On 14th October 2019 President Donald Trump issued an Executive Order implementing sanctions against Turkey in response to the latter’s military offensive in Northern Syria.  The US’ Office of Foreign Assets Control (“OFAC”) claimed that the military action could undermine efforts to defeat terrorist organisation Islamic State (Daesh), endanger civilians, and further threaten the security and stability of the region.  At present sanctions have only been imposed on five parties: the Ministry of National Defence, the Ministry of Energy and Natural Resources, Minister of Defence Hulisi Akar, Minister of Energy and Natural Resources Fatih Donmez and Minister of the Interior Suleyman Soylu.  All transactions and activities that are necessary to wind down operations with the Ministry of National Defence or the Ministry of Energy and Natural Resources are permitted until 13th November 2019.


The sanctions do, however, allow OFAC to target any current or former Turkish government official, and bills for further sanctions against the Turkish state are currently under consideration in the US Congress.  The so-called Turkey Sanctions Bill could target further individuals in the Turkish Government and aims to introduce other broader measures, including cutting US military support to the Turkish armed forces.  Sanctions on the US assets of Turkish President Recep Tayyip Erdogan are also being discussed.  The bill has so far received cross-party support in Congress, with both Republican and Democrat senators claiming Trump’s initial sanctions do not go far enough and will have a limited impact in their current form.


The implementation of US sanctions on Turkey comes against the backdrop of increased pressure from the US Government in the past four days.  Less than 24 hours after sanctions were imposed, on 15th October 2019, the Department of Justice filed new criminal charges against Turkish state-owned bank Halkbank following a three-year investigation in connection with the latter’s alleged use of gold to bypass US sanctions on Iran.  In addition to sanctions offences, Halkbank was charged with fraud and money laundering.

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