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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.

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On June 20, 2017, pursuant to four executive orders (EOs), the U.S. Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) subjected to U.S. economic sanctions more individuals and entities involved in the ongoing Crimean conflict between Russia and Ukraine. These actions were deemed necessary to counter attempts to circumvent current U.S. sanctions. Treasury Secretary Steven Mnuchin stated, &ldquo;This administration is committed to a diplomatic process that guarantees Ukrainian sovereignty, and there should be no sanctions relief until Russia meets its obligations under the Minsk agreements.&rdquo;
OFAC designated 38 individuals and entities under the Ukraine-related EOs, including:
<ul>
<li>Alexander Babakov, the Russian Federation&rsquo;s Special Presidential Representative for Cooperation with Organizations Representing Russians Living Abroad;</li>
<li>Oboronlogistika, OOO, the Russian Defense Ministry&rsquo;s sole executor for the procurement of goods, works, and services for maritime transport of military troops and freight on the territory of the so-called Republic of Crimea; and</li>
<li>The following seven banks for operating or assisting in financial transactions in Crimea: Tsmrbank, OOO; Taatta, AO; Joint Stock Company Black Sea Bank of Development and Reconstruction; Joint Stock Commercial Bank Rublev; Joint Stock Company Commercial Bank North Credit; IS Bank, AO; and VVB, PAO.</li>
</ul>
OFAC also identified a number of subsidiaries owned 50 percent or more by Transneft, which was made subject to the Sectoral Sanctions Identification (SSI) List on September 12, 2014 pursuant to EO 13662. Transneft and its 50 percent or more subsidiaries are subject to Directive 2, which prohibits U.S. persons from dealing in new debt of greater than 90 days&rsquo; maturity of sanctioned entities. The <a href="https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20170620.aspx" target="_blank" rel="noopener">complete listing of individuals and entities</a> is available on Treasury&rsquo;s website.
BIS has added 10 entities to the Entity List on the basis of 15 C.F.R. &sect; 744.11 (license requirements that apply to entities acting contrary to the national security or foreign policy interests of the United States) of the EAR. The 10 entities added to the Entity List consist of two entities in the Crimea region of Ukraine and eight entities in Russia. For a complete list of these entities, please see the <a href="http://www.thompsonhine.com/uploads/1345/doc/Federal_Register_-_Russian_Sanctions_-_Addition_of_Certain_Entities_to_the_Entity_List.pdf" target="_blank" rel="noopener">Federal Register notice</a>.

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OFAC and BIS Designate Additional Individuals and Entities Under the Ukraine/Russia-Related Sanctions