On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act  (“HKAA”) providing for the imposition of sanctions on foreign persons who materially contribute to the undermining of Hong Kong’s autonomy by the Government of the People’s Republic of China (PRC) and foreign financial institutions who engage in significant transactions with such foreign persons.  During a press conference announcing the signing of the HKAA, President Trump also indicated that he had signed an Executive Order ending Hong Kong’s preferential treatment under the United States-Hong Kong Policy Act of 1992.

The HKAA is part of the US response to the new national security law imposed on Hong Kong by the PRC.   The passage of the HKAA follows US Secretary of State Pompeo’s certification to Congress in May 2020, that Hong Kong is no longer sufficiently autonomous from the PRC to warrant its preferential treatment.  For detailed information on these developments, please see our prior blog posts here and here.

To read the rest of this article by Terence Gilroy, Inessa Owens and Andrea Tovar, please go to our Sanctions blog here.  The rest of the article discusses:

  • Who Does the HKAA target?
  • What Sanctions Can Be Imposed Under the HKAA?
  • What Are the Likely Impacts of the HKAA?

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