Trump Towers, Ofis Kule:2 Kat:18, No:12, Sisli, Istanbul, Turkey

Sanctions and Export Controls

Sanctions and export controls are one of HERDEM’s areas of special focus. We advise Turkish manufacturers, traders, banks and defence suppliers whose business reaches the United States, the European Union or the United Kingdom, and foreign companies that need to understand Türkiye’s own controls before they invest, buy or transfer technology here. Because Türkiye is not bound by EU, UK or US sanctions as such, the questions usually turn on contracts, banks, ownership and the origin of the goods, and that is where we focus.

How we help

  • US sanctions and export controls for Turkish companies, including OFAC, the EAR and ITAR
  • Türkiye’s export controls for foreign clients: the dual-use regime and, separately, the controls on military goods
  • Voluntary self-disclosure under Türkiye’s dual-use control framework
  • Classification of goods and technology, and licence applications
  • Counterparty, ownership and end-use screening, including the 50 per cent ownership rules
  • Sanctions clauses in supply, distribution, finance and charter contracts
  • Responding to a listing: what it means in Türkiye and the route to delisting
  • In-house training on ITAR and EAR compliance

Questions clients bring to us

  • Our customer’s parent company has just been listed. Can we still ship?
  • Does an EU or US rule apply to a Turkish company at all, and through which link?
  • Is our product dual-use under Turkish law, or a military item, and which authority licenses it?
  • Our bank has frozen a payment over sanctions concerns. What can we do?

Related industries

Related analysis

Speak to us

Simge Kılıç, Managing Partner and co-founder of the Turkish Trade Compliance & Sanctions Network (TTCSN), leads this practice. Send us a message below or contact our Istanbul office.


Kustepe Mahallesi, Mecidiyekoy Yolu Caddesi, Trump Towers, Ofis Kule:2 Kat:18, No:12, Sisli Mecidiyekoy, Istanbul, Turkey

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