The US government has established new authorities to impose
sanctions in response to China's national security law for
Hong Kong, increasing the compliance risks for international banks
and other companies that do business in Hong Kong, China and
elsewhere.
The latest measures—the Hong Kong Autonomy Act and
Executive Order 13936—expand sanctions authorities that had
already been established under the Hong Kong Human Rights and
Democracy Act of 2019. Together, these three measures, detailed
below, establish a system of related and potentially overlapping
sanctions that can be leveraged by the United States to respond to
Chinese government's actions in Hong Kong that are inconsistent
with US foreign policy objectives.
