On October 23, 2019, the Treasury Department's Office of
Foreign Assets Control ("OFAC") announced it was removing three Turkish
government ministers and two Turkish government ministries from its
list of Specially Designated Nationals and Blocked Persons
("SDN List"). The removals come only six
days after OFAC's initial designations, resulting in some of
the shortest-lived sanctions in OFAC's history.
As we discussed in our recent
client alert, the imposition of sanctions against
Turkish officials represented an unusual deviation from previous
U.S. administrations, as it punished a NATO ally. Shortly after
imposing the sanctions, the Trump Administration promised Turkey sanctions relief if it
agreed to a ceasefire in northern Syria. Less than a week later,
the President stated in a White House speech that the Turkish government
agreed to a permanent ceasefire in northern Syria – and these
recent removals fulfill the United States' end of this
bargain.
