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On May 2, 2023, for the second time this year, the US and Turkish governments took joint action in imposing sanctions.  Specifically, the United States and Türkiye imposed sanctions against two individuals determined to be financial facilitators of Syria-based terrorist groups Hay’at Tahrir al-Sham (“HTS”) and Katibat al-Tawhid wal-Jihad (“KTJ”), both of which are sanctioned by the United States and the United Nations.  This follows a prior joint action in January targeting parties associated with the financial facilitation network of the Islamic State of Iraq and Syria (“ISIS”), as reported previously on our blog (see here).

See here for the most recent US action and here for the Turkish action.  The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued this press release on these new sanctions, which states that the joint action “continues the cooperation between the United States and Türkiye to counter the financing of terrorist groups that perpetuate violence and instability throughout the region.”

The sanctions were imposed by OFAC, the Turkish Ministry of Treasury and Finance, and the Turkish Ministry of Interior. OFAC added these parties to its List of Specially Designated Nationals or Blocked Persons (“SDN List”), essentially cutting these parties off from the US financial system and transactions involving a US nexus. Türkiye’s Treasury and Interior ministries implemented an asset freeze against the targeted parties.

This latest joint action is a further sign of increased levels of international coordination on sanctions. 

The authors acknowledge the assistance of Ryan Orange with the preparation of this blog post.

Author

Kerry Contini is a partner in the Firm's international trade practice in Washington, DC. She advises companies on export controls, sanctions, and related human rights and supply chain compliance issues. She has been with Baker McKenzie since she was a summer associate in 2005 and started as an associate in 2006. Kerry has been ranked in the Up and Coming categories for Export Controls & Trade Sanctions by Chambers Global (2022) and Chambers USA (2021), with clients highlighting that "her advice and solutions are business-focused" and that she is "very practical and easy to work with." Kerry has been recognized as a “standout” member of Baker McKenzie’s international trade team by Legal 500. Legal 500 reported a client as stating that, “Kerry is thoughtful, practical, efficient, and has really invested in getting to know our business and our team.” Kerry was recognized in the Who's Who Legal 2021 as a Global Leader in Trade & Customs - International Sanctions. Kerry has written on export controls and trade sanctions issues for a number of publications, including WorldECR, The Export Practitioner, and Ethisphere. She has presented on pandemic-related supply chain issues to the US International Trade Commission. Kerry has been quoted in a number of publications, including Global Investigations Review and Asian Legal Business. She is an editor of the Firm’s Global Supply Chain Compliance blog and is a regular contributor to that blog as well as the Firm’s Sanctions & Export Controls Update blog. Kerry is a co-chair of the Export Controls and Sanctions Section of the Association of Women in International Trade. Kerry is part of the diversity and inclusion leadership for the Washington DC office and is a member of the BakerWomen Steering Committee. She has maintained an active pro bono practice throughout her career at Baker McKenzie and is co-chair of the Washington DC office pro bono leadership team. Kerry has worked on a wide range of pro bono matters, primarily focusing on public international law, animal advocacy, and election protection. She is an active member of the Animal Law Committee of the Environment, Energy, and Natural Resources Community of the DC Bar.

Author

Gokce Serez is a lawyer at Esin Attorney Partnership, Istanbul office. She focuses her practice on corporate compliance, including corporate investigations, anti-bribery, anti-money laundering, anti- corruption, white-collar crimes, trade sanctions and export controls.

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