OFAC Sanctions on Turkey

Turkey has long been an important partner of the United States, including within the framework of the North Atlantic Alliance NATO. However, in recent years, relations between Ankara and Washington have become strained, leading to a series of restrictive measures from the U.S.

One of the key events that provoked sanctions was Turkey’s decision in 2017 to purchase S-400 surface-to-air missile systems from Russia. The first deliveries began in 2019, which caused a mixed reaction from Western allies.

In December 2020, the U.S. administration imposed sanctions against Turkey’s Defense Industry Directorate (SSB) and several of its executives under the Countering America’s Adversaries Through Sanctions Act — CAATSA. Later, depending on the development of events, the sanctions lists were reviewed and supplemented.

In addition to the purchase of the S-400, serious disagreements arose over a number of foreign policy issues, including Turkey’s role in regional conflicts (Syria, Libya, Eastern Mediterranean).

A number of Turkish organizations associated with the defense industry (including the Presidency of Defense Industries of Turkey, SSB) have come under sanctions. Deliveries and joint projects in the field of advanced military technologies are prohibited, as well as the transfer of technologies that the United States considers critically important for the defense sector.

Some restrictions apply to transactions in dollars and access to American loans for sanctioned entities. Individuals included in the sanctions lists face freezing of assets and a ban on conducting business in the jurisdiction of the USA.

Officials and heads of defense enterprises are prohibited from entering the USA. Their assets under US jurisdiction (if any) are frozen. Although the S-400 issue laid the legal groundwork for CAATSA, the focus of US policy has since evolved dramatically towards financial warfare.

While diplomatic disputes over the S-400 remain in the background, the primary risk for businesses in 2026 is the aggressive enforcement of Secondary Sanctions. Following the expansion of Executive Order 14024 and the strict measures of 2025, the U.S. Treasury (OFAC) now targets intermediaries—logistics firms, trading houses, and electronics suppliers—that facilitate the circumvention of sanctions against Russia.

Unlike the political sanctions of the past, these measures are automatic and targeted. Dozens of Turkish companies have been added to the SDN List in the last two years solely for re-exporting “High-Priority Items” (such as microchips, ball bearings, and navigation equipment) or providing material support to sanctioned entities. Being designated means total isolation from the global financial system.

Formally, the first notable decisions on the introduction of sanctions against Turkey began to be discussed in EU bodies in 2019. At that time, the European Union accused Ankara of illegal exploration and extraction of natural gas in the exclusive economic zones of EU member states (in particular, Cyprus).

During 2020 and 2021, sanctions were revised and supplemented several times. The EU Council made decisions to introduce personal measures (visa restrictions and asset freezes) against specific Turkish officials and companies associated with exploration activities in the Eastern Mediterranean.

Territorial disputes between Ankara and Athens and Nicosia, including over offshore gas fields and maritime borders, have repeatedly become the subject of heated discussions at EU summits. The violation of Cyprus and Greece’s maritime borders provoked a negative reaction from Brussels and served as a catalyst for the introduction of targeted restrictions.

So far, the EU has not imposed large-scale sectoral sanctions on the Turkish economy, as it has in the case of other countries. However, a number of statements indicate that in the event of conflict escalation, the introduction of stricter restrictions in energy, shipping, and other sectors may be considered.

Since the implementation of Executive Order 14114 (initially Dec 2023, tightened in 2025), Turkish banks face the direct threat of losing access to U.S. correspondent accounts if they process payments related to Russia’s military-industrial base.

This has created a “Compliance Gridlock” in 2026:

Before the official Brexit at the end of 2020, the United Kingdom participated in sanction initiatives within the framework of the European Union’s common foreign and security policy. Therefore, many of the early restrictive measures against Turkey were effectively applied in the territory of the United Kingdom as well.

After Brexit, London created its own independent UK Sanctions regime. Now the government of the United Kingdom independently develops and approves sanction measures, although in many cases they remain aligned or harmonized with the sanctions of the US, EU, and other allies.

In the context of the U.S. law CAATSA and similar measures against Russia’s partners, the United Kingdom has introduced targeted sanctions and restrictions on the supply of military technologies to Turkish companies associated with the acquisition or use of Russian military equipment.

The situation with human rights, the arrests of journalists, opposition members, and human rights defenders in Turkey has repeatedly been criticized in London. Positioning itself as a supporter of international legal norms and freedoms, the United Kingdom imposes targeted sanctions against individuals involved in such violations.

First and foremost, the sanctions are aimed at the financial sector and export control. This includes freezing assets and restricting access to the British financial market for Turkish companies and individuals included in the sanctions lists.

Possible restriction or suspension of cooperation in the oil and gas sector in case of Turkish companies involvement in controversial energy resource extraction projects in the Eastern Mediterranean. Tightened control over the conclusion of contracts for the supply of weapons and military technologies.