Sanctions Compliance and Turkish Customs Law: What Foreign Investors Need to Know in 2026

Sanctions Compliance and Turkish Customs Law for Foreign Investors | 2026

Learn how international sanctions affect customs transactions, imports, exports, payments, logistics, and investments in Turkey. A 2026 legal guide for foreign investors on sanctions screening, Turkish customs compliance, and risk management.

Foreign investors conducting import, export, manufacturing, logistics, banking, energy, technology, or distribution activities in Turkey must consider both Turkish customs law and applicable international sanctions.

A transaction may appear lawful from a conventional customs perspective but still create serious risk because of the parties involved, the destination country, the origin of the goods, the payment route, the end user, or the intended use of the product.

Sanctions violations may lead to blocked payments, rejected shipments, frozen assets, customs investigations, cancelled contracts, reputational damage, and exposure under anti-money laundering, terrorism-financing, proliferation-financing, export-control, or anti-smuggling rules.

A reliable compliance system must therefore assess more than whether customs duties were correctly calculated. It should examine the complete transaction, including the buyer, seller, beneficial owner, freight forwarder, vessel, bank, insurer, country, product, payment method, and ultimate end use.

What Are International Sanctions?

International sanctions are legal restrictions imposed to address threats to international peace, terrorism, weapons proliferation, armed conflict, or other serious security concerns.

Sanctions may include:

• Asset freezes
• Trade restrictions
• Arms embargoes
• Travel bans
• Financial prohibitions
• Sectoral restrictions
• Commodity controls
• Export and import bans
• Restrictions on providing services

The United Nations Security Council applies measures ranging from targeted asset freezes and travel restrictions to arms embargoes, financial controls, and commodity-related restrictions.

The United Nations Consolidated List includes individuals and entities subject to measures imposed under different Security Council sanctions regimes. Because sanctions lists change, companies must use the current version rather than relying on previously downloaded records.

Does Turkey Automatically Apply Every Foreign Sanctions Regime?

Foreign investors should distinguish between:

• United Nations sanctions implemented in Turkey
• Turkish domestic restrictive measures
• Sanctions imposed by the European Union
• Sanctions administered by the United States
• Sanctions applied by the United Kingdom or other jurisdictions
• Contractual sanctions obligations imposed by banks or multinational groups

European Union, United States, or United Kingdom sanctions do not automatically become Turkish law merely because they exist abroad.

However, they may still have major practical consequences where a transaction involves:

• A foreign parent company
• An international bank
• United States dollar payments
• European financing
• Foreign insurers
• International shipping companies
• Overseas technology
• Multinational compliance policies
• Contracts governed by foreign law

Accordingly, a transaction may be permissible under Turkish law but commercially impossible because a bank, insurer, carrier, supplier, or parent company is prohibited from participating.

Turkish Legal Framework for Sanctions Compliance

Turkey’s sanctions-related legal framework is not contained in a single statute. Relevant rules may arise from:

• Turkish Customs Law No. 4458
• Anti-Smuggling Law No. 5607
• Law No. 6415 on the Prevention of the Financing of Terrorism
• Law No. 7262 on the Prevention of the Financing of the Proliferation of Weapons of Mass Destruction
• Law No. 5549 on the Prevention of Laundering Proceeds of Crime
• Import and export regulations
• Product-specific control rules
• Presidential decisions implementing international obligations
• Secondary legislation and administrative decisions

Law No. 7262 regulates the implementation of United Nations Security Council resolutions concerning the financing of weapons proliferation. It prohibits, within the applicable resolutions, providing funds to listed persons or entities and establishing certain business relationships involving them.

Law No. 6415 governs measures relating to terrorism financing and asset freezing. It prohibits providing or collecting funds for terrorist acts and establishes mechanisms for freezing relevant assets.

How Sanctions Affect Customs Transactions

Sanctions compliance and customs compliance often overlap.

Customs authorities may examine:

• The identity of the importer and exporter
• The declared country of origin
• The destination country
• The route of transportation
• The description of the goods
• The tariff classification
• The end user
• The intended use
• Supporting licences
• Payment and commercial records

A company may face risk where goods are routed through an intermediary country to conceal the true destination or end user.

Similarly, changing invoices, product descriptions, consignee information, origin documents, tariff codes, or transportation records to avoid restrictions may create both sanctions and customs liability.

