OFAC Updates Hong Kong-Related Sanctions List: Multiple Individuals Moved to Non-SDN Menu-Based Sanctions List

US Updates Hong Kong-Related Sanctions List: Multiple Individuals Moved to Non-SDN Menu-Based Sanctions List

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) updated its Hong Kong-related sanctions list on July 17, stating that the expiration of Executive Order 13936 does not affect the continued applicability of the statutory accountability framework under the Hong Kong Autonomy Act.

According to OFAC, due to the expiration of the national emergency declared in Executive Order 13936, individuals who were only designated pursuant to that order and whose property was blocked pursuant to the International Emergency Economic Powers Act (IEEPA) have been removed from the SDN List. Meanwhile, individuals who remain subject to sanctions under the Hong Kong Autonomy Act have been added to the non-SDN menu-based sanctions list.

Background of the List Adjustment

OFAC explained that the expiration of the national emergency declared in Executive Order 13936 does not repeal the Hong Kong Human Rights and Democracy Act or the Hong Kong Autonomy Act. Therefore, relevant statutory sanctions may still apply, with adjustments only to the presentation of the list and the legal basis.

Affected Individuals

The newly added individuals to the non-SDN menu-based sanctions list include Cai Dafeng, Cao Jianming, Chen Guoji, Chen Dong, Chen Zhu, and Zheng Ruohua, among others. The OFAC entries specify the identities, birth information, locations, and sanctions measures applicable to these individuals under Section 6 of the Hong Kong Autonomy Act.

Legal Effect

According to OFAC, individuals who remain subject to the Hong Kong Autonomy Act will retain the corresponding sanctions consequences. Assets that were already blocked prior to July 14, 2026, will continue to be blocked. OFAC also stated that it will revise the Hong Kong-related sanctions regulations in future Federal Register notices to reflect the changes following the expiration of the national emergency.

Factual Boundary

This update is not a cancellation by the US of the accountability framework under the Hong Kong Autonomy Act, but rather an adjustment to the list structure following the expiration of the executive order. The evaluation of responsibility for Hong Kong officials and National People's Congress-related personnel should still be based on US legal documents, sanctions grounds, and subsequent regulatory announcements.