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President Trump directed this morning that sanctions imposed 10/14 on the Turkish Ministries of Defense and Energy, plus their Ministers and the Minister of the Interior, be lifted in light of Turkey’s agreement to a “permanent” ceasefire.  OFAC immediately implemented that directive and removed the parties from the SDN List.

However, Congress could still enact legislation requiring sanctions – as it did in CAATSA. So parties doing business in Turkey, particularly in the defense sector, should continue to monitor the situation. And parties operating in the EU also need to keep EU military sales restrictions in mind.