The US sanctions space is very active and changes are made frequently. This publication is current as of October 23, 2019.

On October 23, 2019, the United States, in response to Turkey's agreement to pause military operations in Syria, lifted the sanctions it had imposed just a little over a week prior on the Government of Turkey's Ministry of National Defense and the Ministry of Energy and Natural Resources, as well as the Minister of National Defense, Minister of Energy and Natural Resources, and the Minister of the Interior.

Each of the ministries and individuals have now been removed from OFAC's SDN List and all property and interests in property, which had been blocked solely as a result of the designations, are unblocked and all otherwise lawful transactions involving US persons and these entities and individuals are no longer prohibited. The United States has also agreed to refrain, at least for the time being, from imposing any additional sanctions authorized by the October 14, 2019 executive order, as described in our prior update.

The delisting represents a remarkably quick change in policy by the United States. The situation could deviate again as there are a number of bills pending in the US Congress that seek to impose new sanctions on Turkey in response to its military activities in Syria. While none of these bills are currently close to being passed or signed into law, there does appear to be some bipartisan support for some sort of legislation. We will continue to monitor developments and provide additional updates, as appropriate.

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