US Sanctions Against Turkey - 14 October 2019 |
October 2019 |
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On 14 October 2019 the US imposed sanctions on certain Turkish ministries and senior government officials in response to Turkey’s military offensive in northern Syria. The relevant Executive Order provides for the imposition of asset freezing measures which US persons must comply with. It also authorises the imposition of sanctions against:
The latter prohibition suggests that non-US persons are at risk of sanctions if they engage in activities with designated persons which the US categorises as assistance/sponsorship, financial, material or technological support, or goods or services.
Certain foreign financial institutions are prohibited from conducting or facilitating significant financial transactions for persons blocked under the EO (Section 3).
There is a general license allowing performance of transactions and activities up to 13 November 2019 which are ordinarily incident and necessary for winding down contracts with the 2 designated ministries if they had been entered into prior to 14 October 2019.
Section 1 of the Executive Order sets out primary sanctions which provide for the blocking of property by US persons of any person determined by OFAC:
Section 2 authorises the imposition of sanctions against a foreign person who engages in
OFAC is also authorised to impose sanctions on persons responsible for or complicit in, or who have directly or indirectly engaged in, or attempted to engage in the expropriation of property, for personal gain or political purposes in Syria.
Section 3 authorises the imposition of sanctions against foreign financial institutions engaging in any significant financial transactions for a person who is blocked pursuant to Section 1 of the EO. “Foreign financial institution” is defined as an entity engaging in certain specific types of activities such as deposit business, giving of loans and credits, and securities brokering.
Concurrently, OFAC has made the following designations:
INDIVIDUALS:
ENTITIES:
OFAC has issued 3 general licenses. Of particular relevance is GL2 which provides for a winding down period up to 13 November 2019 in respect of contracts or other agreements with the Ministry of National Defense or Ministry of Energy and Natural Resources that were in effect prior to 14 October 2019.
This GL does not authorise financial transactions with the designated ministries which would have a US nexus.