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…
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 December 23, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”), in further implementation of Executive Order 13936 (“EO 13936”), to remove provisions that provide differential and preferential treatment for exports, reexports, and transfers of items to Hong Kong as compared to China. As a result of these changes, Hong Kong will be removed as a separate destination on the Commerce Country Chart and in other places…
On August 11, 2020, US Customs and Border Protection (CBP) published in the Federal Register a general notice [CBP Dec. 20-15] that notifies the public that, in light of the President’s Executive Order 13936 on Hong Kong Normalization, issued on July 14, 2020, suspending the application of section 201(a) of the United States-Hong Kong Policy Act of 1992 to the marking statute, section 304 of the Tariff Act of 1930 (19 U.S.C. 1304), with respect…