United States Sanctions Against Turkey *Update*

For further information and advice, Members can contact North’s sanctions team at sanctions.advice@nepia.com.

16 October 2019

The EO provides for the property of any person to be blocked who is determined (by the US Secretary of State of the Treasury in consultation with the US Secretary of State) to be:

• Contributing to the situation in Syria (as more fully set out in (1)(i)(A) of the EO); or
• A current or former official of the Govt. of Turkey; or
• A subdivision, agency or instrumentality of the Govt. of Turkey; or
• Operating in such sectors of the Turkish economy as determined by the US.

Thus far three individuals and two entities have been designated under the Executive Order.  The entities designated are the Republic of Turkey Ministry of Energy and Natural Resources and the Republic of Turkey Ministry of National Defence.

The EO also provides for the ability to sanction any person deemed to have:

• Materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to the EO; or
• To be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to the EO.

Furthermore, the EO sets out at section six, that the prohibitions include the making of any contribution or provision of funds, goods or service by, to, or for the benefit of any person who is blocked under the EO, and the receipt of any contribution or provision of funds, goods, or services from any such person.

The US has also issued three General Licenses. Perhaps most relevant is General License 2 which authorises US persons to complete the wind down of operations or existing contracts  – that were in effect prior to 12:01 eastern daylight time on 14 October –  involving the two designated entities or any entity in which one or more of such entities own, directly or indirectly, a 50 percent or greater interest,  until 12:01am eastern standard time on 13 November, on the terms as set out in the General License.

Foreign financial institutions can also be sanctioned for knowingly conducting or facilitating any significant financial transaction for or on behalf of any person designated under the Executive Order.  The EO can be read in full here.

For further information and advice, Members can contact North’s sanctions team at sanctions.advice@nepia.com