On January 15, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published in the Federal Register final regulations to implement a July 14, 2020 Hong Kong-related Executive Order. In Executive Order 13936, President Donald Trump determined that Hong Kong was no longer sufficiently autonomous from the People’s Republic of China (China) to justify differential treatment under various U.S. laws and regulations due to increasingly denied autonomy and freedoms that China promised to the people of Hong Kong. For additional background, see International Trade Update of July 16, 2020.

The Hong Kong-related Sanctions Regulations are now codified at 31 C.F.R. part 585 (the ‘‘Regulations’’), and implement the provisions of Executive Order 13936. OFAC states that the Regulations are being published “in abbreviated form at this time for the purpose of providing immediate guidance to the public. OFAC intends to supplement this part 585 with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy.” As published, the Regulations set forth prohibitions, general definitions, and initial interpretations and license authorizations. The Regulations are effective as of January 15, 2021.