On October 23, OFAC announced the removal of two Turkish ministries and three government officials from its SDN List. These sanctions, which were originally imposed on October 14, were lifted at the direction of President Trump as a result of Turkey’s purported adherence to an agreed cease-fire with the United States that was put into place on October 17 after the country’s repeated attacks on Kurdish forces in northern Syria. Due to these changes to the SDN List, transactions between U.S. persons and the listed entities and individuals are no longer restricted, and all related property and interests in property that were previously blocked are now unblocked. Despite OFAC’s action, there are still indications that Congress intends to move forward with a Turkey sanctions bill. As such, there remains a possibility that new sanctions will be imposed in the coming months.
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