Thompson Hine LLP

Catch up on international trade law updates on our SmarTrade blog, including: 🔷 United States, Switzerland and Liechtenstein Agree to Framework Agreement on Reciprocal Trade On November 14, the United States, Switzerland and Liechtenstein agreed to a framework for negotiations on an Agreement on Reciprocal Trade. Once finalized, the actual agreement will result in investments by Switzerland and Liechtenstein in the United States over the next five years and reduce tariff rates by the United States on goods from these two countries. The framework seeks to address non-tariff barriers impacting the countries’ trade relationship. The parties also agreed to cooperate as to economic security matters. 🔷 White House Announces Details on U.S.-South Korea Trade Deal On November 14, the White House released a Fact Sheet providing details on the Korea Strategic Trade and Investment deal first announced in July 2025. The Fact Sheet provides an overview on issues related to South Korean investments in the United States, revisions to the level of U.S. Section 232 and reciprocal tariffs implemented on imports from South Korea, and other matters addressing non-tariff trade barriers and supply chain security. 🔷 OFAC Issues New and Amended Russia-related General Licenses On November 14, the Department of the Treasury's Office of Foreign Assets Control issued several new and amended general licenses authorizing limited transactions under previous sanctions involving Rosneft and Lukoil, Russia’s two largest oil companies. Read more and subscribe here: https://lnkd.in/gvycpDsG #tariffs #autoindustry #semiconductors #Russia #SouthKorea #Switzerland #Liechtenstein #ThompsonHine

Recent Self-Reporting Case Involving Potential FTO Payments Signals Urgent Compliance Risks for Global Companies Kodiak Gas reported in an SEC filing that an internal investigation found likely payments in Mexico to individuals linked to an FTO/SDGT—activity that began before its 2024 acquisition of its Mexican affiliate. The company engaged outside counsel to conduct a full review of the matter. Read more: https://bit.ly/47MhObc Authors: Mark Cipolletti I Brittain Shaw I Ben Sandlin

Texas Says Mini-TCPA Exempts Consent-Based Text Communications   Texas has provided new guidance on its telemarketing law, SB 140, indicating that programs sending texts only to people who clearly opted in are not “telephone solicitations,” and therefore would not need to register, post a $10,000 bond, or file quarterly reports under the State’s view. SB 140 otherwise requires registration, bonding, and reporting for businesses that text prospects or mixed lists without clear consent; enforcement would largely rest with the Attorney General, and litigation is ongoing. This update is most relevant for clients that market by text to leads or broad audiences without documented opt-in, and less urgent for programs limited to verified opt-in subscribers or current/former customers covered by the two-year, same-name carveout. Read more: https://bit.ly/3K7ozer Authors: Jenna Schneider I Kim Sandell I Steven Stransky #ThompsonHine #TCPA #MiniTCPA #TCPA

In this Dow Jones Risk Journal, Heidi B. (Goldstein) Friedman, a partner in our Cleveland office, examines how companies should prepare for California’s climate disclosure regime amid shifting definitions, ongoing litigation, and delayed rulemaking. Her article breaks down the scope of SB 253 and SB 261, highlights the California Air Resources Board’s evolving guidance and Q1 2026 rulemaking timeline, and underscores the real-world stakes of steep penalties despite CARB’s current emphasis on “good faith” compliance and enforcement discretion. Friedman outlines practical steps to get ready now—confirming thresholds and entity scope, aligning with TCFD, standardizing and validating GHG inventories under the GHG Protocol, planning for assurance, assessing climate-related financial risks, maintaining robust documentation, ensuring cross-reporting consistency, and closely tracking CARB updates. With CARB’s preliminary list identifying thousands of likely in-scope companies and parallel constitutional challenges unfolding, she urges businesses to adopt a proactive, streamlined approach that meets California’s requirements while leveraging work done for other regimes such as CSRD. As Friedman notes, a thoughtful strategy can both mitigate enforcement risk and add enterprise value in this new era of climate transparency. Read the article here ➡️ https://bit.ly/3JGRCWd (subscription required)

