On October 14, 2019, the Trump administration imposed new sanctions against Turkey for its recent military offensive in northeastern Syria.

In the new Executive Order, President Trump declared a national emergency due to the national security and foreign policy threat posed by the Turkish Government's military operation. President Trump denounced the attack, saying that the Turkish Government is (i) hindering efforts to defeat the Islamic State of Iraq and Syria (a/k/a, "ISIS"), (ii) threatening civilians and (iii) further destabilizing the region. The Executive Order authorizes the suspension of entry of, and blocks all property and interests in U.S. property that are connected to, any person who is:

  • destabilizing or committing human rights abuses in Syria;
  • a Turkish Government official;
  • operating in certain sectors of the Turkish economy; or
  • materially assisting a designated person.

Simultaneously, OFAC issued three General Licenses that authorize:

  • the conduct of official U.S. government business, otherwise prohibited by the Executive Order;
  • a 30-day wind-down period for all transactions and activities involving the Ministries of National Defense or Energy and Natural Resources of the Turkish Government; and
  • certain UN activities.

In addition, pursuant to the October 14 Executive Order, OFAC designated the Ministries of National Defense and Energy and Natural Resources of the Turkish Government as well as three senior Turkish Government officials. As a result of OFAC's designations, all property and interests in property of the designated individuals and entities, and of any entities that are owned, directly or indirectly, 50 percent or more by them, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. OFAC regulations also generally forbid all dealings by U.S. persons, and all transactions that occur within or transiting the United States, that involve the property or interests in property of blocked individuals or entities. In addition, OFAC warned that persons or foreign financial institutions that engage in certain financial transactions in connection with these designated individuals and entities could be subject to U.S. correspondent or payable through account sanctions.

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