U.S. Department of the Treasury Removes Sanctions on Turkish Ministries and Officials
Client Alert
On October 23, 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) removed the Specially Designated National (“SDN”) designations on the Government of Turkey’s Ministries of National Defense and Energy, as well as the SDN designations on the Turkish Ministers of National Defense, Energy, and Interior. On October 14, 2019, President Trump issued Executive Order 13894 authorizing the Secretary of the Treasury to designate the Government of Turkey, its officials, and foreign companies providing goods and services to SDNs under this E.O. In addition, E.O. 13894 also imposed secondary sanctions prohibiting foreign (1) parties from engaging in certain Syria-related transactions and (2) banks from facilitating any transactions involving SDNs or activity in Syria.
As a result of OFAC’s de-listing of the Turkish Ministries and Ministers, U.S. and foreign parties are no longer prohibited from engaging in business with these parties. Nonetheless, foreign forwarders are still prohibited from engaging in certain transactions related to operations in Northern Syria, as listed in E.O. 13894 § 2.
Parenthetically, the removal of sanctions here was contingent on Turkey accepting a ceasefire in Northern Syria. As has been evident in the news, this is a sensitive political situation and it is not clear to what extent the ceasefire will be successful. Accordingly, as E.O. 13894 is still in effect, it is possible that OFAC may re-designate the Government of Turkey depending on the events over the next several weeks.
We hope this is helpful, but please contact Ed Greenberg (egreenberg@gkglaw.com) or Oliver Krischik (okrischik@gkglaw.com) if you have any questions.
