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Vague definition of ‘significant transactions’ in US sanctions act leaves FIs with less space to comply

The ambiguity of the US Hong Kong Autonomy Act (HKAA) in defining ‘significant transactions’ is making it hard for financial institutions to manage risks without completely severing banking relationships with Hong Kong and China officials under sanction. The HKAA imposes sanctions on foreign individuals and entities that materially contribute to China’s failure to preserve Hong Kong’s autonomy. On 15 October, US Secretary…

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