Key Points
On December 14, 2020, in response to Turkey’s procurement of the S-400 surface-to-air missile system from Russia in 2019, the Trump administration imposed new sanctions on the Turkish Presidency of Defense Industries (SSB) and four of its officers pursuant to the CAATSA sanctions provisions enacted by Congress against Russia in 2017. This follows Congressional approval of the NDAA for Fiscal Year 2021 by a veto-proof majority on December 11, 2020, which includes specific provisions to compel the imposition of the new sanctions measures.
The European Union separately has also recently adopted new sanctions against Turkey in connection with disputed Turkish drilling activities in the Eastern Mediterranean.
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On December 14, 2020, the United States
imposed sanctions on the Republic of Turkey s
Presidency of Defense Industries ( SSB ), the
country s defense procurement agency, and four senior officials
at the agency, for knowingly engaging in a significant
transaction with Rosoboronexport ( ROE ),
Russia s main arms export entity, in procuring the S-400
surface-to-air missile system. These measures were a long-time
coming under
Section 231 of the Countering America s
Adversaries Through Sanctions Act ( CAATSA ) of 2017, the
President has been
required to impose sanctions
on any person determined to have knowingly engage[d] in a
December 18, 2020
On December 14, 2020, the United States imposed sanctions on the Republic of Turkey’s Presidency of Defense Industries (“SSB”), the country’s defense procurement agency, and four senior officials at the agency, for knowingly engaging in a “significant transaction” with Rosoboronexport (“ROE”), Russia’s main arms export entity, in procuring the S-400 surface-to-air missile system. These measures were a long-time coming under Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) of 2017, the President has been
required to impose sanctions on any person determined to have knowingly “engage[d] in a significant transaction with a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation.” This includes ROE, and Turkey’s multi-billion dollar S-400 transaction with ROE has been public knowledge for at least three years. Indeed, in