On October 23, 2019, President Trump and the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that certain Turkish individuals and agencies of the Turkish Government, who had previously been added to OFAC’s Specially Designated Nationals (“SDN”) List, would now be removed given the ceasefire agreement in Syria. Those individuals and entities designated as SDNs would have effectively been barred from the U.S. financial system and their property and interests in property in the U.S. or in the possession of a U.S. person would have been subject to blocking, in addition to other potential consequences. The individuals and entities that have now been removed from the SDN List include the Turkey Ministry of National Defence and the Turkey Ministry of Energy and Natural Resources, among others.

Despite the SDN de-listings, the President’s initial Executive Order 13894 announced on October 14, 2019 is still in effect and has not been formally withdrawn. However, there currently are no individuals or entities that are designated as SDNs under the Executive Order and it remains to be seen whether the Trump Administration will aggressively enforce sanctions against Turkey in the future. The political developments in this space are moving rapidly and we will continue to follow and report on any further developments.

If you have any questions or concerns about U.S. sanctions, please contact Bruce G. Paulsen (212-574-1533), Andrew S. Jacobson (212-574-1477), Noah S. Czarny (212-574-1642), or Paul B. Koepp (212-574-1613) at Seward & Kissel’s Sanctions Practice Group.