U.S. Department of State Imposes Sanctions on Turkey’s Presidency of Defense Industries
Client Alert
On December 14, 2020, the U.S. Department of State imposed broad sanctions on Turkey’s Presidency of Defense Industries (also known as SSB) pursuant to Sections 231 and 235 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), including a prohibition on U.S. government agencies from providing U.S. export licenses and authorizations for transfers of goods and technology to SSB. This restriction was implemented by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC).
Moving forward, BIS and DDTC will not issue any licenses or authorizations for the export or re-export of items to SSB. DDTC has stated that current, valid, non-exhausted licenses and authorizations are not affected by this change in policy. Similarly, there is no indication that BIS will revoke current and valid export licenses. Accordingly, absent further action from BIS or DDTC, items moving under existing BIS or DDTC licenses are not affected by the SSB sanctions.
We are seeking guidance from the U.S. government as to whether exempt activity, such as Foreign Military Sales transactions, are affected by these sanctions. We will send an update when we hear back from the U.S. government on this issue.
Importantly, these sanctions target SSB, Turkey’s primary defense procurement entity, and some of its officers. This is not a country-wide embargo on Turkey or a broader restriction against business with the Turkish government. These new restrictions are only triggered to the extent that SSB or one of its officers is involved with a shipment.
We hope this is helpful, but please let us know if you have any questions.
