Home / Research / Trackers / Third-Country Sanctions Monitor
Third-Country Sanctions Monitor · Türkiye
Which Turkish Firms Have the US, EU and UK Sanctioned Since 2024?
Every US, EU and UK measure since January 2024 under the Russia and Iran sanctions programmes against firms and people with an address in Türkiye, with the rules that reach Türkiye, the trade at stake and what to watch.
Official measures only, each linked to its source. A listing records what a government did; it is not a finding by this publication. Not legal advice.
Photo: A bulk carrier passing under the Fatih Sultan Mehmet Bridge, Bosphorus, Istanbul, 4 July 2012. Moonik via Wikimedia Commons, CC BY-SA 3.0.
- Latest action
- 1 October 2026
- Measures in 2026
- 44
US Treasury (OFAC): Added 1 firm with an address in Türkiye to the SDN List under its Iran sanctions.
to 6 October 2026
Summary
Key points
- 1
Since January 2024 the US, EU and UK have taken 198 measures against firms and people with an address in Türkiye: 153 by the US, 36 by the EU and 9 by the UK. 26 of them concern people.
- 2
85 of the US measures are under its Russia programmes and 68 under its Iran programmes. 29 of the EU measures are export restrictions under Annex IV of Regulation 833/2014.
- 3
The largest single action was taken by the US State Department on 30 October 2024: 16 listings of firms with an address in Türkiye.
- 4
In 2025 Türkiye sold US$152.6bn of goods to the US, the EU and the UK, 56% of its goods exports, and bought US$42.4bn of goods from Russia.
Measures
How many measures have been taken since 2024, and by whom?
Measures against firms and people with an address in Türkiye, by the year of the measure and the authority that took it: 68 under Iran programmes, 130 under Russia programmes. Against firms 172, against people 26. A further 12 US listings made since 2024 in Türkiye were later removed by OFAC; they are not counted here and are listed in the removals file.
| Year | US | EU | UK | Total |
|---|---|---|---|---|
| 2024 | 89 | 10 | 5 | 104 |
| 2025 | 32 | 15 | 3 | 50 |
| 2026 (to 6 October 2026) | 32 | 11 | 1 | 44 |
| Since January 2024 | 153 | 36 | 9 | 198 |
A firm or person with addresses in two tracked countries is counted under the first address the authority lists. People are counted, not named, on this page; the official names are in the CSV.
All measures (CSV) · Listings removed since 2024 (CSV) · Method
Record
Every action since January 2024, newest first
Each entry is one official action: who took it, what it did, the firms it named, and links to the official page and press release. Filter by authority.
- US Treasury (OFAC)
Added 1 firm with an address in Türkiye to the SDN List under its Iran sanctions.
Troy Trading Arac Parcalari Sanayi Ve Ticaret Limited Sirketi
- US Treasury (OFAC)
Added 1 firm with an address in Türkiye to the SDN List under its Iran sanctions.
Cavalier Dynamics Teknoloji Ticaret Anonim Sirketi
- US Treasury (OFAC)
Added 3 firms with an address in Türkiye to the SDN List under its Iran sanctions.
Sky Phoenix Hava Yollari Tasimaciligi Ticaret Limited Sirketi, S Sistem Lojistik Hizmetler Anonim Sirketi, Mes Cargo Transportation Tourism and Foreign Trade Limited Company
- US Treasury (OFAC)
Added 3 firms with an address in Türkiye to the SDN List under its Iran sanctions.
Golden Global Yatirim Bankasi Anonim Sirketi, Golden Global Varlik Kiralama Anonim Sirketi, Golden Global Portfoy Yonetimi Anonim Sirketi
- US State Department
Designated 4 firms and 2 people with an address in Türkiye under US Iran sanctions; OFAC added them to the SDN List.
Starplas Kimya Sanayi Ve Ticaret Anonim Sirket, SELFPLAST PLASTIK AMBALAJ SANAYI DIS TICARET LIMITED SIRKETI, Oshida Petrokimya Urunleri Sanayi Ve Ticaret Anonim Sirketi, HUZUR PLASTIK KIMYEVI MADDELER ITHALAT IHRACAT SANAYI VE TICARET LIMITED SIRKETI
- US Treasury (OFAC)
Added 3 people with an address in Türkiye to the SDN List under its Iran sanctions.
- US Treasury (OFAC)
Added 1 firm with an address in Türkiye to the SDN List under its Iran sanctions.
Zedpay Finansal Sistem Ve Hizmetleri Anonim Sirketi
- Council of the EU
Added 4 firms with an address in Türkiye to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to them.
Uzay Group Dis Ticaret Limited Sirketi, Suvari Global Endustriyel Ekipmanlar İthalat İhracat Ticaret Limited Șirketi, Mastel Makina Ithalat Ihracat Limited Sirketi, Alfatrex Dis Ticaret Limited Sirketi
- UK government
Designated 1 firm with an address in Türkiye on the UK Sanctions List under its Russia sanctions.
