OFAC took Hong Kong names off the SDN list — most of them are still sanctioned

On 22 July 2026 the Office of Foreign Assets Control removed a set of Hong Kong-related names from the Specially Designated Nationals and Blocked Persons list. In the same notice it moved other people, who remain sanctioned under the Hong Kong Autonomy Act, from the SDN list onto the Non-SDN Menu-Based Sanctions list.

Those are two different events wearing one headline, and the second one is the one that will bite. A transfer between lists is not a release. The people who moved to the NS-MBS list are still restricted; what changed is which file their names sit in. If your screening reads the SDN list and nothing else — which is the default for a surprising number of tools — those names came back clean on the morning of the 23rd.

For an exchange or an OTC desk the practical question is not the designation itself but your coverage. A counterparty that your system flagged in June and passes in August has not become safe. Your system has stopped looking in the right place. That is the kind of gap that is invisible until an examiner asks you to reproduce a decision and the answer is that the list you checked no longer contained the name.

The delistings are genuine and those names really are unblocked. But a compliance file that treats the whole notice as good news, without separating the two groups, is recording a conclusion the source does not support. Read the notice itself rather than a summary of it, ours included — the primary source is linked below and it names the specific parties.

Worth being precise about scope: this notice concerns Hong Kong sanctions authorities and the HKAA. It says nothing about other programmes, and it is not a signal about the direction of any other designation. Sanctions status changes monthly and each list movement stands on its own.