On October 23, President Trump announced that the sanctions placed on Turkey’s Ministries of National Defence and Energy and Natural Resources as well as on three senior Turkish government officials, which went into effect just nine days ago, will be removed. Shortly thereafter, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed both ministries and all three ministers from its list of Specially Designated Nationals and Blocked Persons (SDN List). However, in his announcement this morning, President Trump left open the possibility that the sanctions could be reimposed, and the executive order (E.O. 13894) issued on October 14, pursuant to which the sanctions removed today were imposed, remains firmly in place.

In the meantime, legislation was introduced in the Senate on October 17 that would impose a set of sanctions stronger than those President Trump removed today. While the president has the power to impose sanctions through delegations made by Congress under the International Emergency Economic Powers Act and the National Emergencies Act, Congress can and frequently does pass additional sanctions legislation, as it has done in the case of Iran, Russia and other countries.

The proposed Senate legislation (which is just one of the bills currently pending in Congress that would impose sanctions on Turkey) would place sanctions not just on the Ministries of National Defence and Energy and Natural Resources and the three ministers who were removed from the SDN List yesterday but also on President Recep Tayipp Erdogan and a wide range of additional government ministers. The legislation would also add Turkiye Halk Bankasi, currently under indictment for, among other things, attempting to evade sanctions on Iran, to the SDN List. Significantly, the legislation also would direct the U.S. Department of the Treasury to place sanctions on Turkey in response to Turkey’s acquisition of the Russian S-400 air and missile defense system, prohibit U.S. military assistance to Turkey, and ban several Turkish government officials from visiting the United States.

The future of sanctions against Turkey thus remains uncertain, and the events of the past several days have illustrated just how quickly the sanctions landscape can change, providing companies doing business globally with yet another important reminder of the need to stay apprised of geopolitical and other developments that could result in imposition of sanctions.