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OFAC Implements Hong Kong-Related Sanctions Regulations Pursuant to E.O. 13936

By Cortney Morgan, Grant Leach, Julia Banegas & Camron Greer on February 5, 2021
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The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published regulations in the Federal Register on January 15, 2021 to implement Executive Order 13936 (“E.O. 13936”), titled “The President’s Executive Order on Hong Kong Normalization.”  The President determined on July 14, 2020 in E.O. 13936 that Hong Kong was no longer sufficiently autonomous to justify special treatment under U.S. law, due to the implementation of the Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong Administrative Region (“National Security Law”). Additionally, E.O. 13936 directed the Department of Treasury to implement sanctions on persons undermining democracy in Hong Kong.

OFAC’s Hong Kong regulations formally block transactions prohibited by E.O. 13936 and establish the process by which persons and entities are added to OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”). On January 15, 2021 OFAC also added six (6) persons to the SDN List pursuant to E.O. 13936. These persons were found to have been involved in the implementation of the National Security Law and to be undermining democratic processes in Hong Kong. As a result, all property and interests in property of 50% or greater belonging to these persons—which are in the U.S. or held by U.S. persons—must be blocked and reported to OFAC.

OFAC stated in its final rule that the regulations “are being published in abbreviated form at this time for the purpose of providing immediate guidance to the public,” and that OFAC intends to supplement with “a more comprehensive set of regulations.” However, since the OFAC regulations are a published final rule, they are not impacted by the President’s “Regulatory Freeze Pending Review Memorandum” and are therefore in effect until amended or withdrawn.

Should you have any questions or concerns regarding OFAC’s Hong Kong-related sanctions, please contact Cortney Morgan or Grant Leach of Husch Blackwell’s Export Controls & Economic Sanctions team.

Photo of Cortney Morgan Cortney Morgan

An experienced attorney in the area of international trade and supply chain issues, Cortney advises foreign and domestic clients on all aspects of international trade regulation, planning and compliance, including import (customs), export controls, economic sanctions, embargoes, international trade agreements and preference programs.

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Photo of Grant Leach Grant Leach

Grant focuses his practice on international trade, international compliance, securities, mergers, acquisitions and general corporate matters.

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Photo of Julia Banegas Julia Banegas

Julia is an associate in the Washington, DC office of Husch Blackwell. She advises clients doing business in the heavily-regulated Government Contracts and International Trade sectors.

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Photo of Camron Greer Camron Greer

A trade analyst, Camron researches transitions in global trade policy and their impact on client business matters. Camron assists clients, attorneys and legal teams when trade, business and the law intersect.

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  • Posted in:
    Government and Public Policy
  • Blog:
    International Trade Insights
  • Organization:
    Husch Blackwell LLP
  • Article: View Original Source

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