Wednesday, March 21, 2012


Businesses in the Republic of Turkey, with government approval, continue to ignore EU and US sanctions against Iran, due to its ongoing prohibited WMD and ballistic missile programmes. Turkey has adopted the lesser United Nations sanctions, and continues to trade with Iran, including in oil & gas.

With the almost universal monetary barriers now in place, including the expulsion of Iranian banks from the financial conduit performed by the SWIFT network, alternative methods of payment, including bulk cash, and precious metals and jewels are reportedly being employed by Iranian purchasers dealing with Turkish suppliers.

Under the circumstances, with the decline of the use of the United Arab Emirates (UAE) as a third-party agent to evade global sanctions, Turkey has emerged as one of the jurisdictions du jour, and for that reason, you are advised to review the facts, and, consider the decision to raise country risk on Turkey at this time. You do not want to be "named and shamed" on the US Treasury OFAC website on the monthly Fines and Penalties list. More importantly, you and your clients certainly do not to become involved in any criminal action.

It is prudent to examine all large ongoing client transactions with Turkish clients, paying special attention to any goods or services that might possibly be deemed "Dual Purpose" by US law enforcement agencies. New client business with Turkish customers, that did not exist before 2012, is especially noteworthy; Watch yourself here.

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