In an updated report to Congress, Treasury stated that it "has not identified any foreign financial institution ("FFI") that has knowingly conducted a significant transaction" with previously identified sanctioned foreign persons under the Hong Kong Autonomy Act ("HKAA").

The update of the HKAA Section 5(b) ("Identifying Foreign Financial Institutions") report by Treasury follows an update of an HKAA Section 5(a) report ("Identification of Foreign Persons") by the Secretary of State, which identified an additional 24 previously sanctioned foreign persons found to have materially contributed to "the failure of the Government of China to meet its obligations" under the Joint Declaration or the Basic Law.

In its update, Treasury stated that, following an investigation, it did not identify any FFI that knowingly conducted a significant transaction with persons identified in the October 2020 Section 5(a) report or the subsequent March 2021 update. Treasury further stated that it will continue to (i) monitor for violations, (ii) engage foreign governments and FFIs to ensure HKAA compliance and (iii) resubmit updates to the Section 5(b) report.