Background

Effective Dec. 14, the U.S. imposed export sanctions on the Turkish Presidency of Defense Industries (Savunma Sanayii Başkanlığı, or SSB), a Turkish government entity, after Turkey took delivery of a surface-to-air missile system from Russia.

The State Department’s Directorate of Defense Trade Controls has prohibited the granting of specific U.S. export licenses and authorizations for any goods or technology transferred to SSB. As a result, DDTC will not approve any specific license or authorization to export or reexport any defense articles, including technical data, or defense services where SSB is a party to the transaction. This prohibition does not apply to temporary import authorizations or to current, valid, non-exhausted export and reexport authorizations. However, it does apply to new export and reexport authorizations, including amendments to previously approved licenses or agreements and licenses in furtherance of previously approved agreements.

DDTC adds that this sanction does not apply to subsidiaries of SSB but that licenses naming such subsidiaries are still subject to a standard case-by-case review, including a foreign policy and national security review.

DDTC is also imposing the following sanctions with respect to SSB.

- a prohibition on loans or credits by U.S. financial institutions to SSB totaling more than $10 million in any 12-month period

- a ban on U.S. Export-Import Bank assistance for exports to SSB

- a requirement for the U.S. to oppose loans benefitting SSB by international financial institutions

Separately, the Commerce Department’s Bureau of Industry and Security has implemented a policy of denial for export license applications to SSB.

For more information on these actions, please contact Kristine Pirnia.

Copyright © 2024 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.

ST&R: International Trade Law & Policy

Since 1977, we have set the standard for international trade lawyers and consultants, providing comprehensive and effective customs, import and export services to clients worldwide.

View Our Services 

Close

Cookie Consent

We have updated our Privacy Policy relating to our use of cookies on our website and the sharing of information. By continuing to use our website or subscribe to our publications, you agree to the Privacy Policy and Terms & Conditions.