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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 September 15, 2022, the Department of the Treasury issued a <a href="https://home.treasury.gov/system/files/126/determination_09152022_eo14071.pdf" target="_blank" rel="noopener">Determination pursuant to E.O. 14071</a> that prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of quantum computing services to any person located in the Russian Federation. This determination will take effect on October 15, 2022, and excludes: (i) any services provided to an entity located in Russia that is owned or controlled by a U.S. person, or (ii) any services related to the wind-down or divestiture of an entity located in Russia that is not owned or controlled by a Russian person. In conjunction with this determination, the Office of Foreign Assets Control (OFAC) issued a related <a href="https://home.treasury.gov/system/files/126/determination_09152022_eo14024.pdf" target="_blank" rel="noopener">Determination pursuant to E.O. 14024</a>, which allows for sanctions to be imposed on any individual or entity determined to operate or have operated in this sector of the Russian Federation economy. Any such sanctioned individuals or entities will be placed on one of the OFAC sanctions lists.
In a series of <a href="https://ofac.treasury.gov/faqs/added/2022-09-15" target="_blank" rel="noopener">new FAQs</a>, OFAC states that the definition of the quantum computing sector of the Russian economy includes &ldquo;activities related to products and services in or involving the Russian Federation in research, development, manufacturing, assembling, maintenance, repair, sale, or supply of quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing.&rdquo; OFAC interprets this term to include any of the following services when related to quantum computing: infrastructure, web hosting or data processing services; custom computer programming services; computer systems integration design services; computer systems and data processing facilities management services; computing infrastructure, data processing services, web hosting services, and related services; repairing computer, computer peripherals, and communication equipment; other computer-related services; as well as the exportation, reexportation, sale, or supply, directly or indirectly, of quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing to or from the Russian Federation.
Finally, OFAC has amended several other FAQs which have previously been published regarding earlier Treasury determinations about accounting, trust and corporate formation, and management consulting services in the Russian Federation. These <a href="https://home.treasury.gov/policy-issues/financial-sanctions/faqs/updated/2022-09-15" target="_blank" rel="noopener">FAQs</a> have been revised to include and be responsive to the new determinations covering quantum computing services.

Treasury Issues Determinations on Quantum Computing Services in Russia

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