EN-US 
TR-TR On 1 October 2025, Türkiye implemented new asset-freeze measures against persons and entities linked to Iran’s nuclear program through Presidential Decision No. 10438, published in the Official Gazette (EK-5 update). The decision, grounded in UN Security Council Resolution 2231 (2015) and enforced domestically under Law No. 7262 on the Prevention of the Financing of the Proliferation of Weapons of Mass Destruction, expands Türkiye’s earlier implementation of UN obligations. This step aligns Türkiye’s framework with evolving international sanctions trends following the EU’s reactivation of nuclear restrictions under the “snapback” mechanism and concurrent U.S. actions. Turkish financial institutions, logistics operators, and insurers are now required to exercise heightened diligence in identifying and managing potential exposure to these newly listed parties.
Legal and regulatory background
Türkiye has periodically implemented UN sanctions decisions related to Iran since 2006. The latest decree builds upon earlier enactments in 2015 and 2021, broadening the EK-5 annex to include 20 individuals and 19 entities directly associated with Iran’s nuclear research, financing, and logistics activities. Once published, these measures became legally binding and enforceable without further administrative action. The listing encompasses key Iranian nuclear and research organizations, including the Atomic Energy Organization of Iran (AEOI), several Isfahan-based research centers, Bank Sepah and its international arm, as well as shipping and industrial entities forming part of Iran’s nuclear supply and distribution framework. Turkish entities must immediately enforce asset freezes and examine both direct and indirect connections, including ownership, intermediaries, and “on-behalf-of” transactions.
Listed persons and entities (Official Gazette, 1 October 2025, Decision No. 10438, EK-5)
Individuals (20): Dawood Agha-Jani, Amir Moayyed Alai, Behman Asgarpour, Mohammad Fedai Ashiani, Abbas Rezaee Ashtiani, Haleh Bakhtiar, Morteza Behzad, Seyyed Hussein Hosseini, Ali Hajinia Leilabadi, Hamid-Reza Mohajerani, Jafar Mohammadi, Ehsan Monajemi, Houshang Nobar, Mohammad Qannadi, Amir Rahimi, Javad Rahiqi, Abbas Rashidi, M. Javad Karimi Sabet, Seyed Jaber Safdari, and Ghasem Soleymani.
Entities (19): Atomic Energy Organization of Iran (AEOI), Bank Sepah, Bank Sepah International, Isfahan Nuclear Fuel Research & Production Center (NFRPC), Isfahan Nuclear Technology Center (ENTC), First East Export Bank, Irano Hind Shipping Company, IRISL Benelux NV, Jabber Ibn Hayyan, Karaj Nuclear Research Center, Kavoshyar Company, Mesbah Energy Company, Modern Industries Technique Company, Novin Energy Company, Nuclear Research Center for Agriculture and Medicine (NRCAM), Pars Trash Company, Pishgam Energy Industries, South Shipping Line Iran, and Tamas Company.
Implementation and procedure under Turkish law
Law No. 7262 provides the statutory basis for transposing UN sanctions into the domestic system. An asset freeze under this law operates as a preventive and temporary restriction on the use or transfer of assets rather than as a confiscation. The freeze applies to financial accounts, securities, movable and immovable property, and shareholdings. The Ministry of Treasury and Finance coordinates enforcement, ensuring banks, financial institutions, and registries implement blocking orders immediately upon notification. Affected persons and entities may seek administrative review before the Audit & Cooperation Commission, and judicial recourse before administrative courts is available to challenge listings based on competence, due process, or proportionality.
Compliance expectations for operators in Türkiye
Financial institutions are expected to conduct immediate screening, block identified assets, review historical dealings, and assess beneficial ownership chains. Companies engaged in trade, shipping, or logistics should apply enhanced end-use and end-user checks, verify cargo routing and trans-shipment details, and ensure alignment between shipping and customs documentation. Insurers and reinsurers should reassess their sanctions clauses, reinsurance coverage structures, and exposure under contracts involving Iranian-related risks. Given the broader reach of EU and U.S. sanctions, Turkish businesses interacting with international financial systems must anticipate stricter compliance standards and longer processing times.
Contractual risk management and governance considerations
Contracts should include adaptable sanctions clauses that can respond to regulatory changes, incorporating representations, termination or suspension rights, and change-in-law provisions. Financial and trade documentation should also address events of default arising from sanctions exposure and include proportional remedies consistent with Turkish public order principles. At the organizational level, companies should adopt formal sanctions compliance frameworks, maintain clear escalation mechanisms, and provide internal training for staff involved in compliance and risk management functions. Detailed records of screening, UBO verification, and remediation efforts should be maintained to evidence compliance.
Legal remedies and review procedures
Persons or entities subject to asset freezes may petition the Audit & Cooperation Commission for an administrative review. Judicial review by administrative courts allows for an examination of procedural fairness, proportionality, and compliance with Turkish administrative law standards while balancing national security interests.
Geopolitical implications
The 2025 decree aligns Türkiye’s sanctions implementation more closely with the EU and U.S. frameworks while maintaining its own independent legal process. Although disputes persist among major powers regarding the legality of the snapback mechanism, the practical result is increased compliance pressure across financial and trade networks. For Turkish businesses, indirect exposure through supply chains, counterparties, or financing arrangements will demand continuous monitoring and risk reassessment.
Advisory perspective
HERDEM Attorneys at Law supports clients in understanding and managing the implications of Türkiye’s evolving sanctions regime. The firm advises on compliance program design, sanctions risk mapping, end-use verification, contractual safeguards, and the integration of internal control mechanisms. HERDEM also represents clients in administrative proceedings before the Audit & Cooperation Commission and judicial challenges in administrative courts. By combining deep knowledge of Turkish regulatory practice with cross-border compliance insight, the firm assists clients in navigating sanctions, export controls, and transaction risk across banking, trade, insurance, logistics, and defense-related sectors.
