanctions on Syria, Iran and Burma," Strafford Publications Webinar (November 6, 2013)
  • "FCPA Compliance in Latin America," Practising 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 (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 (January 22, 2013)


Chambers USA — Nationwide, International Trade: Export Controls & Economic Sanctions (2013-2017)

Chambers Global — USA, International Trade: Export Controls & Economic Sanctions (2018, 2016)

Washington, D.C. Super Lawyers (2014-2017)

Representative Experience:

Economic Sanctions

  • Advised multinational financial institution in investigation and settlement of OFAC enforcement matter
  • Counseled multinational defense contractor in investigating possible sanctions violations caused by a third party representative
  • Assisted non-U.S. offshore drilling company conduct internal investigation of potential U.S. sanctions violations, including preparing a voluntary disclosure to OFAC
  • Represented multinational manufacturer investigate and disclose violations of U.S. sanctions on Iran
  • Advised U.S. medical devices company on obtaining OFAC licenses for exports to Iran under the Ag-Med program
  • 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 U.S. pharmaceutical company in investigation and disclosure to OFAC of possible sanctions violations

Export Controls

  • Represented 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)
  • Counseled U.S. oilfield services company on U.S. export law issues related to offshore drilling rigs
  • Advised automobile manufacturer on export compliance, including developing and presenting comprehensive compliance training to company's U.S. and non-U.S. personnel
  • Represented U.S. manufacturer in responding to and negotiating penalties in BIS enforcement matter
  • Advised U.S. research university on technology and deemed export issues related to non-U.S. students and faculty
  • Counseled U.S. defense contractor in internal review and revision of export compliance policies
  • Assisted multinational manufacturer understand and comply with technology export issues under EAR and develop compliance provisions for master services agreements
  • Developed risk-based approach to export compliance review for U.S. defense contractor

FCPA and Anti-bribery

  • Represented U.S. medical devices company in investigation by U.S. Justice Department (DOJ) and Securities and Exchange Commission (SEC)
  • Created detailed, risk-based compliance matrix for multinational manufacturer to use to determine audit location and priorities
  • Counseled U.S. defense contractor in internal investigation of alleged corruption in company's office in Middle East
  • Advised oilfield services company on FCPA compliance due diligence related to acquisition of non-U.S. company in West Africa
  • Assisted U.S. logistics company conduct internal review of corruption compliance issues in company's Asia operations
  • Counseled U.S. healthcare company on developing comprehensive anti-corruption compliance policy and procedures
  • Developed anti-corruption compliance processes and procedures for multinational financial institution
  • Delivered anti-corruption compliance training to employees and officers of multinational manufacturing company


  • Represented publicly traded Hong Kong entity in making CFIUS submissions in connection with acquisition of interests in U.S. natural resources
  • Counseled Chinese acquirer of U.S. technology assets throughout CFIUS process, including meeting with the Committee and preparing filing draft and final notices
  • Advised publicly-traded Canadian company on CFIUS implications of U.S. acquisition of defense contractor
  • Assisted Asian acquirer of U.S. energy interests understand and navigate CFIUS process and follow-up steps necessary to comply with CFIUS conditions


  • Advised U.S. construction services firm on preparing and submitting voluntary disclosure to U.S. Commerce Department, Office of Anti-boycott Compliance (OAC)
  • Helped major U.S. manufacturer understand and respond to potential boycott requests in letters of credit from Gulf States
  • Assisted financial services company 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 non-U.S. manufacturer develop anti-boycott compliance policies and training in reviewing and responding to potential boycott requests


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