On 14 October, OFAC published 4 new FAQ relating to sanctions under the Hong Kong Autonomy Act, addressing such questions as: how does the Treasury Department determine whether a transaction is “significant”, and what “knowingly” and “financial institution” means. At the same time, 10 existing entries on the sanctions list are amended.
https://home.treasury.gov/policy-issues/financial-sanctions/faqs/848
https://home.treasury.gov/policy-issues/financial-sanctions/faqs/849
https://home.treasury.gov/policy-issues/financial-sanctions/faqs/850
https://home.treasury.gov/policy-issues/financial-sanctions/faqs/851
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201014
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