On July 17, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced certain updates and changes to its Hong Kong-related sanctions program following the expiration of the national emergency declared in Executive Order (“EO”) 13936, The President’s Executive Order on Hong Kong Normalization. Key changes include: What Changed? OFAC explained that the expiration of EO 13936 does not affect the continuing validity of either the HKAA or the Hong Kong…
On April 28, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took a series of Iran-related actions as part of the Administration’s “Economic Fury” campaign of exerting maximum pressure against Iran. Specifically, OFAC (1) issued an alert warning of the sanctions risks of dealing with Chinese “teapot” oil refineries that process Iranian crude oil and (2) published FAQ 1249, which warns that “toll” payments to the Government of Iran (“GoI”)…
Hong Kong controls dual-use items under the Import and Export Ordinance (Cap. 60) and its corresponding subsidiary legislation, the Import and Export (Strategic Commodities) Regulations (Cap. 60G) (“IESCR”). On 17 September 2021, an order to amend the list of strategic commodities under relevant schedules to the IESCR came into effect. The amendments aim to align Hong Kong’s control list with international non-proliferation regimes, including the Wassenaar Arrangement. The Trade and Industry Department has provided guidance…
On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (the “CMIC EO”). This amends and replaces Executive Order 13959 (“EO 13959”) and revokes Executive Order 13974 (“EO 13974”) that restricted investments in certain “Communist Chinese Military Companies” (“CCMCs”). The main changes implemented by the CMIC EO and related public guidance are to (1) change the group of targeted…