OFAC moves 39 Hong Kong officials to a second list as the 2020 emergency expires

Carrie Lam is off the Specially Designated Nationals List. She is still sanctioned. The Treasury Department's Office of Foreign Assets Control said the national emergency declared in Executive Order 13936 of July 14, 2020, the order that built the Hong Kong sanctions program, has expired, and that it has therefore removed from the SDN List those persons designated under that order whose property had been blocked solely under the International Emergency Economic Powers Act. Individuals who remain sanctioned under the Hong Kong Autonomy Act of 2020 were added to the Non-SDN Menu-Based Sanctions List instead. That list took 39 Hong Kong-related entries. Fourteen are vice-chairpersons of the 13th National People's Congress Standing Committee. The rest carry the titles they held when they were designated, among them chief executive of the Hong Kong Special Administrative Region, secretary for security, secretary for justice, commissioner of police, director of the Hong Kong Liaison Office, and director of the Hong Kong and Macao Affairs Office of the State Council.

Blocked property stays blocked. Assets frozen before July 14, 2026 remain frozen, and each of the 39 entries carries a note under section 6 of the Hong Kong Autonomy Act blocking all property and prohibiting all transactions, with an exception for the importation of goods. OFAC said the expiry does not repeal the Hong Kong Human Rights and Democracy Act of 2019 or the Hong Kong Autonomy Act, and that both statutes remain in effect. It said it intends to publish an amendment to the Hong Kong-Related Sanctions Regulations at 31 CFR part 585 to reflect the expiry, and that it is reviewing the frequently asked questions and guidance attached to the program.