SHTRAL MAKINE ITHALAT IHRACAT SANAYI VE TICARET LIMITED
UK Sanctions List entries (linked from each name)
- Council of the EU
Listed 3 firms with an address in Türkiye for an asset freeze under its Russia sanctions.
Trans KA Tankers Management Company Limited, East Gemi İşletmeciliği AS, EMT Gemi İşletmeciliği AS
- US Treasury (OFAC)
Added 3 people with an address in Türkiye to the SDN List under its Iran sanctions.
- US Treasury (OFAC)
Added 1 person with an address in Türkiye to the SDN List under its Iran sanctions.
- Council of the EU
Added 4 firms with an address in Türkiye to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to them.
Meryn Dis Ticaret Limited Sirketi, Epic Shipping & Shipbuilding JSC, Autoteile Dis Ticaret Limited Sirketi, Abem Global Ithalat Ihracat Anonim Sirketi
- US Treasury (OFAC)
Added 1 firm and 1 person with an address in Türkiye to the SDN List under its Iran sanctions.
Emti Fiber Textile Import Export Trade Limited Company
- US Treasury (OFAC)
Added 3 firms with an address in Türkiye to the SDN List under its Iran sanctions.
Utus Gumrukleme Gida Tekstil Ithalat Ihracat Dis Ticaret Ve Sanayi Limited Sirketi, Arya Global Gida Sanayi Ve Ticaret Limited Sirketi, ALTIS TEKSTIL MAKINA TICARET LIMITED SIRKETI
- US State Department
Designated 5 firms with an address in Türkiye under US Iran sanctions; OFAC added them to the SDN List.
STAREX DIS TICARET KIMYA ANONIM SIRKETI, MHK SHIPPING CORP, MARS OCEANWAY INC, DIAKO IC VE DIS TICARET ANONIM SIRKETI, AMON KIMYA VE MAKINA SANAYI VE TICARET LIMITED SIRKETI
- US Treasury (OFAC)
Added 7 firms and 2 people with an address in Türkiye to the SDN List under its Iran sanctions.
Royal Yapi Insaat Emlak Gida ve Tekstil Urunleri Turizm Sanayi Dis Ticaret Limited Sirketi, Ozkam Nakliyat Petrol Ithalat Ihracat Sanayi Ticaret Limited Sirketi, Own Ucar Gida Insaat Sanayi ve Ticaret Limited Sirketi, Loris Turizm Organizasyon Ithalat ve Ihracat Limited Sirketi, Intro Oto Yedek Parca Ithalat Ihracat Ticaret ve Sanayi Limited Sirketi, Artas Gumrukleme Ithalat Ihracat Sinir Ticareti Tekstil Gida ve Sanayi Ticaret Limited Sirketi, Arkedya Gida Tekstil Dis Ticaret Sanayi Limited Sirketi
- UK government
Designated 1 firm with an address in Türkiye on the UK Sanctions List under its Russia sanctions.
S-MIKRON ELEKTRONIK ELEKTRIK SANAYI TAAHHUT TICARET ANONIM SIRKETI
UK Sanctions List entries (linked from each name)
- US State Department
Designated 4 firms and 1 person with an address in Türkiye under US Iran sanctions; OFAC added them to the SDN List.
YESIL BASAK TARIM SANAYI VE TICARET LIMITED SIRKETI, MIKROTEKNIK KIMYEVI MADDELER LABORATUVAR MALZEMELERI VE CIHAZLARI SANAYI TICARET LIMITED SIRKETI, DINA PETROKIMYA SANAYI TICARET ANONIM SIRKETI, ABY PLASTIK AMBALAJ VE ENERJI SANAYI TICARET ANONIM SIRKETI
- US Treasury (OFAC)
Added 1 firm with an address in Türkiye to the SDN List under its Iran sanctions.
Cabuk Calisan Tasimacilik Ve Endustri Makineleri Ticaret Limited Sirketi
- UK government
Designated 1 firm with an address in Türkiye on the UK Sanctions List under its Russia sanctions.
MASTEL MAKINA ITHALAT IHRACAT LIMITED SIRKETI
UK Sanctions List entries (linked from each name)
- US Treasury (OFAC)
Added 2 firms with an address in Türkiye to the SDN List under its Iran sanctions.
WESTANKER DENIZCILIK VE TICARET LIMITED SIRKETI, GREEN ENERGY CHEMICALS ENERJI KIMYASALLARI SANAYI TICARET ANONIM SIRKETI
- US State Department
Designated 3 firms with an address in Türkiye under US Iran sanctions; OFAC added them to the SDN List.
LAVINYA PLAST KIMYEVI MADDELER VE PETROL URUNLERI NAKLIYE SANAYI IC VE DIS TICARET ANONIM SIRKETI, FIVA PLASTIK ANONIM SIRKETI, ELM KIMYA ITHALAT IHRACAT SANAYI VE TICARET ANONIM SIRKETI
- Council of the EU
Added 4 firms with an address in Türkiye to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to them.
