Policy Recommendations
Hong Kong’s value as a hub for sanctions evasion has grown significantly in recent years. This report underscores
the urgent need for comprehensive and decisive measures to stem this trend. While these recommendations are
relevant to all democratic nations, most of our recommendations focus on U.S. policy due to the United States’
unparalleled influence over the global economy and its demonstrated political will to address these issues.
1
The U.S. should use its secondary sanctions authority to designate Hong Kong and Chinese banks financing illicit trade.
2
The U.S. should Designate Hong Kong as a Primary Money Laundering Concern ("PLMC").
3
Congress should act to increase resources and coordination across government departments responsible for sanctions and export control enforcement.
4
The U.S. should use its secondary sanctions authority to designate Hong Kong and Chinese banks financing illicit trade.
5
Global financial firms should enhance AML procedures to capture data like customs records and suspicious vessel activity.
6
The U.S., E.U., and their allies should increase enforcement and penalties against manufacturers and distributors of sensitive technologies.