By Maya Lester KC & Michael O’Kane

Sanctions Profile: Turkey

At a glance

The EU adopted Council Regulation (EU) 2019/1890 and Council Decision (CFSP) 2019/1894 to establish a new sanctions regime in November 2019 in response to Turkey’s oil and gas drilling activities in the Eastern Mediterranean sea.

The UK adopted The Unauthorised Drilling Activities in the Eastern Mediterranean (Sanctions) (EU Exit) Regulations 2020 in January 2021 after the Brexit transition period. 

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BIS expedites processing of export licence applications for Turkey & Syria aid

The US Commerce Department’s BIS has expedited the processing of export licence applications for items needed to aid survivors of the earthquake that took place in Turkey and Syria on 6 February 2023. Press Release. BIS has said that: Most items needed for aid in Turkey do not require an export licence, but it will expedite any necessary licence applications …

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UK lifts suspension on licencing military exports to Turkey

On 13 December 2021, the UK lifted its suspension on licencing military exports to Turkey. Notice. The suspension was imposed in October 2019 in relation to items that may be used in military operations in Syria following Turkey’s military action in the country’s north-east. See previous post.


US adds 37 to Entity List & designates 8 as Chinese Military-Industrial Complex Companies

The US Department of Commerce’s Bureau of Industry and Security (BIS) has added 37 entities (under 40 entries) based in China, Georgia, Malaysia and Turkey to its Entity List. The listings respond to China’s research into biotechnology and other technologies for military applications and human rights abuses, as well as the diverting of US items to Iran’s defence industries and …

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Renewal of US & EU sanctions regimes & third countries align with EU sanctions

US The US has renewed multiple sanctions regimes by extending for 1 year the national emergencies declared in: Executive Order (E.O.) 13959, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China”, as amended by E.O. 14032. Previous post & post. Letter & Notice. O. 12170, “Blocking Iranian Government Property”. Notice. O. 13851, “Blocking …

ChinaChina IranIran NicaraguaNicaragua Chemical WeaponsChemical Weapons VenezuelaVenezuela TurkeyTurkey Human RightsHuman Rights RussiaRussia

US Court rules that Halkbank can be prosecuted over Iran sanctions violations

On 22 October 2021, the US Court of Appeals for the Second Circuit ruled that the Foreign Sovereign Immunities Act (FSIA) does not protect state-owned Turkish lender Halkbank from criminal prosecution over accusations that it helped Iran evade US sanctions, as the charges would fall under the commercial activity exception of the FSIA. Case 20-3499-cr. Judgment here. See previous post …

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Current Sanctions



Council Regulation (EU) 2019/1890

Parent Regulation

Council Regulation (EU) 2019/1890

Amended by:

Council Implementing Regulation (EU) 2020/274

Council Implementing Regulation (EU) 2020/1655

Council Implementing Regulation (EU) 2021/1960


Council Decision (CFSP) 2019/1894

Parent Regulation

Council Decision (CFSP) 2019/1894

Amended by:

Council Decision (CFSP) 2020/275

Council Decision (CFSP) 2020/1657

Council Decision (CFSP) 2021/1966

The Unauthorised Drilling Activities in the Eastern Mediterranean (Sanctions) (EU Exit) Regulations 2020 (SI 2020/1474)

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