International sanctions regimes and export control regulations have become increasingly determinative for cross-border trade and financial transactions. Güzeloğlu Attorneys-at-law provides comprehensive advisory services to clients under OFAC, EU, UN Security Council, UK OFSI, and other sanctions regimes.
Within the globalised trade order, international sanctions and export control regimes have moved to the centre of corporate compliance obligations. Sanctions imposed by the United States, the European Union, the United Kingdom, and the United Nations directly affect Turkish companies across a broad spectrum — from financial transactions to goods exports, from shipping to information technology services. The proper management of this multi-layered regulatory framework is essential to ensure the continuity of clients' commercial operations and to protect them from criminal and administrative sanctions.
1. International Sanctions Regimes
Güzeloğlu Attorneys-at-law provides integrated legal advisory to clients under sanctions regimes across multiple jurisdictions. The sanctions programs administered by OFAC (Office of Foreign Assets Control), within the US Department of the Treasury, include comprehensive measures targeting Iran, Russia, North Korea, Syria, Cuba, and other designated countries. The EU consolidated sanctions list, UN Security Council resolutions, and UK OFSI (Office of Financial Sanctions Implementation) regulations also affect Turkish companies with differing scopes and applications. The intersections and conflicts between these regimes require independent legal analysis.
2. Correspondent Banking and RFI Responses
International financial transactions of Turkish banks and companies are subject to sanctions compliance checks throughout the correspondent banking network. Requests for Information (RFIs) from major correspondent banks such as Standard Chartered, JP Morgan, and Deutsche Bank are typically triggered by red flags arising from sanctions screening. Our firm has deep experience in preparing RFI responses on behalf of our clients, conducting sanctions nexus analysis, and submitting technical explanations to banks. Particularly in Iran and Russia nexus analyses, the evaluation of transaction history and commercial relationships from a sanctions perspective requires meticulous examination.
3. Export Control and Dual-Use Goods
Türkiye's commitments under Council of Ministers Decree No. 2002/4536 and the Wassenaar Arrangement require special authorisation for the export of dual-use items. These items include civilian products that may also be used for military purposes (semiconductors, measurement equipment, chemicals, software). The US EAR (Export Administration Regulations) and the EU Dual-Use Regulation (2021/821) impose additional compliance obligations on Turkish exporters. Our firm provides advisory services in preparing export licence applications, reviewing end-user certificates, and establishing export control compliance programmes.
4. OFAC Licence Applications and General Licences
Under OFAC sanctions, certain transactions may be carried out through the use of a specific licence or a general licence. The preparation of specific licence applications, the submission of documents and justifications expected by OFAC, and the management of the process require meticulous expertise. Proper interpretation and application of general licences is also critical for compliance. Our firm provides legal support to our clients at all stages of OFAC licence processes — from application preparation to compliance monitoring of licence conditions.
5. EU Sanctions and Turkish Companies
Sanctions implemented under EU Council Regulations and Decisions have expanded dramatically, particularly following Russia's invasion of Ukraine. The indirect effects of EU sanctions packages on Turkish companies — especially with allegations of "sanctions circumvention" — have become a significant agenda item in the recent period. The control mechanisms introduced under the EU's 14th sanctions package and beyond effectively require third-country companies to behave in a compliant manner. Our firm assesses the risks of Turkish companies under EU sanctions and develops compliance strategies.
6. Sanctions Compliance Programmes and Training
An effective sanctions compliance programme encompasses the establishment of internal policies, employee training, selection and configuration of sanctions screening software, third-party due diligence processes, and development of incident response protocols in case of violation. Our firm provides advisory services in designing, reviewing, and updating sanctions compliance programmes appropriate to the sector and risk profile of our clients. Tailored training programmes for management and compliance personnel are also an important part of our service portfolio.
7. Sanctions Violation Investigations and Defence
Defending clients in sanctions violation investigations initiated by OFAC, OFSI, or EU authorities requires high expertise, linguistic capabilities, and international cooperation. Our firm provides comprehensive legal representation to our clients at all stages of investigation proceedings — from document production to voluntary self-disclosure strategies, from settlement negotiations to appeals. Working in cooperation with foreign counsel focused on US and EU law, we provide effective defence in cross-border investigations.
For expert advisory services in sanctions and export control law, please contact us at info@guzeloglu.legal.