Hong Kong-related Designations Updates and Removals (National Emergency Lapse Notice)

Date issued: Jul. 17 2026

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TURBOFAC Commentary (250 words)

Notes:

1) For the first time since we have tracked such matters, this is the first time that the sanctions portion of an executive order was allowed to lapse, as opposed to being the subject of a different executive order revoking the underlying executive order or terminating the national emergency that served as the basis for the IEEPA-based sanctions. In this case, and apparent as a result of a deal with China, the “national emergency declared in [EO 13936] of July 14, 2020" expired, and as a result OFAC removed EO 13936 as a basis for designations on the SDN List. Notwithstanding the lapse of EO 13936, however, OFAC redesignated most (but not all) of the SDNs previously blocked pursuant to EO 13936 pursuant to the Hong Kong...