Tariff Notices · Sanctions · confirmed
OFAC moves Hong Kong sanctions targets off the SDN List—but some blocking restrictions remain
Updated · Impact score 74/100 · Confidence 55%
After the national emergency under Executive Order 13936 expired, OFAC removed people blocked solely under that authority from the SDN List and moved people who remain sanctioned under the Hong Kong Autonomy Act to the NS-MBS List.
Why it matters
A party disappearing from the SDN List is not automatically cleared for every transaction. OFAC says assets blocked before July 14 remain blocked for people still sanctioned under the Hong Kong Autonomy Act, whose new NS-MBS entries continue to carry blocking and transaction restrictions with an exception for importation of goods.
What to check next
Rescreen Hong Kong and China counterparties against both the current SDN and NS-MBS lists, reconcile former SDN matches before releasing blocked property, and obtain sanctions advice before relying on the importation-of-goods exception while OFAC updates its regulations and guidance.
Affected entities
- Hong Kong
- China
- OFAC
- Sanctions screening
- Import transactions