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T
he price of advocating for democracy in Hong Kong may have been calculated at HK$1 million ($128,000).
That, in fact, is the bounty that Hong Kong authorities have set for the pro-democracy activists Joey Siu and 18 others who have been made fugitives over accusations of committing national security offenses.
Siu had expected the cross-border effort to silence activists-in-exile like her. But still, the 22-year-old said, the hefty bounty was like a “death certificate.”
“I can really never go back,” Siu, who is currently based in Washington, D.C., told the Human Rights Foundation.
One year after Hong Kong implemented its own national security law called the Safeguarding National Security Ordinance (SNSO) – commonly known as Article 23 – the Chinese government’s crackdown on pro-democracy activists has rapidly grown from a domestic campaign into a global manhunt for dissidents.
Not satisfied with crushing pro-democracy voices within Hong Kong’s borders, authorities are now systematically targeting the Hong Kong diaspora through not just the million-dollar bounty, but also through passport cancellations, disqualification of professional licenses, and harassment of family members left behind.
This extraterritorial reach has been expanded to include a wider campaign of censorship and intimidation and efforts to pressure businesses, media outlets, and tech companies worldwide to remove content critical of Beijing and block access to pro-democracy websites and content.
These concerns were highlighted at a webinar hosted recently by Asia Democracy Network and Lady Liberty Hong Kong, where experts and activists gathered to discuss the continued erosion of the rule of law in the city and the impact of the one-year-old SNSO.
Dismantled rule of law
The extension of Hong Kong’s repressive apparatus beyond its borders builds on years of systematic dismantling of fundamental rights at home through its passage of draconian laws.
The 2020 National Security Law (NSL) – promulgated in Hong Kong directly by China’s National People’s Congress – had led to an alarming deterioration of human rights, including the right to free expression and the freedom of assembly. But the passage of the SNSO in March 2024 introduced the new offense of “external interference” and broadened the definition of theft of state secrets and espionage.
As a result of these two laws, Hong Kong’s once-massive pro-democracy movement – whose adherents took to the streets in 2019 and 2020 in protest – has been all but snuffed out, with many activists now jailed or forced into exile.
There is currently an average of 1,929 political prisoners detained as of May 2, 2025, according to Hong Kong Democracy Council’s database. The international arrest warrant and bounty put up for Siu in December 2023 just marked the start of her troubles. Charged with “collusion with foreign forces” and “inciting secession” – broad offenses allegedly committed by target pro-democracy activists under the National Security Law – Siu’s situation worsened a year later.
On the eve of Christmas last year, Hong Kong authorities revoked her passport and officially labeled her an “absconder” under the SNSO. She was one of six overseas activists similarly classified and subjected to financial restrictions.
Siu, who holds U.S. citizenship, explained that several activists in exile face a far more precarious situation due to their uncertain legal status. “A lot of them still do not have a permanent residency status in their new host country yet,” Siu said during the webinar. “If they have their passports canceled by the Hong Kong authorities, they would be subjected to an immigration limbo where they would effectively become stateless.”
This risk is compounded by what Siu describes as a “global anti-immigration wave” in countries like the United Kingdom, Canada, and the United States. This has led to increased risks of deportation and long-term immigration uncertainties for many Hong Kongers in exile, which means they cannot obtain a legal document that will allow them to “stay in a country safely and then, secondly, to be politically active.”
Hong Kong authorities have also expanded their crackdown by targetting professional credentials and access to financial resources. Last December, Dennis Kwok and Kevin Yam – who also have HK$1 million ($1.3 million) bounties on their heads – saw their law license suspended.
Family members of activists remaining in Hong Kong also face “repetitive interrogation and questioning,” said Siu, creating further pressure on those in exile.
These are designed not just to intimidate but also to cause mental and emotional exhaustion among the pro-democracy diaspora while forcing them to cut ties with their families back home and local residents.
“It is very clear,” said Siu, that the Hong Kong government wants them “to give up or take a step back from our activism overseas to make sure that the situations in Hong Kong developments are no longer broadcasted.”
It does not help that support from overseas has declined, with many potential donors hesitant to engage with activists targeted by bounties. Even participation in crowdfunding efforts by exiled groups has dropped, as fear of repercussions, including for their families in Hong Kong, grows.
Transnational repression via third parties
Beyond its transnational crackdown on individuals, the Chinese government has also embarked on a global effort to censor information and rewrite the narrative of Hong Kong’s pro-democracy movement by targeting digital platforms that carry their causes.
