US lets Trump-era Hong Kong sanctions order lapse, restoring trade privileges in major diplomatic shift
The expiration of Executive Order 13936 reverses six years of penalties against Hong Kong and could reshape the city's trajectory as a crypto-friendly financial hub.
Executive Order 13936 is dead. The Trump-era order that stripped Hong Kong of its preferential trade status, effectively treating the semi-autonomous territory the same as mainland China, quietly expired on July 14, 2026, after neither the White House nor Congress moved to extend it.
China’s Ministry of Commerce confirmed the development on July 17, calling it an important step toward improving bilateral ties. The US Treasury’s Office of Foreign Assets Control (OFAC) followed up by announcing it would review its guidance on Hong Kong-related sanctions.
What actually happened
In 2020, then-President Trump signed Executive Order 13936 in response to Beijing’s imposition of a national security law on Hong Kong. The law, critics argued, effectively dismantled the “one country, two systems” framework that had governed the territory since the 1997 handover from Britain.
The executive order revoked Hong Kong’s special trade privileges under US law, suspended extradition treaties, and imposed sanctions on individuals and entities deemed responsible for eroding the city’s autonomy.
Presidents Biden and Trump both extended the order annually. Then, on July 14, 2026, the order simply lapsed.
China’s Commerce Ministry framed the move as a fulfillment of commitments made during 2025 trade talks in Madrid, suggesting the expiration was part of a broader negotiated deal. OFAC’s announcement that it would review its Hong Kong sanctions guidance added weight to that interpretation.
Why this matters for crypto markets
Hong Kong introduced a licensing regime for virtual asset service providers in 2023 and approved spot Bitcoin and Ether ETFs in 2024. Under Executive Order 13936, US firms and their subsidiaries faced significant compliance headaches when dealing with Hong Kong-based entities, and sanctions risk made American banks, asset managers, and crypto firms think twice before setting up shop there.
With the order expired and OFAC reviewing its guidance, that calculus changes. US-based crypto firms that previously avoided Hong Kong exposure may now reconsider, and institutional capital that stayed on the sidelines could start flowing more freely into Hong Kong-listed digital asset products.
The bigger picture for investors
There are risks to watch. China’s framing of this as a concession won during trade talks means Beijing may expect reciprocal gestures on other fronts. And OFAC said it’s reviewing its guidance, not eliminating it. Some Hong Kong-related sanctions could remain in place even without the executive order’s umbrella authority.