Hong Kong-related OFAC updates

The national emergency declared in E.O. 13936 of July 14, 2020 ("The President's Executive Order on Hong Kong Normalization") expired on July 14, 2026. OFAC clarified that the expiration does not repeal or otherwise affect the Hong Kong Human Rights and Democracy Act of 2019 (HKHRDA) or the Hong Kong Autonomy Act (HKAA) of 2020, both of which remain in effect. As a result of the expiration, OFAC removed from the SDN List all individuals whose property had been blocked solely pursuant to IEEPA authority under E.O. 13936. Of the 48 individuals delisted, 39 remain sanctioned under the HKAA and were concurrently added to OFAC's Non-SDN Menu-Based Sanctions List (NS-MBS List). Assets blocked prior to July 14, 2026 for these individuals remain frozen under the HKAA designation. The remaining 9 individuals were fully removed from OFAC's sanctions lists.