A number of family members of high-ranking Hong Kong officials are holders of foreign passports and have assets in other countries including the U.S. and the U.K., RFA has learned.
If the U.S. goes ahead with sanctions against officials involved in suppressing Hong Kong's human rights or imposing China's national security law on the city, Hong Kong chief executive Carrie Lam, police commissioner Chris Tang, and Han Zheng, head of the Hong Kong and Macao Affairs Office (HKMAO), could all be in the firing line for asset freezes and travel bans.
John Ullyot, a spokesman for the White House National Security Council, has said U.S. President Donald Trump has not ruled out further sanctions against Hong Kong and ruling Chinese Communist Party officials over Hong Kong and other rights violations.
Reuters has cited sources as saying that Washington is considering a travel ban on members and families of the Chinese Communist Party.
Lam has said she has no assets in the U.S., nor any plans to travel there.
"I'm not bothered because I don't have assets in the United States and I don't want to go there," she told a local TV network this week.
"If they won't give me a visa, I just won't go."
Families not restricted by law
But while Article 61 of the Basic Law stipulates that the principal officials of the Hong Kong government may not hold right of abode in foreign countries, their families aren't restricted by the law.
A search of publicly available records carried out by RFA found that the spouses or children of many of the city's senior officials do hold foreign passports, including the family of former chief executive Leung Chun-ying.
Leung, who now holds the post of vice chairman in the Chinese People's Political Consultative Conference (CCPPC), an advisory body to the National People's Congress (NPC), has family members who hold British passports.
Lam's husband and two sons are also British citizens.
Security secretary John Lee, who was behind the police crackdown on last year's anti-extradition protests and subsequent pro-democracy movement, has given up his British passport, while his wife and two sons have retained theirs.
Otto Poon, husband of Hong Kong's secretary for justice Theresa Cheng, also holds Canadian citizenship.
He is also chairman and a major shareholder in a listed engineering company, Analogue Holdings, while Cheng owns more than 60 percent of the group's equity.
The company owns U.S.-based Transel Elevator & Electric, an elevator and escalator engineering company, which could be affected by any U.S. sanctions.
Many pro-Beijing lawmakers in Hong Kong have declared that they hold shares in overseas companies or property.
Regina Ip, for example, is listed on the records of two British Virigin Islands companies, one of which holds U.S. shares.
Ip has been a vocal critic of the Hong Kong Autonomy Act requiring sanctions against anyone impeding the city's freedoms and autonomy, as promised in the 1984 Sino-British Joint Declaration and the Basic Law.
Legislative Council (LegCo) president Andrew Leung has declared ownership of property in the U.K., without providing details.
He is currently also a paid director of 18 companies across several sectors including property, finance, and logistics.
Period of uncertainty, instability
Benson Wong, a political cultural scientist at the Hong Kong Baptist University, said some pro-China lawmakers could hold passports from other countries.
"Some [lawmakers] may be living in Hong Kong while holding an American passport and fighting for Beijing and the Hong Kong government, so what will their situation be?" he said.
"This period of uncertainty and instability will cause a lot of political pressure," Wong said.
Ming Sing, associate professor of Social Science at the Hong Kong University of Science and Technology, said banks can also be forced to impose sanctions internationally under the new U.S. law.
"Unless you put all your money in a single domestic bank that has no dealings with any international banks, the threat is very real," Sing said.
"You could have your accounts frozen otherwise, so there are very serious implications here, actually."
Reported by Man Hoi-tsan and Tseng Yat-yiu for RFA's Mandarin and Cantonese Services. Translated and edited by Luisetta Mudie.