ILMOR KIMYA VE TEKSTIL SANAYI VE TIC. LTD, FS DIS TICARET A. S., BOSFORLAB DIS TICARET LTD, BASHTRADEHOUSE IC VE DIS TICARET LTD
- US Treasury (OFAC)
Added 2 firms with an address in Türkiye to the SDN List under its Iran sanctions.
PULCULAR ENERJI SANAYI VE TICARET ANONIM SIRKETI, GOLDEN GLOBE DEMIR CELIK PETROL SANAYI VE TICARET ANONIM SIRKETI
- US Treasury (OFAC)
Added 1 firm with an address in Türkiye to the SDN List under its Iran sanctions.
Edisa Dis Ticaret Limited Sirketi
- Council of the EU
Added 6 firms with an address in Türkiye to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to them.
Stimul Engineering Ltd., Over the Line, Kocaeli Kesici Takimlar Makine Sanayi Ticaret Ltd, GTCT Ltd., Etkin Hirdavat Insaat Pazarlama Sanayi Ve Ticaret Limited., CS Yönetim ve Destek Hizmetleri Ltd.
- Council of the EU
Listed 1 firm and 1 person with an address in Türkiye for an asset freeze under its Russia sanctions.
AFA Media
- Council of the EU
Listed 1 firm with an address in Türkiye for an asset freeze under its Russia sanctions.
Cape Gemi Isletmeciligi AS
- US State Department
Designated 1 firm with an address in Türkiye under US Iran sanctions; OFAC added it to the SDN List.
Kimpas Kimyevi Maddeler Pazarlama Ticaret Ve Sanayii Anonim Sirketi
- Council of the EU
Added 1 firm with an address in Türkiye to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to it.
Burmech Teknoloji Makina Sanayi Ve Ticaret Limited Șirketi
- UK government
Designated 1 firm with an address in Türkiye on the UK Sanctions List under its Russia sanctions.
MCR GLOBAL ELEKTRONIK SANAYI VE TICARET LTD SIRKETI
UK Sanctions List entries (linked from each name)
- Council of the EU
Listed 1 firm with an address in Türkiye for an asset freeze under its Russia sanctions.
Enutek Makina Sanayi Ve Ticaret
- US State Department
Designated 7 firms and 1 person with an address in Türkiye under US Russia sanctions; OFAC added them to the SDN List.
YMV KREYN VE MAKINA SISTEMLERI SANAYI TICARET ANONIM SIRKETI, SERMAX LOJISTIK SANAYI VE DIS TICARET LIMITED SIRKETI, SAHINLER METAL MAKINA ENDUSTRI ANONIM SIRKETI, CS YONETIM VE DESTEK HIZMETLERI LIMITED SIRKETI, BIMAKSAN TAKIM TEZGAHLARI SANAYI VE DIS TICARET MUHLIS KOKSAL VE ORTAGI KOLLEKTIF SIRKETI, Atlasnoble Gayrimenkul Danismanlik Anonim Sirketi, ARMIDA MAKINA IC VE DIS TICARET LIMITED SIRKETI
- US Treasury (OFAC)
Added 1 firm with an address in Türkiye to the SDN List under its Russia sanctions.
TGR Partners
- UK government
Designated 1 firm with an address in Türkiye on the UK Sanctions List under its Russia sanctions.
BY INOVASYON TEKNOLOJI SANAYI VE TICARET LIMITED SIRKETI
UK Sanctions List entries (linked from each name)
- US State Department
Designated 16 firms with an address in Türkiye under US Russia sanctions; OFAC added them to the SDN List.
TURBOSHAFT DIS TICARET LIMITED SIRKETI, TIOSEAL ISI VE IZOLASYON MALZEMELERI SANAYI TICARET LIMITED SIRKETI, SUVARI GLOBAL ENDUSTRIYEL EKIPMANLAR ITHALAT IHRACAT TICARET LIMITED SIRKETI, SOLID TARIM INOVASYON ANONIM SIRKETI, SERATAN LOJISTIK VE DIS TICARET LIMITED SIRKETI, REKA GRUP DANISMANLIK VE TICARET LIMITED SIRKETI, OZ RULMAN TICARET VE SANAYI LIMITED SIRKETI, MNR Lojistik Ve Dis Ticaret Limited Sirketi
and 8 more
MAS LOGEX DIS TICARET VE LOJISTIK SANAYI LIMITED SIRKETI, KHIUS ULUSLARARASI TICARET VE LOJISTIK ANONIM SIRKETI, Icon Endustri Ihracat Ticaret Limited Sirketi, Guclu Global Lojistik Limited Sirketi, ELEKTROPANEL MUHENDISLIK SANAYI VE TICARET LIMITED SIRKETI, CBG TECH DIS TICARET LIMITED SIRKETI, AVAT ENDUSTRIYEL SISTEMLERI IC VE DIS TICARET LIMITED SIRKETI, ALTERNATE HAVACILIK SANAYI VE DIS TICARET EGITIM DANISMANLIK LIMITED SIRKETI
- US Treasury (OFAC)
Added 8 firms and 6 people with an address in Türkiye to the SDN List under its Russia sanctions.
