OFAC Lawyer in Turkey The search often arises due to the suspension of an international payment, similarity of names on the sanctions list, sanctions affiliation of company partners or the need to be removed from the SDN list. The correct legal approach begins by determining which sanction program, which person or institution and which country connection the transaction is based on. Bank review, application for unblocking and removal from the sanctions list are not the same process.
Last updated: September 21, 2026. This guide explains the basic distinctions of OFAC processes for individuals and companies in Turkey. In each file, the regulation, license and listing records on the transaction date should be checked separately.
What is OFAC and what does it do?
OFAC is the abbreviation of the English name “Office of Foreign Assets Control”. It enforces economic and trade sanctions within the U.S. Treasury Department. The subject of sanctions may be specific individuals, companies, assets, activities or geographical areas. Therefore, OFAC review is not just about looking for a person’s name on a list. OFAC collects official questions and answers, programs and compliance issues under separate headings.
SDN refers to the list of “Specially Designated Nationals and Blocked Persons”. In addition, there are other OFAC lists with different restrictions. It should not be concluded that all transactions are prohibited without reading which list and which program the record seen as a result of a scan belongs to.
How do OFAC sanctions affect people and companies in Turkey?
OFAC rules are of direct relevance to U.S. citizens, permanent residents, persons located in the United States, and entities established under U.S. law. Some programs also impose obligations on foreign companies owned or controlled by U.S. persons. Non-U.S. persons directing U.S. persons to violate sanctions and circumventing sanctions are also subject to certain prohibitions. OFAC FAQ 11.
Being established in Turkey does not automatically exclude a cross-border transaction from sanctions review. The U.S. correspondent bank, the U.S. person involved in the transaction, or a specific connection to the relevant program may change the assessment. Payment in dollars makes examining the banking chain particularly important; However, currency alone is not a substitute for all legal analysis.
For a business in Istanbul, Ankara, Izmir or another city, the starting questions are the same: Which banks does the payment pass through, who is the real beneficiary, where does the goods or service go and in what capacity is the counterparty transacting? Proper evaluation is based on concrete transaction and party information, not the city name.
OFAC-related issues and recourse: comparison table
| Status | First thing to examine | Possible approach |
|---|---|---|
| Name similarity | Do the ID and listing belong to the same person? | Distinguishing documents to the bank; contact OFAC compliance if necessary |
| Transfer pending review | Additional document request or official block? | Completion of written situation statement and transaction documents from the bank |
| Blocked funds | Blocking institution, program and asset connection | Reviewing the need for appropriate authorization or special licensing |
| Rejected transfer | Distinguishing between transaction ban and blockable interest | Evaluation of the reason for rejection, return status and legal transaction conditions |
| Actual sanction record | Justification for listing and supporting information | Application for administrative reconsideration, i.e. delisting |
| Subsidiary not listed | Direct and indirect partnership chain | Review of the 50 percent rule and related program |
The table provides general guidance. Especially the expressions “blocked”, “rejected” and “pending review” do not produce the same result. OFAC FAQ 9 and OFAC FAQ 36 to distinguish between blocking and rejection; OFAC FAQ 5 should be taken as basis for name matching.
What is the difference between OFAC bank hold and transaction denial?
Blocking is the freezing of transfer and savings transactions on the relevant assets. It does not mean that ownership automatically passes to the state. Transactions cannot be made on the blocked fund unless permission is given. OFAC’s definition of a block.
Transaction rejection This may only come to the fore if the transaction is prohibited and there is no interest that needs to be blocked. The payment is not processed and may return to the sender. On the other hand, the bank’s request for additional invoices or conducting an internal compliance review does not alone prove that there is an OFAC block. OFAC’s statement on transaction denial.
Transaction reference, amount, date, current status and explainable legal justification are requested from the bank. Concretizing which action is stopped and why in the first correspondence prevents the application from being directed to the wrong channel.
How does OFAC evaluate name similarity?
A match in the screening system is not definitive proof that you are on the sanctions list. In addition to the name and surname, date of birth, nationality, address and company registry information should be compared. First, it is determined whether the warning actually originates from the OFAC list or another agency’s list. OFAC name matching guide.
For example, two people with the same name may have different birth dates and nationalities. Similar trade names in companies can also create confusion. The comparison letter to be submitted to the bank must be supported by relevant documents. Personal documents required for review must be transmitted through a secure channel.
It is not an appropriate way to start for a person who is not actually subject to sanctions to apply for removal from the list simply because of similarity of names. OFAC in this case refers to communication with the compliance unit. OFAC FAQ 897.
OFAC 50 percent rule in companies
If the direct or indirect total ownership share of one or more blocked persons is 50 percent or more, the company may also be considered blocked under this rule, even if its name is not included in the list. The fact that two blocked persons have 30 percent and 20 percent shares in the same company constitutes the total threshold of 50 percent. If there are intermediate companies, simply multiplying the final percentages may not be sufficient; Every level of the partnership chain should be evaluated. OFAC 50 percent rule and examples.
The rule concerns ownership. Having control with a share below 50 percent does not, by itself, create an automatic blockage through this rule. However, a separate sanction basis, the blocked person signing the transaction, or other program restrictions may also be important. The approach of “partnership share is 49 percent, there is no risk” is not correct. OFAC FAQ 398.
