On May 2, 2023, for the second time this year, the US and Turkish governments took joint action in imposing sanctions.  Specifically, the United States and Türkiye imposed sanctions against two individuals determined to be financial facilitators of Syria-based terrorist groups Hay’at Tahrir al-Sham (“HTS”) and Katibat al-Tawhid wal-Jihad (“KTJ”), both of which are sanctioned by the United States and the United Nations.  This follows a prior joint action in January targeting parties associated with the financial facilitation network of the Islamic State of Iraq and Syria (“ISIS”), as reported previously on our blog (see here).

See here for the most recent US action and here for the Turkish action.  The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued this press release on these new sanctions, which states that the joint action “continues the cooperation between the United States and Türkiye to counter the financing of terrorist groups that perpetuate violence and instability throughout the region.”

The sanctions were imposed by OFAC, the Turkish Ministry of Treasury and Finance, and the Turkish Ministry of Interior. OFAC added these parties to its List of Specially Designated Nationals or Blocked Persons (“SDN List”), essentially cutting these parties off from the US financial system and transactions involving a US nexus. Türkiye’s Treasury and Interior ministries implemented an asset freeze against the targeted parties.

This latest joint action is a further sign of increased levels of international coordination on sanctions. 

The authors acknowledge the assistance of Ryan Orange with the preparation of this blog post.


Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.