Sanctions Success or About Face? – White House Removes Sanctions on Turkey

As a result of this request, OFAC has removed the individuals and entities added to the SDN List on October 14, 2019, which we had reported on in our October 15, 2019 client alert. The individuals and entities are:

• AKAR, Hulisi, Turkey; DOB 1952; POB Kayseri, Turkey; Gender Male (individual)

• DONMEZ, Fatih, Turkey; DOB 1965; POB Bilecik, Turkey; Gender Male (individual)

• SOYLU, Suleyman, Turkey; DOB 21 Nov 1969; POB Istanbul, Turkey; Gender Male (individual)

• REPUBLIC OF TURKEY MINISTRY OF NATIONAL DEFENCE, Ankara, Turkey

• REPUBLIC OF TURKEY MINISTRY OF ENERGY AND NATURAL RESOURCES, Ankara, Turkey

OFAC’s “Recent Action” notice can be found here, and the related Treasury press release can be found here.

However, the President has not yet revoked the national emergency pursuant to which the sanctions were put in place. Accordingly, the authority remains and could be used should the situation change significantly on the ground in Northern Syria. Indeed, the White House’s “Update on the Developments in Northern Syria” specifically notes that “President Trump has been clear that should Turkey fail to keep its commitments, including to the protection of religious and ethnic minorities, the Administration reserves the right to impose crippling sanctions.” Notably, the President stated in his remarks that “the sanctions will be lifted unless something happens that we’re not happy with.” In addition to possible future action by the President, there is also proposed legislation moving through Congress that could require new sanctions to be placed on Turkey.

Given the unstable situation in Northern Syria and the strong views held by many in Congress, US companies should be mindful of the potential future risk of more sanctions on the Turkish government and its officials.

So, in a haiku:

Turkey has announced
a ceasefire in Syria
no more SDNs