US persons are not allowed, under the EO, to engage in any transactions with the above named Turkish Ministries or the three designated individuals. However, the US Office of Foreign Asset Control (OFAC) has issued a license authorising US persons to wind down their existing contracts with the two Turkish Ministries by the 13 November 2019.
Non-US persons may be subject to sanctions if they are found to have 'materially assisted' or provided goods or services in support of the two Turkish Ministries or the named individuals.
These sanctions are in response to the recent Turkish military incursion into northern Syria. However, Turkey has agreed to a ceasefire to allow Kurdish-led forces to withdraw.
"Whether this will lead to the US retracting their sanctions remains to be seen. For the time being, members are strongly advised to exercise due diligence when trading to Turkey", the Standard Club said.
Operators should closely monitor the website of the US Office of Foreign Asset Control to determine whether any Turkish entities or individuals with whom they transact have been added to the US SDN List.