Restricted Parties Screening

Before accepting a transaction, foreign investors should screen all relevant persons and entities.

Screening should cover:

• Buyer
• Seller
• Importer
• Exporter
• Consignee
• Notify party
• Manufacturer
• Distributor
• Freight forwarder
• Customs broker
• Shipping company
• Vessel owner
• Bank
• Insurer
• Beneficial owners
• Directors and controlling persons
• End user

A name-only comparison is not sufficient. Companies should also consider:

• Alternative spellings
• Former names
• Trade names
• Nationality
• Address
• Date of birth
• Passport or registration details
• Ownership and control structure

A company that is not expressly listed may still present risk where it is owned, controlled, represented, or used for the benefit of a sanctioned person.

Beneficial Ownership Risks

The contractual buyer may not be the true beneficiary of a transaction.

Foreign investors should identify:

• Direct shareholders
• Indirect shareholders
• Ultimate beneficial owners
• Persons exercising control
• Nominee shareholders
• Trustees
• Intermediary companies
• Persons acting on behalf of another party

Complex ownership structures, recently established companies, unexplained intermediaries, or ownership changes immediately before a transaction may require enhanced investigation.

Product and Dual-Use Risks

Certain goods have both civilian and military applications. These are commonly described as dual-use goods.

Risk may arise in transactions involving:

• Electronics
• Sensors
• Navigation systems
• Telecommunications equipment
• Drones and components
• Machine tools
• Advanced materials
• Chemicals
• Laboratory equipment
• Encryption technology
• Energy-sector equipment
• Aerospace products
• Semiconductor-related products

The fact that a product has a civilian description does not eliminate risk. The company must consider the product’s specifications, performance, customer, destination, and possible end use.

A technically inaccurate customs description may also be interpreted as an attempt to conceal the controlled nature of the goods.

Country and Destination Risk

Sanctions risk cannot be assessed by reviewing only the shipment’s immediate destination.

The company should determine:

• The final destination
• The final consignee
• The end user
• Any transit countries
• Whether re-export is expected
• Whether the buyer is a distributor
• Whether the goods may be diverted
• Whether the payment originates from another jurisdiction

A shipment to a non-sanctioned country may still be problematic if there are indications that the goods will be re-exported to a restricted destination.

Customs Classification and Sanctions Evasion

Tariff classification determines more than customs duty rates. It may affect whether a product is subject to export controls, trade restrictions, licensing requirements, or other regulatory measures.

Sanctions-evasion risks may arise where a business:

• Uses an incorrect HS code
• Gives a vague product description
• Splits a product into components
• Misstates technical specifications
• Declares a false country of origin
• Uses an intermediary consignee
• Conceals the final destination
• Routes goods through several countries

The classification file should therefore contain technical documentation sufficient to explain why the selected tariff code is legally correct.

Origin and Routing Risks

Country of origin and country of dispatch are different concepts.

Goods may be shipped from one country while originating in another. Repackaging, relabelling, storage, or simple transit generally does not automatically change origin.

Foreign investors should review:

• Certificates of origin
• A.TR and EUR.1 documents
• Supplier declarations
• Manufacturing records
• Bills of materials
• Transport documents
• Transit routes
• Warehouse records
• Invoices from intermediary companies

Documents should reflect the actual commercial and logistical structure.

Payment and Banking Risks

Sanctions compliance is closely connected to payment processing.

Banks may reject or delay payments because of:

• Listed parties
• High-risk jurisdictions
• Unclear payment descriptions
• Mismatched invoice details
• Unrelated third-party payments
• Correspondent-bank restrictions
• Suspicious ownership structures
• Goods with military or dual-use potential
• Attempts to divide payments

Foreign investors should avoid changing payment routes merely to bypass a bank’s compliance decision.

Payments from unrelated third parties, offshore companies, cash-intensive businesses, or unexplained financial intermediaries should receive enhanced review.

Vessel, Shipping, and Logistics Screening

Maritime and logistics transactions may create additional risk.

Companies should review:

• Vessel name
• International Maritime Organization number
• Flag
• Registered owner
• Beneficial owner
• Operator
• Charterer
• Previous names
• Recent ports
• Route changes
• Ship-to-ship transfers
• Cargo documents

A vessel may change its name, flag, ownership, or operator. Screening based solely on the current vessel name may therefore be insufficient.

