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 March 16, 2021, the State Department identified 24 additional persons it determined are contributing to &ldquo;the failure of the People&rsquo;s Republic of China (PRC) to meet its obligations under the Sino &ndash; British Joint Declaration ... or Hong Kong&rsquo;s Basic Law&rdquo; and, as a result, the Department of the Treasury has sanctioned these persons. These actions were taken pursuant to the Hong Kong Autonomy Act (HKAA), which authorizes and imposes sanctions on foreign persons, entities and financial institutions contributing to China&rsquo;s actions to remove autonomy from Hong Kong. See Update of <a href="https://www.thompsonhinesmartrade.com/2020/07/president-trump-signs-the-hong-kong-autonomy-act-and-issues-executive-order-on-hong-kong-normalization/">July 16, 2020</a>. The HKAA requires the State Department to submit a report to Congress identifying such persons, the first of which was issued on October 14, 2020, and identified 10 Chinese and Hong Kong government officials. See Update of <a href="https://www.thompsonhinesmartrade.com/2020/10/state-department-issues-hong-kong-autonomy-act-report/">October 15, 2020</a>.
The <a href="https://www.state.gov/update-to-report-on-identification-of-foreign-persons-involved-in-the-erosion-of-the-obligations-of-china-under-the-joint-declaration-or-the-basic-law/" target="_blank" rel="noopener noreferrer">March 16 notice</a> is an update to the October 14 report, and identifies each foreign person and provides an explanation for why each individual was identified and a description of the activity that resulted in their being sanctioned. In most instances, the identified government officials are members of China&rsquo;s Standing Committee of the National People&rsquo;s Congress, which adopted the National Security Law that undermined freedoms of assembly, speech, press and reduced the autonomy granted to Hong Kong.
Concurrently, the Treasury Department&rsquo;s Office of Foreign Assets Control (OFAC) imposed sanctions on these same individuals and placed them on the <a href="https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210317" target="_blank" rel="noopener noreferrer">Specially Designated National (SDN) List</a>. OFAC has noted that the HKAA requires blocking sanctions on persons identified by the State Department and that the Treasury secretary must thereafter identify &ndash; and potentially sanction &ndash; any foreign financial institution that knowingly conducts significant transactions with such identified foreign persons.

State Department Issues Second Hong Kong Autonomy Report

Services