Careers

Diversity, Equity & Inclusion

Experience

Innovation

Interactive Maps

Locations

About

Pages

Meet our team of innovators
Ask us how we do it

Professionals

Insights

Services

Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

Home | Thompson Hine LLP

Atlanta

Chicago

Cincinnati

Cleveland

Columbus

Dayton

Los Angeles

Minneapolis

New York

Silicon Valley

Washington, D.C.

On July 19, 2021, the Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) published a <a href="https://www.govinfo.gov/content/pkg/FR-2021-07-19/pdf/2021-15362.pdf" target="_blank" rel="noopener">final rule</a> adding six Russian entities to the Entity List after having been determined to be &ldquo;acting contrary to the foreign policy interests of the United States.&rdquo; The entities are:
<ul>
<li>Aktsionernoe Obshchestvo AST;</li>
<li>Aktsionernoe Obshchestvo Pasit;</li>
<li>Aktsionernoe Obshchestvo Pozitiv Teknolodzhiz;</li>
<li>Federal State Autonomous Institution Military Innovative Technopolis Era;</li>
<li>Federal State Autonomous Scientific Establishment Scientific Research Institute Specialized Security Computing Devices and Automation; and</li>
<li>Obshchestvo S Ogranichennoi Otvetstvennostyu NEOBIT.</li>
</ul>
These designations are related to President Biden&rsquo;s April 15, 2021, <a href="https://www.whitehouse.gov/briefing-room/presidential-actions/2021/04/15/executive-order-on-blocking-property-with-respect-to-specified-harmful-foreign-activities-of-the-government-of-the-russian-federation/" target="_blank" rel="noopener">Executive Order 14024</a> (&ldquo;E.O.&rdquo;) on &ldquo;Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation.&rdquo; This E.O. established a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of Russia against the United States and others, including: undermining free and fair elections; malicious cyber-enabled activities; transnational corruption; extraterritorial activities targeting dissidents or journalists; undermining security, international law and the territorial integrity of states. Shortly after the issuance of this E.O., the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) placed these six entities on its Specially Designated Nationals (SDN) List. See Update of <a href="https://www.thompsonhinesmartrade.com/2021/04/biden-imposes-new-sanctions-on-russias-technology-defense-and-financial-sectors/">April 19, 2021</a>. In also placing them on the Entity List, BIS stated that it is seeking to &ldquo;ensure the efficacy of existing sanctions on Russia that target aggressive and harmful activities by the Russian government.&rdquo;
Placement on the Entity List ensures that U.S. sanctions on these entities will apply to all items subject to the Export Administration Regulations (EAR) regardless of whether a U.S. person is involved in the transaction or whether the transaction involves the U.S. financial system. BIS has imposed a license review policy of a &ldquo;presumption of denial&rdquo; for these six entities. In addition, no license exceptions are available for exports, reexports, or transfers (in-country) to these six Russian entities. This final rule is effective as of July 19, 2021. However, shipments that were en route aboard a carrier to a port of export, reexport, or transfer (in-country) on July 19, 2021, pursuant to actual orders for export or reexport to a foreign destination, may proceed to that destination under the previous eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR).

BIS Adds Six Russian Entities to the Entity List

Services