U.S. government issues new executive order targeting Turkey and sanctions the Turkish Ministry of Defense, Ministry of Energy and Natural Resources, and others

On 14 October, President Donald Trump issued Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (EO). Pursuant to the EO, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) added two Turkish ministries – the Ministry of Energy and Natural Resources and the Ministry of National Defence (MOD), and three Turkish ministers – Hulusi Akar, the Minister of National Defence, Suleyman Soylu, the Minister of Interior, and Fatih Donmez, the Minister of Energy, to the Specially Designated Nationals and Blocked Persons List (SDN List). As a result, U.S. persons generally are prohibited from engaging in any transactions or dealings with these new SDNs, and non-U.S. persons also are prohibited to the extent there is a U.S. nexus. The prohibition applies to any entity that is owned, directly or indirectly, 50 percent or more, individually by an SDN or when aggregated with the ownership interests of any SDNs. Non-U.S. persons could face exposure under secondary U.S. sanctions for providing "material support" to these new SDNs (or entities owned by them), or for engaging in types of sanctionable activities identified in the EO, even if the underlying transaction has no U.S. nexus.