U.S. Department of the Treasury Reports: No FFI Identified as Subject to HKAA Secondary Sanctions | ZFZ Postcard Cases
On 11 December 2020, the U.S. Department of the Treasury issued its report under the Hong Kong Autonomy Act (HKAA).
The report concludes that no FFI at risk of secondary sanctions under the HKAA has been identified for the time being.
As a reminder, the HKAA (enacted on July 14, 2020) required the Secretary of the Treasury to submit a report to Congress that identifies any FFI that knowingly conducted a significant transaction with a foreign person previously identified by the Secretary of State, against whom OFAC had imposed asset-blocking sanctions.
Although this report came as a relief for FFIs, the Treasury announced that “it will continue to actively monitor this type of activity”.
A takeaway consideration is that FFIs should make sure that they understand their reporting requirements and sanctions risks under the HKAA.
Read more on this decision here.