Hong Kong

Global sanctions guide

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  1. Does Hong Kong have a sanctions regime in place?

Yes.

  1. Does Hong Kong implement UN sanctions?

Yes.

  1. Does Hong Kong implement an autonomous sanctions regime?

No.

  1. What is the nature of the sanctions regime in Hong Kong?

Hong Kong implements legislation to give effect to various UN sanctions. UN sanctions presently in force in Hong Kong are implemented through the United Nations (Anti-Terrorism Measures) Ordinance and the United Nations Sanctions Ordinance (Cap. 537), although this legislation explicitly excludes sanctions against the People’s Republic of China.

  1. Does Hong Kong maintain a list of sanctioned individuals and entities?

Yes. The Commerce, Industry and Tourism Branch of the Commerce and Economic Development Bureau maintains lists that may be found here.

The lists include:

  • countries subject to UN sanctions
  • persons subject to travel ban under the UN sanctions ordinance by country
  • persons and entities subject to an asset freeze under the UN Sanctions Ordinance by country
  • specified items under the United Nations Sanctions (Democratic People’s Republic of Korea) Regulation (Cap. 537AE)
  • regulated prohibited items and specified prohibited items under the United Nations Sanctions (Iran) Regulation (Cap. 537AF)
  • specified goods under the United Nations Sanctions (Côte d’Ivoire) Regulation (Cap. 537BK)
  1. Are there any other lists related to sanctions?

Yes. In addition to UN sanctions implemented through domestic legislation, financial institutions authorised by the Hong Kong Monetary Authority are required to each maintain a database of names and particulars of terrorist suspects and designated parties for client and transactional screening purposes. This database must consolidate lists published in the Hong Kong Government Gazette and those designated by the US Treasury’s Office of Foreign Assets Control, pursuant to US Executive Order 13224.

  1. Does Hong Kong have a licensing or authorisation system in place?

Yes. The Secretary of Security may grant a licence to authorise activities that would otherwise contravene the United Nations (Anti-Terrorism Measures) Ordinance. The Ministry of Foreign Affairs of the People’s Republic of China can instruct the Chief Executive of Hong Kong to cease implementation of sanctions, modify sanctions or replace sanctions.

  1. What are the consequences for a breach of sanctions in Hong Kong?

Contravention or breach shall be punishable on summary conviction by a fine not exceeding HKD 500,000 and imprisonment for up to 2 years or, on conviction on indictment, by an unlimited fine and imprisonment for up to 7 years.

  1. Who are the relevant regulators in Hong Kong and what are their contact details?

The Commerce and Economic Development Bureau has overall responsibility for implementing the United Nations Sanctions.Address: Commerce and Economic Development Bureau (Commerce, Industry and Tourism Branch)

23/F, West Wing,
Central Government Offices,
2 Tim Mei Avenue, Tamar,
Hong Kong.

T: (852) 3655 5170
E: citbenq@cedb.gov.hk

The Trade & Industry Department is responsible for trade sanctions.

Trade & Industry Department Room 908,
Trade and Industry Department Tower,
700 Nathan Road, Kowloon,
Hong Kong

T: (852) 2392 2922
E: enquiry@tid.gov.hk

The Hong Kong Monetary Authority and Securities and Futures Commission are responsible for implementing and administering financial sanctions in Hong Kong.

Hong Kong Monetary Authority
55th Floor, Two International Finance Centre,
8 Finance Street
Central,
Hong Kong

T: (852) 2878 8196
E: hkma@hkma.gov.hk

Securities and Futures Commission
35/F, Cheung Kong Center,
2 Queen’s Road Central,
Hong Kong

T: (852) 2231 1222
E: enquiry@sfc.hk

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