Thompson Hine was proud to host the RIA Merger Conference in our New York office, bringing together a full room of RIA owners, compliance leaders, and industry professionals, along with virtual participants, for an afternoon of conversations focused on the regulatory, compliance, and growth trends shaping today’s advisory landscape.   Our panels covered key topics including SEC and state exam priorities, anti-assignment considerations in change-of-control transactions, succession planning strategies, consolidation and joint ventures, and compliance challenges unique to advisory practices. Thank you to our panelists and attendees for making this a highly engaging and successful event. To view a recording of the panel discussions, visit our YouTube channel ➡️ https://bit.ly/4oHNsN2   #RegisteredInvestmentAdviser #InvestmentAdvisers #Compliance #MergersAndAcquisitions #ThompsonHine #NYCEvents #InvestmentManagement

USTR Announces One-Year Suspension of Section 301 Countermeasures Targeting China’s Maritime, Logistics, and Shipbuilding Sectors On November 13, the Office of the U.S. Trade Representative published a Federal Register notice announcing a nearly one-year suspension—until November 10, 2026—of countermeasures it had imposed under Section 301 of the Trade Act of 1974, as amended, on Chinese vessels and maritime transport operations. Read more here: https://lnkd.in/gFV9GHx7 #China #maritime #tariffs #USTR #Section301 #ThompsonHine

DOJ Announces Charges for False Country-of-Origin Claims and Tariff Evasion Through Undervaluation The Department of Justice (DOJ) in September announced the unsealing of an indictment charging two Colorado companies and three executives with a multiyear scheme to sell Chinese made forklifts to the U.S. government while falsely representing that the equipment was manufactured in the U.S. and compliant with the Buy American Act and the Trade Agreements Act. The charges span 27 counts, including conspiracy to commit wire fraud, wire fraud, making materially false statements, and conspiracy to defraud the United States. Read more: https://bit.ly/4ovylGe Authors: Francesca Guerrero I Brian Lanciault #ThompsonHine #TradeCrimes #DOJ #InternationalTradeLaw

Thompson Hine was proud to sponsor the 34th Annual Program in Law and Technology (PILT) Seminar at the University of Dayton School of Law focused on “The Ever-Changing Legal Tech Landscape: AI and More.” Our own Jim Butler and Julie Honor shared insights on data security policies and applying AI principles to governance frameworks. Steve Elleman has long served on the PILT planning committee, Jennifer Elleman, Steve Elleman and Jeffrey Metzcar joined the event to connect with fellow presenters, including representatives from the Air Force Materiel Command/IP Division and leading law firms. The Dine with Speakers event at Coco’s Bistro offered a fantastic opportunity to network with all attendees.

California and Oregon Take Action to Limit Private Equity Investment in Health Care Entities California and Oregon recently took action to limit the involvement of private equity investors in health care practices, continuing a growing trend among states concerned about how such ownership structures affect quality, cost and other aspects of health care practices by unlicensed individuals or entities. Read more: https://bit.ly/4qOctaB Authors: Cori Haper I Gabriella Fletcher #ThompsonHine #HealthCareLaw #PrivateEquity

Attorney-Only Closings in Georgia: Navigating e-Closings in CRE Deals Thompson Hine partners Sean Gordon and Stephen B. Schrock recently published, Attorney-Only Closings in Georgia: Navigating e-Closings in CRE Deals, which examines how Georgia, unlike most states, considers real estate closings to be the practice of law. The Georgia Supreme Court and State Bar have consistently held that only Georgia-licensed attorneys may prepare deeds and conduct closings. For commercial buyers and lenders accustomed to title-company closings elsewhere, this framework has significant implications for closing checklists, staffing and timelines—especially with the rise of e-closings. Read more: https://bit.ly/43ZI8Mv