President Trump announced Oct. 23 the lifting of the economic and trade sanctions he imposed nine days earlier against Turkey. However, he also said the U.S. reserves the right to “reimpose crippling sanctions” against Turkey, including “substantially increased tariffs on steel and all other products coming out of Turkey,” if it does not meet certain obligations, including the protection of religious and ethnic minorities.

Trump said he had instructed the Treasury Department to “lift all sanctions” imposed Oct. 14. As a result, the Office of Foreign Assets Control removed the Turkish ministries of national defense and energy and natural resources, along with the Turkish ministers of national defense, energy and natural resources, and interior, from its Specially Designated Nationals list. This means all property and interests in property that had been blocked solely as a result of these designations have been unblocked and all otherwise lawful transactions involving U.S. persons and these entities and individuals are no longer prohibited.

These five entities appear to be the only ones that had been added to the SDN list under an Oct. 14 executive order that included the following provisions.

- prohibited exports and other actions with respect to property and interests in property that are in the U.S. or under the control of a U.S. person of specified categories of entities, including those who operate in specific sectors of the Turkish economy, current or former Turkish government officials, Turkish government agencies, and others

- required a ban on imports of goods, technology, and services, as well as U.S. government procurement of goods or services, from those determined by Treasury to engage in specified activities with respect to the conflict in Syria

- allowed secondary sanctions on those not subject to U.S. jurisdiction who provide goods, services, or other support to sanctioned persons

- allowed restrictions on foreign financial institutions that knowingly conduct or facilitate any significant financial transaction for or on behalf of a blocked person

The White House has not indicated whether it intends to resume negotiations on an agreement aimed at increasing trade between the U.S. and Turkey to $100 billion a year, which were halted as part of the Oct. 14 measures.

In addition, while the president had planned to increase the Section 232 tariff on steel products imported from Turkey to 50 percent, press source state that this change was never formally implemented and that the tariff therefore remains at 25 percent.

For more information, please contact export compliance attorney Kristine Pirnia.

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