On August 7, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 11 individuals for undermining Hong Kong’s autonomy and restricting the freedom of expression or assembly of the citizens of Hong Kong. These actions were taken pursuant to Executive Order 13936, “The President’s Executive Order on Hong Kong Normalization” (see Update of July 16, 2020). In announcing the sanctions, Secretary of the Treasury Steven Mnuchin stated that these individuals “have implemented policies directly aimed at curbing freedom of expression and assembly, and democratic processes, and are subsequently responsible for the degradation of Hong Kong’s autonomy.” He added, “The United States stands with the people of Hong Kong and we will use our tools and authorities to target those undermining their autonomy.” The individuals sanctioned are:

  • Carrie Lam, Chief Executive, Hong Kong Special Administrative Region (HKSAR)
  • Chris Tang, Commissioner of Hong Kong Police Force (HKPF)
  • Stephen Lo, Former Commissioner of HKPF
  • John Lee Ka-chiu, HKSAR Secretary for Security
  • Teresa Cheng, HKSAR Secretary for Justice
  • Erick Tsang, HKSAR Secretary for Constitutional and Mainland Affairs
  • Xia Baolong, Director of the Hong Kong and Macao Affairs Office of the State Council
  • Zhang Xiaoming, Deputy Director of the Hong Kong and Macao Affairs Office of the State Council
  • Luo Huining, Director of the Hong Kong Liaison Office
  • Zheng Yanxiong, Director, Office for Safeguarding National Security in Hong Kong
  • Eric Chan, Secretary General, Committee for Safeguarding National Security of the HKSAR

As a result of these designations, all property and interests in property of the individuals named above, and of any entities that are owned, directly or indirectly, 50% or more by them individually or with other blocked persons, that are in the United States or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. Unless authorized by a general or specific license issued by OFAC or otherwise exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or that take place within the United States that involve any property or interests in property of designated persons. The prohibitions include the making or receiving any contribution of funds, goods, or services benefiting any blocked person.

China’s Foreign Ministry quickly retaliated by sanctioning 11 U.S. congressmen and several non-governmental officials (NGOs), including: Sens. Patrick J. Toomey (Pa.); Tom Cotton (Ark.); Josh Hawley (Mo.); Marco Rubio (Fla.); Ted Cruz (Tex.); Rep. Christopher H. Smith (N.J);  Carl Gershman, president of the National Endowment for Democracy; Derek Mitchell, president of the National Democratic Institute; Kenneth Roth, executive director of Human Rights Watch; Daniel Twining, president of the International Republican Institute; and, Michael Abramowitz, president of Freedom House.