Sanlitun Yatirim Dis Ticaret Limited Sirketi, SLD Lojistik lc Ve Dis Ticaret Limited Sirketi, SINERJI ENDUSTRIYEL EKIPMAN VE INSAAT MALZEMELERI DIS TICARET LIMITED SIRKETI, NEW WAY GROUP GLOBAL DANISMANLIK TICARET LIMITED SIRKETI, MIREX HAVACILIK VE SAVUNMA SANAYI TICARET ANONIM SERKETI, CRESTA LOJISTIK ITHALAT IHRACAT TICARET SIRKETI, BRK ULUSLARARASI NAKLIYAT VE TICARET LIMITED SIRKETI, BP DIS TICARET VE DANISMANLIK LIMITED SIRKETI
- US Treasury (OFAC)
Added 5 firms and 1 person with an address in Türkiye to the SDN List under its Russia sanctions.
Whitestone Bilism Tic Ve Sanayi Ltd Sti, TAHA SAVUNMA SANAYI VE TICARET ANONIM SIRKETI, FEVA DIS TICARET LIMITED SIRKETI, ENUTEK MAKINA SANAYI VE TICARET LIMITED SIRKETI, CONFIENZA GIDA PAZARLAMA VE TICARET ANONIM SIRKETI
- US State Department
Designated 5 firms with an address in Türkiye under US Russia sanctions; OFAC added them to the SDN List.
NET SISTEM DANISMANLIK VE EGITIM HIZMETLERI LIMITED SIRKETI, Meta CNC Sanayi Ve Ticaret Limited Sirketi, MEDITERRANEAN INTERNATIONAL TRADING DIS TICARET LIMITED SIRKETI, LGM PROCESS DIS TICARET LIMITED, Kayra Elektronik Limited Sirketi
- US Treasury (OFAC)
Added 1 firm and 1 person with an address in Türkiye to the SDN List under its Iran sanctions.
Golden Stars Kiymetli Madenler Tekstil Sanayi Ticaret Limited Sirketi
- Council of the EU
Added 9 firms with an address in Türkiye to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to them.
Smart Trading Tasimacilik Sanayi Ve Ticaret Limited, Orel Dis Tic. Ltd. Sti, Megasan Elektronik Ticaret Ve Sanayi A S, Karasani Dis Ticaret Limited Sirketi, Ix Elektronik Ic Ve Dis Ticaret Limited, Ervacan Makina Ekipmanlari Ve San Ted Ltd, CTL Dis Ticaret Limited, Bion Group Ic Ve Dis Ticaret Limited
and 1 more
Bee Insaat Mimarlik Anonim Sirketi
- UK government
Designated 2 firms with an address in Türkiye on the UK Sanctions List under its Russia sanctions.
EGETIR OTOMOTIV SAN. VE TIC. LTD., BOSFOR AVRASYA IC VE DIS TICARET LTD
UK Sanctions List entries (linked from each name)
- US Treasury (OFAC)
Added 11 firms with an address in Türkiye to the SDN List under its Russia sanctions.
TAKSAN MAKINA SANAYI VE TICARET ANONIM SIRKETI, Safes Lojistik Ithalat Ihracat Sanayi Ticaret Limited, RMB YAPI INSAAT TAAHHUT SANAYI VE TICARET LIMITED SIRKETI, Platform Endustriyel Gida Insaat Elektronik ve Madencilik Dis Ticaret Limited Sirketi, Onyad Bilgisayar Ticaret Sirketi, KAMILHAN LOJISTIK DIS TICARET LIMITED SIRKETI, GEPA ULUSLARARASI TICARET LIMITED SIRKETI, EXPERT MACHINERY KIMYASAL URUNLER TICARET LIMITED SIRKETI
and 3 more
DENER ITHALAT IHRACAT VE DIS TICARET ANONIM SIRKETI, Biopharmist Medikal Urunler Dis Ticaret Ltd Sti, Alptech Makina Sanayi Limited Sirketi
- US State Department
Designated 6 firms with an address in Türkiye under US Russia sanctions; OFAC added them to the SDN List.
PLATIN GROUP MACHINE MANUFACTURING INTERNATIONAL COMPANY LTD, KOC GEMICILIK VE TASIMACILIK DIS TICARET LIMITED SIRKETI, CNCFORM GRUP MAKINA METAL INSAAT HIRDAYAT GIDA NAKLIYE OTOMOTIV ITHALAT IHRACAT SANAYI VE TICARET LIMITED SIRKETI, BULUTLAR GEMI TERSANECILIK SANAYI TICARET LIMITED SIRKETI, BEE INSAAT MIMARLIK ANONIM SIRKETI, ANKARA GLOBAL DIS TICARET LIMITED SIRKETI
- US Treasury (OFAC)
Added 1 firm with an address in Türkiye to the SDN List under its Iran sanctions.
