Turkey

4. What is the nature of the sanctions regime in Turkey?

The Turkish export controls regime is largely in line with the EU system. However, unlike the EU system (which is based on a single control list), Turkey implements export controls through different control lists under the responsibility of different official bodies. These bodies include: the Ministry of National Defence (“MND”); the Ministry of Economy (“ME”); the Ministry of Customs and Trade (“MCT”); the Undersecretariat for Foreign Trade (“UFT”); the Turkish Atomic Energy Authority (“TAEA”); and the Mining and Exporters Union. These bodies also function as licensing authorities. Turkey is also party to the following international treaties: the Wassenaar Arrangement; the Missile Technology Control Regime; the Australia Group; the Nuclear Suppliers’ Group (“NSG”); the Zangger Committee; International Atomic Energy Agency; Nuclear Non-Proliferation Treaty; Biological Weapons Convention and the Chemical Weapons Convention. The control lists indicated under these international treaties are subject to export controls and the UFT is the responsible body for ensuring control of the items listed therein. Moreover, “catch-all” controls are carried out by the UFT and the MND. The “catchall” controls are regulated under the Communiqu. Concerning the Control of the Export of Dual-use and Sensitive Goods (“Communiqu. No. 2003/12”). Article 6 of Communiqué No. 2003/12 stipulates that the export of items which are not indicated under the lists of the aforementioned international treaties shall be subject to the permission of UFT if:

• the material or technology is exported to an end user that is suspected to be engaged in the development of weapons of mass destruction (“WMD”)
• the exporter has suspicion that the exported items, wholly or partially might be used for the development of WMD
• the export of such material or technology might endanger national or international security or cause a violation of human rights

Asset freezing restrictions are handled by the Presidency of the Turkish Republic in accordance with the Law 6415 on the Prevention of the Financing of Terrorism.