October 2019



For further information please contact:

Lara Sezerler
Partner, Istanbul

Gökseli Cengiz
Senior Associate, Istanbul

Ergün Avukatlık Bürosu İstanbul | Levent Loft II, D: 13-16, Levent
T +90 (212) 280 90 91

Ankara | Next Level, A Blok, D: 33, Çankaya
T +90 (312) 220 30 60



US Sanctions against Turkey

On October 14, the President of the United States issued an executive order, as published under the link Also the Office of Foreign Assets Control (OFAC) issued General License 1, General License 2 and General License 3 and added the following names to its list of Specially Designated Nationals (“SDN”) and Blocked Persons, as detailed under With these, OFAC took action against two ministries and three senior Turkish Government officials in response to Turkey’s military operations in Syria. The following have been added to OFAC’s SDN List:

  • Minister of National Defence,
  • Ministry of National Defence,
  • Minister of Energy and Natural Resources,
  • Ministry of Energy and Natural Resources, and
  • Minister of the Interior.

This block freezes all property and interests in property of these persons, that are in the U.S. and bans transactions with them that involve the US financial system.

On October 15, a draft bill (PACT (Protect Against Conflict by Turkey Act)) imposing sanctions on Turkish governmental officials and Turkish industries which have links to the operations in Syria, was introduced to the House of Representatives. It is also expected to be submitted to the U.S. Senate on October 17. If both the House of Representatives and the Senate approves of the draft law, it will be submitted for the approval of the U.S. President as a final step. If the President does not veto and approves of the draft law within ten days, then the draft bill will enter into force and will be implemented for a period of three years following the end of the operations in Syria. If the President vetoes the draft law, then it will be re-sent to the House of Representatives.

The key points under the draft bill are summarized as below:

  • Sanctions such as freezing U.S. assets and prohibiting entry to the U.S. will be imposed to the Minister of National Defense, Turkish Armed Forces Commander,  Second Army Commander, Minister of Treasury and Finance.
  • The U.S. Minister of Foreign Affairs and Minister of National Defense and Director of National Intelligence will convene and incorporate a list within 30 days following the enactment of the PACT and all Turkish authorities with a link to the conflict will be inserted to this list.  The list will be updated every 60 days and sanctions will enter into force within 15 days following each new addition to the list.
  • The U.S. Minister of Foreign Affairs together with the intelligence agency and U.S. Ministry of Treasury will prepare a  report on the assets of the Turkish President and his family members, in 120 days following the enactment of the bill.
  • None of the U.S. defense systems or services will be imported to Turkey for use in the Syrian operations, except for the equipment to be used for NATO approved transactions and for the U.S. operations in Turkey or for emergency circumstances determined by the U.S. President.
  • Sanctions will be imposed to the Turkish financial institutions which transfer money to the Turkish army and defense industry. Halkbank is mentioned to be one the entities on which sanctions will be imposed, in 15 days following the enactment of the bill.
  • The sanctions numbered CAATSA 231 relating to the sale of S-400 defense systems will be implemented in 30 days following the enactment of the bill.

Once the draft bill is enacted, we will be providing further details.

This information is provided for your convenience and does not constitute legal advice. It is prepared for the general information of our clients and other interested persons. This should not be acted upon in any specific situation without appropriate legal advice. This information is protected by copyright and may not be reproduced or translated without the prior written permission of Ergün Avukatlık Bürosu.