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840. If an official of the Government of the Hong Kong Special Administrative Region (HKSAR) is designated as a Specially Designated National (SDN), does that mean that the HKSAR government is blocked?  What are the prohibitions on U.S. persons dealing with a designated HKSAR government official?


The designation of an official of the Government of the HKSAR does not itself block the HKSAR government or any government agency where the SDN is an official or otherwise exercises control.  Accordingly, engaging in a routine interaction with an agency in which an SDN is an official, but which does not involve the SDN directly or indirectly, is not prohibited. 

U.S. persons are prohibited from engaging in transactions or dealings with, and dealing in the property or interests in property of, designated HKSAR government officials, including any entities that are directly or indirectly owned 50 percent or more in the aggregate by one or more blocked persons.  U.S. persons should be cautious in dealings with HKSAR government agencies in which an SDN is an official to ensure that they are not engaged in transactions or dealings, directly or indirectly, with an SDN (e.g., by entering into contracts that are signed by an SDN, entering into negotiations with an SDN, or processing transactions, directly or indirectly, on behalf of the SDN), absent authorization from OFAC or an applicable exemption.  However, U.S. persons may, for example, enter into HKSAR government contracts signed by a non-SDN official of the HKSAR to whom the HKSAR government has delegated the authority to enter such contracts.

Date Released
September 25, 2020