On March 16, 2021, the State Department identified 24 additional persons it determined are contributing to “the failure of the People’s Republic of China (PRC) to meet its obligations under the Sino – British Joint Declaration … or Hong Kong’s Basic Law” and, as a result, the Department of the Treasury has sanctioned these persons.

On December 23, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule in the Federal Register that removes Hong Kong as a “separate destination” under the Export Administration Regulations (EAR). This rule follows U.S. Secretary of State Michael Pompeo’s May 2020 announcement that Hong Kong no longer warrants treatment

On December 11, 2020, the Treasury Department submitted its first report to Congress under the Hong Kong Autonomy Act, stating that to date it has not identified any foreign financial institutions (FFIs) that have knowingly conducted a significant transaction with an identified foreign person under the Hong Kong Autonomy Act (HKAA). The Department of

On October 14, 2020, pursuant to the Hong Kong Autonomy Act (HKAA), the State Department submitted to Congress a report identifying foreign persons “who are materially contributing to, have materially contributed to, or attempt to materially contribute to the failure of the People’s Republic of China (China) to meet its obligations under the Sino-British Joint

On October 6, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published two final rules in the Federal Register, “Controls on Exports and Reexports of Water Cannon Systems” (“Water Cannon Controls”) and “Amendment to Licensing Policy for Items Controlled for Crime Control Reasons,” (“Licensing Policy Amendment”)

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” (

On July 14, 2020, President Donald Trump signed into law the “Hong Kong Autonomy Act” (H.R. 7440), which authorizes and imposes sanctions on foreign persons, entities and financial institutions contributing to China’s actions to remove autonomy from Hong Kong. Unanimously passed by both the House of Representatives and the Senate in early July, this new