Turkish Trade Compliance & Sanctions Network

The Turkish Trade Compliance and Sanctions Network (TTCSN) is a not-for-profit organization dedicated to promoting best practices in trade compliance.

[Şafak Herdem @SafakHerdem]

𝗢𝗙𝗔𝗖 𝗝𝘂𝘀𝘁 𝗥𝗲𝗹𝗲𝗮𝘀𝗲𝗱 𝗮𝗻 𝗨𝗽𝗱𝗮𝘁𝗲𝗱 𝗜𝗻𝘁𝗿𝗼𝗱𝘂𝗰𝘁𝗶𝗼𝗻 𝗚𝘂𝗶𝗱𝗲 - June 1, 2026.

For compliance officers, legal counsel, and international trade professionals, here are the key details worth noting in this latest version:

📌 Updated Civil Penalty Figure The maximum civil monetary penalty per IEEPA violation, as of January 15, 2025, stands at $377,700 per apparent violation — adjusted annually for inflation.

📌 Extended Enforcement Statute of Limitations OFAC may now commence enforcement actions for IEEPA- or TWEA-based violations within 10 years of the latest violation date (where that date falls after April 24, 2019). Other violations carry a five-year window.

📌 Secondary Sanctions — Expanding Scope The guide reaffirms that the explicit use of secondary sanctions targeting non-U.S. persons has become increasingly common — no longer limited to Iran-focused programs.

📌 The 50% Rule — Still a Blind Spot for Many A company not appearing on the SDN List can still be fully blocked if sanctioned persons own 50% or more of it, directly or indirectly. Due diligence must go beyond name-matching.

📌 Voluntary Self-Disclosure Incentive Reaffirmed Proactively disclosing apparent violations can reduce proposed civil penalties by 50%. Full report expected within 180 days of initial notification.

📌 Recordkeeping: 10-Year Obligation All transactions subject to OFAC regulations must be documented and retained for 10 years — including those processed under a license.

This updated guide is a timely reminder to revisit your screening protocols, KYC procedures, and internal reporting timelines. https://t.co/bvVRmhH3hq

#herdem

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

Switzerland has adopted significant changes to its export control framework by extending country-specific exemptions for trade in military equipment and controlled goods to all member states of the European Union and the European Free Trade Association (EFTA).
#TTCSN #Türkiye

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

The United States has imposed counterterrorism sanctions on 13 individuals and entities connected to an Iran-based procurement network accused of acquiring sensitive goods and technology on behalf of sanctioned Iranian actors.
#TTCSN #TürkiyeTradeCompliance #ExportControl

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

UK has updated its financial sanctions guidance to provide additional clarification regarding the designation of Huobi Global S.A., also known as HTX, which was added to the UK sanctions list on 26 May 2026 as part of a broader package targeting Russia-linked financial networks.

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

BIS issued guidance on 31 May 2026 confirming that a licence is required for the export, re-export, or transfer of certain advanced computing items to entities headquartered in countries listed in Country Group D:5, including the People’s Republic of China.
#TTCSN #TürkiyeTrade

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

FTI Consulting has entered into a settlement agreement with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), agreeing to pay $1,050,000 to resolve potential civil liability arising from apparent violations of U.S. Russia-related sanctions.

#TTCSN

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

The United States has announced a new round of sanctions targeting a network involved in the sale, transportation, and marketing of Iranian oil and petrochemical products, intensifying efforts to disrupt revenue sources connected to Iran’s military and sanctioned entities.
#TTCSN

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

A U.S. District Court in Washington, D.C., has dismissed claims brought against cryptocurrency exchange Binance by victims of the 7 October 2023 Hamas attacks, ruling that alleged deficiencies in the company’s sanctions and anti-money laundering controls
#TTCSN #TürkiyeTrade

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

OFAC has issued Russia-related General License 131F, extending authorization for certain transactions connected to the negotiation and execution of contingent contracts involving the potential sale of assets held by Lukoil International GmbH (LIG) and its majority
#TTCSN #Türkiye

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

The United States has designated the Persian Gulf Strait Authority under its counter-terrorism sanctions programme, citing its links to the Islamic Revolutionary Guard Corps (IRGC), which remains designated by the United States
#TTCSN #TürkiyeTradeCompliance #ExportControl

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

Dutch law enforcement authorities have arrested two individuals as part of an investigation into suspected violations of the Netherlands’ Sanctions Act 1977. The arrests were carried out on 18 May 2026 following an inquiry.

#TTCSN #TürkiyeTradeCompliance #ExportControl #Sanction

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

The United States has re-designated Francesca Albanese under Executive Order 14203, restoring her status on the International Criminal Court (ICC)-related sanctions list maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).
#TTCSN

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

US has imposed visa restrictions on Tanzanian Police Force Senior Assistant Commissioner Faustine Jackson Mafwele, barring him from entering the United States under Section 7031(c) of the National Security, Department of State, and Related Programs Appropriations Act, 2026.#TTCSN

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

The European Court of Justice has issued a preliminary ruling confirming that assets held through trusts may be frozen under Council Regulation (EU) No 269/2014 where sanctioned individuals retain ownership interests or exercise control over those assets.
#TTCSN #TürkiyeTrade

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

The United States has removed Francesca Albanese from sanctions imposed under Executive Order 14203 linked to measures targeting activities associated with the International Criminal Court.
#TTCSN #TürkiyeTradeCompliance #ExportControl #SanctionsUpdate #USA #OFAC #EU #UK #BIS

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

A Belarusian citizen, Yana Leonova, has pleaded guilty before the United States District Court for the District of Columbia to violating the Export Control Reform Act in connection with the unlawful export of US-origin aviation components to Russia.
#TTCSN #TürkiyeTrade

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has imposed new counterterrorism sanctions against nine individuals linked to Hizballah under Executive Order 13224, as amended.
#TTCSN #TürkiyeTradeCompliance #ExportControl #SanctionsUpdate #USA

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

OFAC announced a new round of counterterrorism and Iran-related sanctions on 19 May 2026, targeting individuals, commercial entities, and vessels alleged to be involved in financial, logistical, and operational support for Hamas and Iranian trade networks.
#TTCSN

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

OFSI has imposed a £165,000 monetary penalty on Deutsche Bank AG London Branch (“DBLB”) for breaches of the UK’s Russia sanctions regime linked to payments processed in 2022 involving Russian streaming platform Okko LLC.
#TTCSN #TürkiyeTradeCompliance #ExportControl #Sanctions

[Turkish Trade Compliance & Sanctions Network @ttcsnetwork]

OFAC has issued General License 134C under multiple Russia-, Iran-, and counterproliferation-related sanctions authorities, extending authorization for certain transactions involving Russian-origin crude oil and petroleum products loaded onto vessels before 17 April 2026.

#TTCSN