LOUIS MARINE SHIPHOLDING ENTERPRISES S.A.
- US State Department
Designated 9 firms with an address in Türkiye under US Russia sanctions; OFAC added them to the SDN List.
UZAY GROUP DIS TICARET LIMITED SIRKETI, NA HAVACILIK VE TEKNIK TICARET LIMITED SIRKETI, Modmer Trading Uluslararasi Ithalat Ve Ihracat Limited Sirketi, Marten Ea Trading Insaat Ve Dis Ticaret Pazarlama Limited Sirketi, LSS Global Insaat Sanayi Ve Ticaret Limited Sirketi, GQ SOLUTION ELEKTRONIK EKIPMAN LIMITED SIRKETI, Evol Group Tr Yazilim Limited Sirketi, BELLUGA IC VE DIS TICARET LIMITED SIRKETI
and 1 more
Asay Ic Ve Dis Ticaret Limited Sirketi
- US Treasury (OFAC)
Added 6 firms with an address in Türkiye to the SDN List under its Russia sanctions.
OOO ORLAN, MSO LOJISTIK TIC VE SANAYI LTD STI, GONUL EXPORT LOJISTIK TICARET VE SANAYI LIMITED SIRKETI, GIF GROUPE DINVESTISSEMENT FINANCI OSBORNE DIS TIC LTD STI, ALPHA IMPEX ITHALAT VE IHRACAT DIS TICARET LIMITED SIRKETI, A Y A UNIVERSAL DENIZCILIK KUMANYACILIK LIMAN HIZMETLERI ITHALAT IHRACAT LIMITED SIRKETI
- US Treasury (OFAC)
Added 1 firm with an address in Türkiye to the SDN List under its Iran sanctions.
HSF DIS TICARET LIMITED SIRKETI
- US Treasury (OFAC)
Added 5 firms and 1 person with an address in Türkiye to the SDN List under its Iran sanctions.
Tit Uluslararasi Nakliyat Deri Tekstil Gida Sanayi Ve Ticaret Limited Sirketi, Skies Petroleum (Treasury’s short name; full listed name in the download), Klas Kimyasal Urunler Ticaret Limited Sirketi, Gokler Dis Ticaret Limited Sirketi, DM Gold Kiymetli Madenler Anonim Sirketi
- US State Department
Designated 3 firms with an address in Türkiye under US Russia sanctions; OFAC added them to the SDN List.
OLIMPIK GAMA IC VE DIS TICARET SANAYI LIMITED SIRKETI, MBK Lojistik Medikal Pazarlama Sanayi Ic Ve Dis Ticaret Limited Sirketi, ALPHA VISIT SHOP FOREIGN TRADE LIMITED COMPANY
- Council of the EU
Added 1 firm with an address in Türkiye to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to it.
Yildiz Çip Teknoloji Elektronik Elektrik Bilgisayar Malzemeleri Ticaret Sanayi Limited Sirketi
- UK government
Designated 2 firms with an address in Türkiye on the UK Sanctions List under its Russia sanctions.
COZUM YAZILIM DONANIM ELEKTRONIK, BEKS SHIP MANAGEMENT AND TRADING JOINT STOCK COMPANY
UK Sanctions List entries (linked from each name)
- US Treasury (OFAC)
Added 2 people with an address in Türkiye to the SDN List under its Iran sanctions.
Rules
Which rules reach Türkiye, and what would trigger them?
Rules that reach firms and banks in Türkiye along with every other country. None of these names Türkiye alone.
