On Friday, OFAC issued its first designations under the new Hong Kong sanctions program imposed by E.O. 13936.

OFAC added 11 current and former Hong Kong government officials, including Carrie Lam, Hong Kong’s Chief Executive, to its List of Specially Designated Nationals (SDN List).  As a result, all property and interests in property of the designated officials in the United States or within the possession or control of U.S. persons must be blocked and reported to OFAC.  U.S. persons, companies, and financial institutions are also broadly prohibited from conducting business dealings with the designated officials.

U.S. companies that do business with Hong Kong’s government should ensure that they do not engage in direct or indirect business dealings with the sanctioned officials, which OFAC is likely to view as a violation of the E.O.  Foreign financial institutions that provide services to the officials should also examine their institutions’ potential exposure under U.S. secondary sanctions authorized under the Hong Kong Autonomy Act of 2020 (HKAA).

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