A Remarkable Extension

Inside the busy agenda of Turkey and the world, the US President extended the Executive Order (EO) 13894 for 1 year on 14 October 2020. It is important to remember that the said EO have been issued by US President Trump on 14 Oct 2019 due to the military actions of Turkey on Northern Syria. The EO have given broad authorities to the Secretary of the Treasury and Secretary of the State to implement sanctions on persons, entities and sectors that are mentioned in the order. By this extension both Secretaries keep the authority till 14 October 2021.

The Secretary of the Treasury have been authorized sanctions in consultation with the Secretary of the State as follows;

(A) to be responsible for or complicit in, or to have directly or indirectly engaged in, or attempted to engage in, any of the following in or in relation to Syria:

(1) actions or policies that further threaten the peace, security, stability, or territorial integrity of Syria; or

(2) the commission of serious human rights abuse;

(B) to be a current or former official of the Government of Turkey;

(C) to be any subdivision, agency, or instrumentality of the Government of Turkey;

(D) to operate in such sectors of the Turkish economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State;

(E) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to this order; or

(F) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order.

The Secretary of the State have been authorized sanctions in consultation with the Secretary of the Treasury as follows;

…

(a) (i) is responsible for or complicit in, has directly or indirectly engaged in, or attempted to engage in, or financed, any of the following:

(A) the obstruction, disruption, or prevention of a ceasefire in northern Syria;

(B) the intimidation or prevention of displaced persons from voluntarily returning to their places of residence in Syria;

(C) the forcible repatriation of persons or refugees to Syria; or

(D) the obstruction, disruption, or prevention of efforts to promote a political solution to the conflict in Syria, including:

(1) the convening and conduct of a credible and inclusive Syrian-led constitutional process under the auspices of the United Nations (UN);

(2) the preparation for and conduct of UN-supervised elections, pursuant to the new constitution, that are free and fair and to the highest international standards of transparency and accountability; or

(3) the development of a new Syrian government that is representative and reflects the will of the Syrian people;

(ii) is an adult family member of a person designated under subsection (a)(i) of this section; or

(iii) is responsible for or complicit in, or has directly or indirectly engaged in, or attempted to engage in, the expropriation of property, including real property, for personal gain or political purposes in Syria.

There are several sanction for each category such as investment restrictions, loan/equity limitations, foreign exchange transactions bans, the blocking of properties in US… One remarkable point is sanctions have not been restricted with the governmental parties also sectoral sanctions, which has been widely used since 2014 starting with Russian Sanctions, are mentioned among the sanction clauses.