What is an OFAC license? Distinction between general and special licenses
A general license allows specified types of transactions with publicly available conditions. If the transaction meets all conditions, no additional individual consent is required. A special license is a document that allows a specific transaction upon application for a specific person or organization. In both cases, duration, scope, recording and reporting conditions are important. OFAC license types.
A special license may be required to release blocked funds. First, it should be investigated whether there is an exception or general license for the relevant transaction. Submitting an application alone does not mean processing permission or a positive result. The current application channel and instructions are published on the OFAC license application page.
In order for the file to be understandable, the parties, banks, payment purpose, commercial relationship and the requested transaction must verify each other. If the invoice recipient and the transfer beneficiary are different, the legal and commercial reason for this difference must be documented.
OFAC delisting: application for delisting
Individuals or entities actually sanctioned may request administrative reconsideration under 31 CFR § 501.807. The focus of the review is the basis for the sanction and the conditions requiring its continuation. Instead of a general statement of victimization, a documented file that answers the reason for listing should be prepared. OFAC delisting statement.
OFAC announced the opening of the Reconsideration Portal on June 29, 2026. Applications and requests for certain non-confidential basis information can be made through the portal. The stated target of 7–10 business days for the initial deficiency check is not the final decision time. The actual investigation may take a long time depending on the file.
Re-application is possible after rejection; However, new argument or evidence must be presented to support a different evaluation. Repeating the same file without changes may not be enough. OFAC FAQ 1261.
Dossier preparation with OFAC lawyer in Turkey
Legal work in Turkey; May include preparation of local corporate and bank documents, explanation of transaction flow, review of contractual outcomes, and necessary foreign legal coordination. Relevant jurisdictional and procedural requirements for U.S. law opinion, representation, and possible judicial recourse must also be considered. Just because a lawyer works in Turkey does not mean that he has the authority to represent before every court in the USA.
What documents are prepared for the initial evaluation?
- Bank’s rejection, blocking or additional information letter; transaction reference and SWIFT record if available.
- Contracts, invoices, shipping and delivery documents; Chronology explaining the purpose of the payment.
- Company registry records, partnership scheme and beneficial owner information.
- Documentation of the relevant listing, program information, and identity match.
- Previous applications, application numbers and correspondence with institutions.
This list does not mean that all documents are mandatory in every file. The aim is to identify the required application path and missing information. Fees and the scope of work must be clarified in writing according to the document volume, translation need, relevant country law and application type.
The sequence of work to be followed in preparation for the application
- Classify the event: The review distinguishes between pending payment, rejection, blockage or actual listing.
- Document matching: Bank letter, contract and payment records are combined in a single chronology.
- Legal review: The relevant program, parties, partnership structure and need for permission are evaluated.
- Reference file: The request is written clearly; The basis for each claim is linked to the relevant document.
- Tracking: Requests for additional information, response dates and application numbers are recorded regularly.
This working order is a recommended file management method; It is not a formal and fixed procedure for every application. There may be different steps required by the specific matter.
Are OFAC, INTERPOL and extradition processes the same thing?
OFAC enforcement registration relates to economic restrictions; It is not an INTERPOL red notice or an extradition decision from Turkey alone. Although there may be a separate criminal investigation about the same incident, the basis and application method of each mechanism is different.
For matters involving an international search record, INTERPOL search and removal of records The article on the subject can be read additionally. If there is a US-related criminal file USA and Türkiye extradition process The article titled deals with the separate legal framework. For the relationship between the red notice and the process before the court Red Notice and Extradition Trial You can view the article.
Sanctions compliance program for Turkish companies
OFAC’s compliance framework identifies five key components: management support, risk assessment, internal controls, testing and auditing, and training. The program should be created according to the company’s size, activities, customers and geographies in which it operates. A Framework for OFAC Compliance Commitments.
A study plan; It may include partnership review upon customer acceptance, pre-payment control, transfer of warnings to the authorized person and recording of decision reasons. Having clear responsibilities for sales, finance and logistics teams reduces last-minute document requests. Periodic review prevents an old scan result from being considered permanently valid.
Frequently asked questions about OFAC Lawyer Türkiye
My bank said OFAC; Am I definitely on the sanctions list?
No. Similarity of name, counterparty, partnership structure or connections of the transaction may be examined. The source of the warning and the current status of the transaction must be requested from the bank in writing.
Is it enough not to have the company name on the list?
No. The 50 percent rule and program restrictions that may apply outside the list are also examined. This is why the company’s partnership chain is important.
How long does an OFAC application take?
There is no specific deadline for every application. The type of application, the integrity of the file and the need for additional information affect the duration. The initial control target of the portal should not be confused with the final decision time.
Does getting a special license mean being removed from the SDN list?
No. A special license may allow a specific operation. Delisting is a separate evaluation for the removal of the sanction record.
Can success be guaranteed in the application?
No. The decision of the bank or competent authority cannot be guaranteed in advance. A sound legal approach requires determining the basis of the file, choosing the appropriate application method and presenting the evidence consistently.
This article is for general information purposes. For a specific matter, the relevant sanction program, current licenses and applicable Turkish and foreign country law should be evaluated together.