The U.S. Office of Foreign Assets Control (OFAC), housed in the Treasury Department, administers a set of targeted sanctions tied to Hong Kong that emerged after Beijing imposed the National Security Law (NSL) on the territory in June 2020. The authorities flow primarily from Executive Order 13936 ("The President's Executive Order on Hong Kong Normalization," signed by President Trump on 14 July 2020) and the Hong Kong Autonomy Act (HKAA), Public Law 116-149, enacted the same day.
EO 13936 suspended or eliminated several preferences Hong Kong had enjoyed as a separate customs and travel territory under the U.S.–Hong Kong Policy Act of 1992, and it created a basis for blocking the property of persons determined to be undermining Hong Kong's autonomy or involved in implementing the NSL. The HKAA layered on secondary sanctions risk: foreign financial institutions that knowingly conduct significant transactions with sanctioned individuals can themselves be designated.
In August 2020 OFAC added the first tranche of designations to the SDN List, including then–Chief Executive Carrie Lam, Police Commissioner Chris Tang, Justice Secretary Teresa Cheng, and Hong Kong and Macau Affairs Office director Xia Baolong. Subsequent rounds in 2020–2021 added officials connected to the Standing Committee of the National People's Congress, the Liaison Office, and the national security apparatus in Hong Kong. The Biden administration maintained the program and added further names, and in 2021 issued a business advisory warning U.S. companies of risks operating in Hong Kong.
Practical effects include: all U.S.-jurisdiction property of listed persons is blocked; U.S. persons are generally prohibited from dealings with them; correspondent banking relationships are often severed by global banks fearful of secondary exposure. China retaliated with its own Anti-Foreign Sanctions Law (June 2021) and counter-designations against U.S. officials and NGOs. The program remains active and is periodically updated through OFAC's Recent Actions notices.
Example
In August 2020, OFAC added Hong Kong Chief Executive Carrie Lam to the SDN List under EO 13936, freezing any U.S.-jurisdiction assets and barring U.S. persons from transacting with her.