Reed Smith Client Alerts

On August 7 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on 11 Hong Kong and Chinese governmental officials, including Carrie Lam, the Chief Executive of Hong Kong. These individuals were added to OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) for “undermining Hong Kong’s autonomy and restricting the freedom of expression or assembly of the citizens of Hong Kong.” 

It is said that the action is being taken as a consequence of the individuals’ roles in developing, adopting, or implementing the Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong Special Administrative Region and/or engaging in action or policies that threaten the peace, security, stability, or autonomy of Hong Kong.

It follows the recent signing of the Hong Kong Autonomy Act 2020 and Executive Order 13936, President Trump’s Executive Order on Hong Kong Normalization, on 14 July 2020; the latest in a series of U.S. measures in response to a perceived failure to maintain Hong Kong’s autonomous status and the use of “draconian national security legislation.”

The individuals that were designated are:

  • Carrie Lam, Chief Executive, Hong Kong Special Administrative Region (HKSAR)
  • Chris Tang, Commissioner of Hong Kong Police Force (HKPF)
  • Stephen Lo, Former Commissioner of HKPF
  • John Lee Ka-chiu, HKSAR Secretary for Security
  • Teresa Cheng, HKSAR Secretary for Justice
  • Erick Tsang, HKSAR Secretary for Constitutional and Mainland Affairs
  • Xia Baolong, Director of the Hong Kong and Macao Affairs Office of the State Council
  • Zhang Xiaoming, Deputy Director of the Hong Kong and Macao Affairs Office of the State Council
  • Luo Huining, Director of the Hong Kong Liaison Office
  • Zheng Yanxiong, Director, Office for Safeguarding National Security in Hong Kong
  • Eric Chan, Secretary General, Committee for Safeguarding National Security of the HKSAR