| Rule | Made by | What it does | How it reaches the country | Status on 6 October 2026 |
|---|---|---|---|---|
| US extends Iran sector sanctions to the automotive and rail sectors (E.O. 13902)Determination under section 1(a)(i) of E.O. 13902: automotive and rail sectors of the Iranian economy (1 October 2026) | Treasury (OFAC). 1 October 2026 | Any person determined to operate in Iran’s automotive or rail sector can be blocked, with the same further reach as other E.O. 13902 sectors: persons who knowingly engage in significant transactions for goods or services used in the sector, and foreign banks that knowingly facilitate them. The same day OFAC designated auto-parts suppliers outside Iran for operating in the automotive sector. | Any person, wherever located. OFAC FAQ 831 says Iranian and non-Iranian persons operating in E.O. 13902 sectors could be sanctioned. | in forceIn force since 1 October 2026. Not yet published in the Federal Register on 6 October 2026.OFAC determination (1 October 2026) · Treasury press release sb0643 (1 October 2026) |
| Graham Act: duties on the largest buyers of Russian crude or gas, and mandatory sanctions on foreign firmsLindsey O. Graham Sanctioning Russia and Iran Act of 2026, Division A of H.R. 5334 (Public Law 119-111), sections 102, 103, 108, 110, 113, 115, 117 and 201 | Congress and the President; the President imposes the first duties, and the US Trade Representative adjusts the rates and, every 180 days, redoes the top-five importer lists and imposes duties on the countries named. 18 September 2026 | Requires duties of up to 100% on all goods from countries that were among the five largest importers by volume of Russian crude oil, or of Russian gas, in the 12 months before 18 September 2026 and knowingly buy again from the 30th day, and from the ‘top 5 countries facilitating Russian oil sanctions evasion’, by 18 October 2026. Other sections require sanctions on foreign suppliers to Russia’s defence industry, on owners, insurers and captains of vessels used to move Russian oil or gas around sanctions, on owners of foreign ports that serve US-sanctioned vessels, and on foreign banks that conduct significant transactions with Russian state-owned banks. | Any country that meets the Sec. 113 test; the Act names none. A country is exempt for gas if it took less than 15% of Russia’s gas exports and has taken significant steps to cut them (Sec. 113(d)). The sanctions sections reach foreign firms and banks anywhere. | partly in forceLaw since 18 September 2026. Sec. 102(d), which keeps in force by statute the sanctions and other measures under E.O. 14024 and the other orders issued under that national emergency (among them E.O.s 14066, 14068, 14071 and 14114), as they stood on 17 September 2026, applies now; Russia sanctions under other authorities, such as the 2014 Ukraine-related orders or CAATSA, are not covered. No country had been named, no duty imposed and no designation made under the Act by 6 October 2026. The President may waive a duty after certifying to Congress that a waiver is in the national interest (Sec. 115); ending one needs a certification in a report to Congress and a congressional review of 30 days, or 60 days if the report is sent between 10 July and 7 September (Sec. 117). Division A ends on 18 September 2031.Public Law 119-111, GovInfo · Congressional Research Service, Legal Sidebar LSB11474 |
| US Iran listing of Russia’s VTB Bank, and a warning to foreign banks that deal with itE.O. 13902, section 1(a)(i): operating in the financial sector of the Iranian economy | Treasury (OFAC). 14 September 2026 | OFAC added an Iran listing to VTB Bank, already blocked under US Russia sanctions, for operating in Iran’s financial sector. Treasury said foreign financial institutions that keep dealing with VTB face more sanctions risk and should cut off those relationships ‘immediately’. | Foreign banks anywhere that deal with VTB. VTB’s US list entry names a New Delhi branch and gives addresses in New Delhi, Shanghai and Beijing. | in forceIn force. OFAC’s lists on 5 October 2026 show no foreign bank cut off from US correspondent accounts over dealings with VTB.Treasury press release sb0629 (14 September 2026) · OFAC Recent Actions, 14 September 2026 |
| US extends Iran sector sanctions to aviation, digital assets, gold, shipping and technology (E.O. 13902)Determination under section 1(a)(i) of E.O. 13902 (91 FR 55265, 27 August 2026) | Treasury (OFAC), with the State Department. 24 August 2026 | Any person determined to operate in these five sectors of Iran’s economy can be blocked. Under E.O. 13902, a person who knowingly engages in a significant transaction for goods or services used in a covered sector can also be blocked, and a foreign bank that knowingly facilitates such a transaction can be barred from US correspondent or payable-through accounts. | Any person, wherever located: Treasury said OFAC ‘can now sanction any person, regardless of where they are located’ in these sectors. Each target still needs its own designation. | in forceIn force since 24 August 2026; no revocation or amendment found on 6 October 2026.Federal Register, Determination under E.O. 13902 (2026-17487) · Treasury press release sb0613 (24 August 2026) |
| UK ban on imports of oil products refined from Russian crude in third countriesThe Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (S.I. 2026/543), regulations 46Z9E to 46Z9I | UK government (FCDO); import licences from the Department for Business, Innovation, Science and Trade. 18 May 2026; in force 20 May 2026 | Bans importing into the UK oil products (commodity code 2710) processed in a third country from Russian crude, and related technical assistance, finance and brokering. A general trade licence (GBSAN0004) still allows diesel and jet fuel, and the government says it will end by 1 January 2027 at the latest. | Refiners in any country other than the UK, the Isle of Man and Russia that process Russian crude and sell oil products to the UK, and UK importers and service providers. The instrument names no country. | partly in forceIn force since 20 May 2026, except for diesel and jet fuel, which are allowed under licence GBSAN0004 until 1 January 2027 at the latest.S.I. 2026/543, legislation.gov.uk · UK government, 12 June 2026: end date for diesel and jet fuel imports |
