U.S. Sanctions Turkish Ministries and Officials in Response to Syria Offensive
On Monday, October 14, President Trump issued an executive order imposing economic sanctions in response to Turkey’s military operations in northern Syria (the “Executive Order”). The two major targets of the new U.S. sanctions are the Turkish Ministry of National Defense and the Ministry of Energy and Natural Resources; these sanctions could implicate significant state-sponsored industries including, for example, the Mechanical and Chemical Industry Corporation, Turkish Aerospace Industries, military pharmaceuticals, and oil and natural gas projects. The Executive Order grants the administration broad authority to target entire sectors of the Turkish economy, so any businesses having a significant interest in the Turkish market could be affected if sanctions are further expanded to cover entire sectors of the Turkish economy. Since existing contracts and business with entities owned by the sanctioned ministries must be wound down by November 14, U.S. persons and non-U.S. entities employing U.S. persons, should evaluate their Turkey-related dealings to determine whether any counterparties may be subject to these new sanctions. It is unknown whether any future sanctions will be coupled with a similar wind down period, so even unaffected businesses may wish to review their exposure to Turkey.