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News: US sanctions against Turkey

21 October 2019

On 14 October 2019 the United States issued Executive Order (EO) 13894 imposing sanctions against the Turkish Ministry of Energy and Natural Resources and the Turkish Ministry of National Defence. In addition three government ministers have been added to the United States' Specifically Designated National List (SDN List). 

US persons are prohibited under the EO from engaging in any transactions with the above named Turkish Ministries or the three designated individuals. However, the US Office of Foreign Asset Control (OFAC) has issued a license (General License 2) which authorises US persons to wind down ​their existing contracts with the two Turkish Ministries by the 13 November 2019. Non-US persons may be subject to sanctions if they are determined to have 'materially assisted' or provided goods or services in support of the two Turkish Ministries or the named individuals. Further details are provided in the client alert issued by US law firm Freehill Hogan & Mahar.

These sanctions are in response to the recent Turkish military incursion into northern Syria. It was, however, announced today that Turkey has agreed to a ceasefire to allow Kurdish-led forces to withdraw. Whether this will lead to the US retracting their sanctions remains to be seen. For the time being, members are strongly advised to exercise due diligence when trading to Turkey.

We recommend that members closely monitor the website of the US Office of Foreign Asset Control to determine whether any Turkish entities or individuals with whom they transact have been added to the US SDN List.