“It is this extraterritorial application of repressive laws that not only pose a threat to global rule of law and freedom of expression, but that have also served as a false cover for Hong Kong and the People’s Republic of China to wage transnational repression against the Hong Kong diaspora and its allies,” said Michael Caster, the head of the Asia digital program at Article 19, a U.K.-based human rights organization.
Chinese authorities – whose censorship has “gone global,” as described by Caster — had previously attempted to test their international reach in 2021, three years before the passage of the SNSO in 2024.
Acting on the request of Hong Kong police, the Israeli web host Wix temporarily took down the website of 2021HKCharter.com, which was set up by overseas activists. Wix kept it offline for three days before restoring it with an apology, claiming “error.”
In May 2024, the Hong Kong Court of Appeals approved a global ban on the protest anthem “Glory to Hong Kong.” The sweeping injunction prohibited the broadcasting or distribution of the song anywhere in the world, claiming it could “incite others to commit secession” or be misrepresented as Hong Kong’s national anthem.
Within weeks, U.K.-based music distributor EmuBands removed the song from all major streaming platforms, including Apple Music, iTunes, and Spotify.
“The action amounted to internationalizing censorship of the protest song on streaming media services around the world,” Caster said.
Most recently, in October 2024, Hong Kong police targeted Flow Hong Kong, a prominent diaspora media outlet. Security officials issued formal demands to its US-based web host, Automatic, ordering the removal of the entire website under threat of fines and imprisonment. They claimed that the site violated multiple provisions of the National Security Law and SNSO related to subversion, incitement to subversion, and collusion with foreign forces.
“While there have been previous efforts to silence NGOs and campaign websites abroad, this was the first instance of targeted censorship of overseas media websites on the basis of the NSO,” Caster said.
Unlike EmuBands, Automatic refused to comply despite threats to its personnel, Caster added.
“I think this is a clarion call for global tech actors to do more to document and resist efforts from Hong Kong authorities acting under repressive laws to limit the freedom of expression through censorship in Hong Kong and extraterritorially,” he said.
Setting the wrong example
China’s approach to online censorship is a step above the typical domestic restrictions on content, which it already implements. Rather than simply blocking content for local audiences, Beijing has pressured international companies to remove material globally, as evidenced by its demands for Wix to take down a pro-democracy website and U.K.-based EmuBands to purge protest songs from worldwide streaming platforms like Spotify and Apple Music.
Hong Kong’s use of the SNSO with impunity could also embolden other countries to pass and implement similar laws, said Maiko Ichihara, a professor in the Graduate School of Law at Hitotsubashi University, Japan.
In Asia, China has been conducting transnational repression within the borders of Japan and Thailand. In February, the Thai government had covertly arranged for the deportation of a group of 40 Uyghur men who had been detained in the country since 2014 following a request from China.
“The more cases of transnational repression there are, the more anti-immigrant sentiment will rise in the country out of the fear of being caught up in political problems,” Ichihara said. “This will make it more difficult for governments and organizations that try to help activists facing repression to operate, as domestic opposition to them will increase.”
This could compound hardships posed by shifting political landscapes even in once-friendly countries. Last January, U.S. President Donald Trump signed an executive order indefinitely suspending all refugee admissions to the U.S., leaving dozens of Hong Kongers approved for resettlement in limbo.
While international law does permit limited extraterritorial jurisdiction – such as regulating citizens abroad or prosecuting universally recognized crimes like genocide and war crimes – Hong Kong’s security laws combine extraterritorial reach with deliberately vague definitions of violations, creating an unprecedented legal weapon against its critics in other countries.
Keeping up the fight
Despite the dire conditions for overseas activities, all three advocates of Hong Kong’s democracy believe the fight is far from over. They say that coordinated international action remains key to sustaining resistance and protecting those targeted by China’s transnational repression.
“It is very, very crucial for the international community, especially host countries such as Canada, the U.K., the United States, and elsewhere to ensure a viable humanitarian immigration pathway to permanent citizenships in their countries,” Siu said.
“With the recent [U.S.] foreign aid freeze and with the U.K.’s recent budget cuts, it is very important right now for Asia-Pacific countries, including Japan, South Korea, and others to step up their support for not just the Hong Kong diaspora … but then for all the communities currently fighting and resisting authoritarianism,” Siu said.
More than that, civil society must also maintain “narrative leadership” of what it means to face transnational repression – and to support those who are affected.
“As Hong Kong authorities have intimidated, silenced, detained, and imprisoned protest leaders in Hong Kong in efforts to crush civil society spirit, it has really only succeeded in emboldening a global diaspora of coordinated strategic non-violent resistance,” Caster said. ◉
Cristina Chi is a Filipino journalist based in Manila who writes stories on education, legislature, and human rights.
