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Trump Administration Authorizes Sanctions on Turkey

Responding to Turkey’s actions in Syria, President Trump issued an Executive Order (EO) blocking property and suspending entry of certain persons contributing to the situation in Syria. Pursuant to the EO, OFAC added three Turkish government officials and two Turkish government agencies, the Ministry of National Defence and the Ministry of Energy and Natural Resources, to the Specially Designated Nationals (SDN) List. The EO and associated OFAC action resulted in the blocking of all property and interest in property owned or controlled by the listed individuals and entities, now or at a later date, in the US or under the control of a US person. 

In support of the EO, OFAC issued three Turkey-related general licenses. General License 1, “Official Business of the United States Government,” permits US government employees, grantees or contractors to engage in transactions otherwise prohibited by the new EO, provided the conduct is for the official business of the US government. General License 2, “Authorizing Certain Activities Necessary to the Wind Down of Operations or Existing Contracts Involving the Ministry of National Defence or the Ministry of Energy and Natural Resources of the Government of Turkey,” created a wind-down period, effective through 12:01 a.m. EST, November 13, 2019, for all otherwise prohibited transactions and activities that were incident to the wind down of operations, contracts or other agreements with the Ministry of National Defence or the Ministry of Energy and Natural Resources, or any entity in which either ministry owned a 50% or greater  interest. Finally, General License 3, “Authorizing Official Activities of Certain International Organizations Involving the Ministry of National Defence or the Ministry of Energy and Natural Resources of the Government of Turkey,” authorized otherwise prohibited transactions and activities that were for the official business of the United Nations, including its programs and funds, and its specialized agencies and related organizations.

On October 23, 2019, following Turkey’s commitment to a permanent ceasefire, OFAC removed the previously designated individuals and entities from the SDN List. As a result of OFAC’s actions, all property and interests in property that were blocked solely as a result of those designations are now unblocked, and all otherwise lawful transactions involving US persons with these individuals or entities are no longer prohibited. However, the EO issued on October 14, 2019, authorizing the imposition of sanctions on certain Turkish individuals and entities remains in effect, and there is legislation pending in the US Congress, which, if passed, could lead to new Turkey sanctions. In addition, the Trump Administration could reimpose sanctions, depending primarily on developments on the ground in Northern Syria.

© Copyright 2020 Squire Patton Boggs (US) LLPNational Law Review, Volume IX, Number 307


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