On September 25, 2020, OFAC published Frequently Asked Question No. 840, related to the Government of Hong Kong Special Administrative Region to address whether routine interactions are allowed with the HKSAR government now that certain Hong Kong officials have been designated by OFAC; the FAQ also clarifies which prohibitions exist for US persons dealing with a designated HKSAR official. This follows the July 14, 2020 signing of the Hong Kong Autonomy Act (HR 7440) into law, along with Executive Order 13936, which authorizes sanctions against individuals and entities that contribute to the oppression of Hong Kong by the Government of China. On August 7, 2020, OFAC designated eleven officials for helping to undermine democratic processes in Hong Kong.
According to FAQ 840, routine interactions with the HKSAR government are not prohibited. This includes interactions with government agencies that employ designated officials, but do not directly or indirectly involve the official. In contrast, transactions involving property or interests in property of a designated HKSAR official are prohibited.