The Biden administration issued a warning that US businesses operating in Hong Kong are increasingly at risk due to the implementation of new national security legislation by China in March. The advisory highlights the potential for businesses to run afoul of U.S. sanctions and face other legal and regulatory challenges under the Article 23 security law. This law could impact activities such as lobbying, market analysis, and media publication, treating them as national security threats. The State Department also noted that Hong Kong has become a conduit for Russia to evade sanctions related to its Ukraine invasion, and for the circumvention of export controls on Chinese semiconductor manufacturing. US companies are urged to exercise caution to avoid sanctions risks, updating guidance first given in 2021.
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