| Russian crude oil price cap: $44.10 a barrel in the EU and the UK (the US cap is $60)Council Regulation (EU) No 833/2014, Article 3n and Annex XXVIII, as amended by Regulation 2025/1494 (dynamic cap), Commission Implementing Regulation 2026/124 ($44.10 from 1 February 2026) and Regulation 2026/1848 (reset suspended) | European Commission and Council of the EU; the UK applies the same level. 14 January 2026; in force 1 February 2026 | EU persons may trade, ship, insure or finance Russian crude for third countries only if it is bought at or below the cap, $44.10 a barrel since 1 February 2026 (products: $100 or $45). The EU’s automatic six-monthly reset is suspended until 15 July 2027; by 15 January 2027 the Commission reports and the Council may set a new level. | It binds EU persons and business done in the EU. Shippers, insurers, financiers and traders in third countries are reached when they use EU services; EU firms must also use best efforts to stop entities they own abroad from undermining it (Art. 8a). The US cap for its own persons remains $60. | in forceIn force at $44.10 in the EU and the UK on 6 October 2026; no Commission price notice after 15 January 2026.Regulation 833/2014, consolidated text of 24 July 2026 (Article 3n, Annex XXVIII) · Commission Implementing Regulation (EU) 2026/124 · UK maritime services ban and oil price cap: industry guidance (OFSI) |
| EU ban on imports of fuels refined from Russian crude in third countriesCouncil Regulation (EU) 2025/1494 of 18 July 2025, inserting Article 3ma and Annex LI into Regulation (EU) No 833/2014 | Council of the EU. 18 July 2025; in force 21 January 2026 | From 21 January 2026, bans buying, importing or transferring into the EU petroleum products (CN 2710) made in a third country from Russian crude oil, and related brokering, finance and insurance. Importers must show where the crude came from, except for products from the partner countries in Annex LI (the US, UK, Canada, Norway, Switzerland, Australia, Japan, New Zealand and Liechtenstein). | It binds EU importers and EU service providers, not refiners abroad. It reaches refiners in any third country that process Russian crude and sell fuel into the EU; the Commission’s guidance sets out when a refinery that runs both Russian and other crude can still export to the EU. | in forceApplies since 21 January 2026; amended by Regulations 2025/2033, 2026/506 and 2026/1848, not repealed (EUR-Lex, read 6 October 2026).Council Regulation (EU) 2025/1494, EUR-Lex · European Commission FAQ on the import ban (15 June 2026) |
| US sanctions risk for foreign banks that deal with Russia’s military-industrial base (E.O. 14114)Executive Order 14114 of 22 December 2023 (88 FR 89271), adding section 11 to E.O. 14024; OFAC determination under section 11(a)(ii) (89 FR 78245) | The President; Treasury (OFAC). 22 December 2023 | Lets the Treasury cut a foreign bank off from US correspondent accounts, or block it, if it conducts or facilitates significant transactions for persons sanctioned for operating in Russia’s technology, defence, construction, aerospace or manufacturing sectors, or involving Russia’s military-industrial base. Payments in any currency are covered. | Any foreign financial institution, anywhere. It has been used: Kyrgyzstan’s Keremet Bank was blocked under section 11 on 15 January 2025. In June 2024 OFAC added the foreign branch addresses of sanctioned Russian banks, including branches in New Delhi and Beijing, to their entries. | in forceIn force on 6 October 2026. The national emergency behind it was continued for a year on 24 March 2026 (91 FR 15515); no revocation found.Executive Order 14114, Federal Register · Treasury press release jy2785 (Keremet Bank, 15 January 2025) |
Exposure
How much trade is at stake?
Goods trade in 2025 from Türkiye’s own report to UN Comtrade, in US$ billion: what Türkiye sells to the three authorities’ markets, and its trade with Russia and Iran.
| Goods trade, US$ billion | Exports to the world | To the US | To the EU-27 | To the UK | US, EU and UK share | Exports to Russia | Imports from Russia | Exports to Iran | Imports from Iran |
|---|---|---|---|---|---|---|---|---|---|
| Türkiye, 2025 own report | 273.4 | 16.3 | 119.5 | 16.8 | 56% | 6.7 | 42.4 | 3.1 | 2.5 |
UN Comtrade query, Türkiye 2025
Goods only; services are not included. Values as Türkiye reported them to UN Comtrade, read 6 October 2026.
Outlook
What to watch
Dated decisions ahead, and recent official statements, court rulings and company actions, each with its source.
Graham Act deadline. Section 113 requires the President to raise the duty on all goods from countries that were among the five largest importers of Russian crude or gas in the 12 months before 18 September 2026, and that knowingly buy again from 18 October, to up to 100%, unless he waives it. In the public estimates set out on the Graham Act page, Türkiye ranks joint third, with Belarus, for Russian crude and second for Russian gas.
Section 113 has two more parts that matter for Türkiye. No duty is imposed for a country’s Russian gas purchases if it took less than 15% of Russia’s gas exports in the 12-month period and has taken significant steps to reduce them. And within 180 days of the first duties, and every 180 days after that, the US Trade Representative must redo the top-five crude and gas rankings for the latest 12 months and impose duties on the countries named.
Council Regulation (EU) 2026/1848 of 23 July 2026, the EU’s 21st package, bans transactions with listed refineries in Russia and in third countries that process Russian crude. The first entry, Georgia’s Kulevi refinery, applies from 25 January 2027, and the Commission must report by 25 October 2026 on whether to keep it. Türkiye still imports Russian crude: the KSE Institute estimates 204 kb/d of Russian seaborne crude in August 2026, 34% of its crude imports. Any new refinery entries are the EU step to watch.
