1. Does Turkey have a sanctions regime in place?

Yes. Turkey’s sanctions regime must be complied with by any individual or entity within Turkey and any individual elsewhere who is a Turkish citizen or any entity incorporated or constituted in Turkey (including overseas branches of Turkish companies).

2. Does Turkey implement UN sanctions?


3. Does Turkey implement an autonomous sanctions regime?

Yes. Turkey’s autonomous sanctions regime includes trade embargos on: narcotics (Law on Inspection of Narcotics dated 12 June 1933, No. 2313); casino machinery (Law on Roulette, Tilt, Foosball and Similar Game Tools and Machines dated 13 December 1968, No. 1072); certain types of plants (Regulation on Plant Quarantine published in the official gazette dated 3 December 2011 with the number 28131); and chemical weapons, chemicals and waste which are categorized dangerous and ozone depleting substances (Communiqué on Import 2017/1) Respective sanctions are provided in Law 6415 on the Prevention of the Financing of Terrorism.

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.

5. Does Turkey maintain a list of sanctioned individuals and entities?

Yes. The Ministry of Treasury and Finance maintains a list of entities and individuals sanctioned by it and publishes this list in the official gazette. This list consists of the names of individuals and entities that have been listed by the UN and the EU.

6. Are there any other lists related to sanctions?

Ministry of Defence makes a list of the military materials that will be subject to export and import control according to Law No 5201.

7. Does Turkey have a licensing or authorization system in place?

The export of sensitive and dual-use materials covered by international instruments and export regimes is controlled by virtue of a two-tier mechanism. For military equipment, arms and ammunition, the first tier is regulated by Law Number 5201 published in the official gazette dated 3 July 2004 which replaced Law Number 3763 of 1940 regarding The Control of Private Industrial Enterprises Producing War Weapons, Vehicles, Equipment and Ammunition. This law requires licences to be obtained from the MND for the export of all weapons and ammunition. The MND issues every year a list of all weapons, ammunition, explosive materials and their parts, which are subject to such licensing. As for items listed in the NSG list, TAEA’s licensing authority is regulated by the Regulation on Issuance of Export License for the Nuclear and Nuclear Dual-use Materials published in the official gazette dated 13 September 2007, No:26642.

As to the second tier, it is the duty of the Ministry of Trade (“MT”) to take all monitoring, control, arrangement and orientation measures regarding exports and to draft the general export policy of Turkey. In fulfilling these duties, the MT avails itself of the 13 exporters’ unions located around the country. Istanbul Metals and Minerals Exporters’ Union (“IMMIB”), like other exporters’ unions, is responsible for the implementation of the general export policy under the auspices of the MT. All exporters are required to be a member of an exporters’ union in order to be able to export any goods or material.

8. What are the consequences for a breach of sanctions in Turkey?

According to Law Number 5201, failure to obtain a license from the MND for export of military weapons, military vehicles and military equipment, ammunition and their spare parts shall be punishable by imprisonment for two months to one year and a penalty of not less than TRY4,000,000. Furthermore, the same penalties shall apply in cases where, without permission of the MND: (i) the material or technology is exported to an end user that is suspected to be engaged in the development of WMD; (ii) the equipment exported might be wholly or partially used for the development of WMD; or (iii) the equipment exported endangers national or international security or could cause a violation of human rights. Moreover, there is various administrative fines in regard to export/import requirements indicated in Customs Law Numbered 4458.

9. Who are the relevant regulators in Turkey and what are their contact details?

Ministry of Foreign Affairs Dr. Sadik Ahmet Cad. No:8 Balgat Ankara Turkey 06100 T: (+90) 312 292 10 00 W: www.mfa.gov.tr/default.en.mfa

Ministry of National Defence Milli Savunma Bakanlığı Devlet Mahallesi, Yahya Galip Caddesi Bakanlıklar/ Ankara, Turkey. T: (+90) 312 402 61 00

Ministry of Treasury and Finance

İsmet İnönü Bulvarı No:36 06510 Emek/ Ankara T: (+09) 312 415 29 00

Turkish Atomic Energy Authority Mustafa Kemal Mahallesi, Dumlup nar Bulvar, No: 192, 06510, Çankaya, Ankara, Turkey T: (+90) 312 295 8700

Ministry of Trade Sogutozu Mah. 2176 Sk. No:63 Çankaya / Ankara

T: (+90) 312 204 75 00

Istanbul General Secretariat of Mining and Exporters Union Çobançesme mevkii, Sanayi Cad., No:3, Dis Ticaret Kompleksi A Blok P.K.34197 Yenibosna/Bahçelievler, Istanbul, Turkey T: (+90) 212 454 00 00

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Jonathan Blythe,

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Ali Ergin Çelebi, K ıdemli Avukat/Senior Associate

Senguler & Senguler,

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T: (+90) 212 361 50 66 F: (+90) 212 361 50 67 jonathan.blythe@eurasia.com.tr

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