OFAC’s action is a sanctions restructuring, not a broad rollback of U.S. pressure over Hong Kong. The expiration of the emergency supporting Executive Order 13936 required OFAC to remove officials designated solely under that authority, but dozens of figures—including Carrie Lam, John Lee and senior mainland and Hong Kong security officials—remain blocked under the Hong Kong Autonomy Act and were transferred to the Non-SDN Menu-Based Sanctions List.
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