On July 14, President Trump issued an Executive Order (EO) strengthening and expanding sanctions mandated by Congress under the Hong Kong Autonomy Act (HKAA), which the president also signed into law on July 14. In particular, the EO introduces blocking sanctions against foreign persons pursuant to the International Emergency Economic Powers Act in response to recent developments in Hong Kong.

The EO also directs US agencies to undertake steps to suspend or eliminate different and preferential treatment for Hong Kong pursuant to section 2020 of the United States-Hong Kong Policy Act of 1992.

Click here to read the full client alert which summarizes the background of the EO, sanctions provisions of the HKAA, and open questions that may be addressed by the US government in the coming weeks.