OFAC removes EO 13936 Hong Kong SDN entries and shifts remaining designations to HKAA
US sanctions screeners must drop the lifted EO 13936 SDN entries and keep blocking HKAA parties now on the NS-MBS List
Change
On 17 July 2026 OFAC removed from the SDN List persons designated under Executive Order 13936 whose property was blocked solely under IEEPA, following the expiration of the E.O. 13936 national emergency. Persons still designated under the Hong Kong Autonomy Act (HKAA) were moved to the Non-SDN Menu-Based Sanctions (NS-MBS) List, and assets blocked before 14 July 2026 remain blocked. The Hong Kong Human Rights and Democracy Act and the HKAA both remain in effect.
Why it matters
The E.O. 13936 emergency expiration ends IEEPA-only blocking authority, so US blocking grounds for the remaining designations now rest on statute (the HKAA). OFAC moved HKAA-designated parties to the NS-MBS List while leaving assets frozen before 14 July 2026 in place. US financial institutions must reconcile which Hong Kong-related names remain active block targets and which are delisted, since matching a delisted-only EO 13936 entry now over-blocks while dropping an HKAA name under-blocks. OFAC will amend 31 CFR part 585 to reflect the expiration and is updating related FAQs and guidance.
Implications
- — US banks and payment processors must remove the delisted E.O. 13936 SDN entries from active block filters, because continuing to match those names blocks transactions against parties OFAC no longer designates; screening logic must distinguish delisted E.O. 13936-only entries from names retained under the HKAA.
- — Custody and asset-servicing functions must keep assets blocked before 14 July 2026 frozen and refuse release or transfer tied to them, because OFAC has expressly maintained those blocks despite the SDN removals.
- — Sanctions-compliance functions must screen the HKAA-designated individuals against the NS-MBS List and treat them as subject to HKAA blocking where assets were blocked before 14 July 2026, because these names moved list rather than being delisted.
Who is affected
- — Sanctions-screening functions at US banks and payment processors
- — Custody and asset-servicing functions at US financial institutions
- — Sanctions-compliance functions maintaining OFAC screening lists
What to watch
- — OFAC's forthcoming amendment to the Hong Kong-Related Sanctions Regulations at 31 CFR part 585 in a future Federal Register notice.
- — OFAC's pending update to Hong Kong-related sanctions FAQs and guidance.