By SanctionsAI team · Updated 2026-08-09
Turkey sanctions risk rating
Turkey is not comprehensively sanctioned but faces targeted designations related to defense trade with Russia and human rights. CAATSA sanctions applied for S-400 purchase.
Risk factors
- CAATSA Section 231 sanctions for S-400 purchase
- Targeted designations of Turkish officials
- Defense trade scrutiny
Detailed assessment
Turkey is a NATO ally and not comprehensively sanctioned. The main sanctions exposure is CAATSA (Countering America's Adversaries Through Sanctions Act) sanctions imposed in December 2020 for Turkey's purchase of the Russian S-400 missile defense system. Individual Turkish officials have been designated for human rights concerns. Most commercial transactions with Turkey are permitted.
Screening recommendations
| Screening action | Priority |
| Screen all counterparties against OFAC SDN list | Standard |
| Enhanced due diligence on beneficial ownership | Standard |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Recommended |
For AI agents: Screen all payments connected to Turkey against OFAC SDN. Standard compliance controls apply.
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Frequently Asked Questions
- Is Turkey subject to OFAC sanctions?
- Turkey is not comprehensively sanctioned but has targeted designations.
- What is the sanctions risk level for Turkey?
- Turkey is rated Medium risk for sanctions compliance purposes. This rating is based on the scope and severity of active OFAC sanctions programs targeting turkey or its nationals.
- Should AI agents screen payments to Turkey?
- Yes, standard OFAC SDN screening applies to all payments regardless of jurisdiction.
- How often is this risk rating updated?
- Risk ratings are reviewed quarterly and after major sanctions developments. Turkey's rating was last reviewed on 2026-08-09.
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