Regulation (EU) 2026/1848 (EUR-Lex) · KSE Institute, Russian Oil Tracker, September 2026, p. 12
BOTAŞ’s two gas contracts with Gazprom, about 22 bcm a year, end. Energy Minister Bayraktar said in December 2025 that they had been extended by one year from the end of 2025. Whether they are renewed bears on the Graham Act’s gas exception. No ministry text of the extension was found; the source is a Reuters report.
Since 20 May 2026 the UK has banned imports of oil products refined in third countries from Russian crude. A general trade licence still lets diesel and jet fuel made this way into the UK until 1 January 2027 at the latest; the UK reviews the licence every two weeks.
OFAC warned foreign financial institutions that still do business with Iran or its financial sector that they may be sanctioned under ‘Operation Economic Outcast’. The alert names the 4 September listing of Türkiye-based Golden Global Bank and says that providing financial services to Iranian banks or their branches in third countries risks sanctions.
By board decision 11572, Türkiye’s banking regulator BDDK revoked the operating licence of the Istanbul branch of Bank Mellat, an Iranian bank listed by OFAC and the UK, under Article 71(1)(b) of the Banking Law. The notice, dated 19 September, gives no reason and does not mention US measures.
BDDK ruled (decision 11569) that the state deposit insurance fund TMSF will exercise the shareholder rights, other than dividends, over 99.98% of the shares of Golden Global Yatırım Bankası, which OFAC listed on 4 September. The notice cites Article 18(5) of the Banking Law and does not mention the US listing.
OFAC said that, with immediate effect, it considers Iran-related specific licence applications with a presumption of denial, except as required by law or in cases such as risk to life, limb or environmental safety.
Treasury and Finance Minister Şimşek told foreign journalists in Ankara that all companies operating in Türkiye must comply fully with national law and stay away from transactions that could attract sanctions. He said payments for Iranian gas go into a tightly regulated account that can pay only for food, medicine and similar goods, under an understanding with the US. The source is the state news agency; no ministry transcript was found.
Under E.O. 13902, OFAC listed Istanbul-based Golden Global Yatirim Bankasi and two of its subsidiaries. A wind-down general licence, GL CC, ran until 12:01 a.m. EDT on 19 September 2026. On 14 September, when it designated Russia’s VTB Bank under its Iran sanctions (E.O. 13902), Treasury said that action followed its recent actions against banks in Türkiye and the UAE. VTB has been on the SDN List under US Russia sanctions since 2022.
Treasury press release sb0622 · OFAC Iran General License CC, 4 September 2026 · Treasury press release sb0629, 14 September 2026
KSE Institute estimates that Türkiye imported 204 kb/d of Russian seaborne crude in August 2026, 34% of its crude imports. Its preliminary estimate is that India, China and Türkiye together took 73% of Russia’s seaborne crude exports that month.
KSE Institute, Russian Oil Tracker, September 2026, pp. 8 and 12
An order of nolle prosequi was filed in the US criminal case against the state lender Halkbank (S6 15 Cr. 867), ending the prosecution brought in 2019. It followed a deferred prosecution agreement of 6 March 2026, under which an EY affiliate reviewed the bank’s US sanctions compliance.
In its prospectus for US-dollar bonds, the Republic of Türkiye told investors that US, EU and other sanctions and export controls could harm its economy if they restricted business with Russia or its imports of Russian oil and gas. The same document reports 2024 imports from Russia of 22.5 bcm of gas and 16.9 Mt of crude.
On an earnings call, the refiner Tüpraş said it had stopped buying Russian Urals crude because of the US sanctions of 10 January 2025 on Russian energy companies and tankers.
Energy Minister Bayraktar said the US had granted Türkiye an exemption so it could keep paying for Russian gas through Gazprombank, which the US had listed on 21 November 2024.
Reuters reported that after the US order of 22 December 2023 (E.O. 14114), Turkish banks were reviewing business and tightening compliance with Russian clients, slowing some payments for Russian oil and for Turkish exports.
Method
Data, method and sources
Download the data
How the monitor works
- Every record is a US, EU or UK measure as the authority published it, linked to the official page or act.
- Window: measures dated 1 January 2024 or later, to the list dates on the method page.
- Programme (Russia or Iran) is the authority’s own tag or regime; measures under other programmes are left out.
- Hong Kong is shown apart from mainland China, from the address the authority gives.
- Every record was checked a second time against an official source; corrections are made within two working days and logged.
How to cite. The Geopolitical Economist (2026). Third-Country Sanctions Monitor. Version 1, updated 7 October 2026. https://geopoliticaleconomist.com/research/trackers/third-country-sanctions
Change log
Published as version one: four countries, US, EU and UK measures since January 2024.
Not legal advice. A listing records an official action by the authority named; it is not a finding by this publication. Check the official list before acting. Corrections: write to [email protected] with the record ID and your source; corrections are made within two working days and logged on the method page.