Yes, what I fear most is America sanctioning a Chinese bank.
I've been researching Hong Kong banks. Sadly, most do have operations in the mainland. Banks such as HSBC, as much as I hate them, are apparently highly important to mainland banks.
Here might be some options:
These could be on the very public list of banks for NSL people. Note that I'm not a banking expert, so please correct me if damaging any of these would do strong damage to mainland China.
- Bank of East Asia
- DBS Bank (Singapore)
- Hang Seng Bank (HSBC)
- OCBC Wing Hang Bank (Singapore)
- Standard Chartered (UK)
One problem is that the foreign headquarters could try to prohibit NSL people from banking with these institutions. At that point Hong Kong would have to split the Hong Kong institution from the foreign headquarter. Ideally it'd be better to have local Hong Kong owned banks.
With respect your "special unit for circumventing ALL American sanctions," China does have those banks: Banco Delta Asia, Bank of Dandong, and Bank of Kunlun. Unfortunately none operate in Hong Kong.
These banks are irrelevant in China. HSBC and Standard Chartered are important to HK only. Big 4 Chinese banks control 14 trillions of assets in China.
I think most people just don't get that Hong Kong is the world third biggest financial center and China is the world second biggest economy. China might have been reluctant to retaliate but if the US went too far then we would see decoupling. That means nothing is off the table. Most US banks would be forced to exist China and HK which are a big part of their businesses. HSBC and Standard Chartered would either bow to China or file bankruptcy because majority of their assets and profits are made in HK and China.