Unusual routing, disabled tracking systems, unexplained cargo transfers, or inconsistent bills of lading may indicate diversion or sanctions-evasion risk.

Free Zones, Warehouses, and Transit Operations

Goods placed in a free zone, customs warehouse, or transit procedure remain subject to legal controls.

These procedures should not be used to:

• Conceal the final destination
• Change documents without commercial justification
• Replace the actual consignee
• Misrepresent origin
• Avoid export restrictions
• Transfer goods to prohibited persons

Companies operating in free zones or warehouses should maintain detailed inventory, ownership, movement, and customer records.

Customs Brokers and Freight Forwarders

A company cannot safely transfer its entire sanctions responsibility to a customs broker or freight forwarder.

Service providers may submit declarations and arrange transportation, but the investor should maintain independent controls over:

• Party screening
• Product classification
• Origin
• Destination
• Licensing
• End-use documentation
• Transaction approval

Broker agreements should require immediate reporting of suspicious instructions, customs inquiries, document inconsistencies, and route changes.

Red Flags Foreign Investors Should Recognize

Common sanctions and customs red flags include:

• A customer refusing to disclose its beneficial owner
• A newly incorporated intermediary with no clear business purpose
• Payments made by unrelated third parties
• Last-minute changes to the consignee
• Requests to remove the end user from documents
• Shipment routes inconsistent with commercial logic
• Goods ordered in quantities unrelated to the buyer’s business
• Vague descriptions such as “parts” or “equipment”
• A customer requesting altered invoices
• Different countries shown on contracts, invoices, and transport documents
• Use of personal email addresses for high-value trade
• A distributor refusing to identify the final destination
• Repeated use of high-risk transit points
• Unusual discounts or overpayments
• Requests to avoid a particular bank or carrier
• Attempts to classify controlled goods under a less sensitive tariff code

One red flag may have an innocent explanation. Several connected red flags require enhanced due diligence and possible transaction suspension.

Establishing a Sanctions Compliance Program

A foreign investor operating in Turkey should establish a written compliance program covering:

1. Risk assessment
2. Restricted-party screening
3. Beneficial ownership verification
4. Product classification
5. Country and destination controls
6. End-user and end-use review
7. Banking and payment controls
8. Customs broker supervision
9. Record retention
10. Employee training
11. Escalation and approval procedures
12. Internal audits
13. Investigation protocols
14. Corrective action

The program should reflect the company’s industry, products, customer base, countries, transaction volume, and ownership structure.

End-User and End-Use Statements

For higher-risk transactions, companies should obtain written end-user documentation.

An end-user statement may address:

• Identity of the final user
• Business activity
• Installation location
• Intended use
• Prohibition on unauthorized resale
• Final destination
• Confirmation that goods will not be used for prohibited purposes
• Obligation to notify the supplier of changes

A signed statement does not replace independent verification. The information should be checked against public records, transaction documents, and commercial reality.

Record-Keeping Requirements

A sanctions compliance file may include:

• Screening results
• Ownership records
• Corporate registry documents
• Contracts
• Invoices
• Customs declarations
• Licences
• End-user statements
• Product specifications
• Origin documents
• Bills of lading
• Payment records
• Internal approvals
• Legal opinions
• Investigation records

Turkish rules implementing asset-freezing measures may require relevant records to be retained and made available to competent authorities.

Records should show not only that screening occurred, but also when it occurred, which lists were checked, who approved the transaction, and how identified risks were resolved.

Contractual Protection

International contracts should contain sanctions and trade-compliance clauses addressing:

• Compliance with applicable laws
• Accuracy of ownership information
• End use and destination
• Prohibition on diversion
• Screening cooperation
• Notification of ownership changes
• Right to suspend performance
• Right to request documents
• Termination rights
• Indemnification
• Treatment of blocked payments
• Responsibility for licences

Contractual clauses reduce risk but do not protect a company that ignores obvious warning signs.

What Should a Company Do After Identifying a Match?

A potential sanctions match should not be treated as a confirmed violation without verification.

The company should:

1. Suspend the transaction where appropriate.
2. Compare identifying information.
3. Review ownership and control.
4. Preserve all records.
5. Prevent shipment or payment until the risk is assessed.
6. Obtain legal advice.
7. Determine whether notification or freezing obligations apply.
8. Document the final decision.

Employees should never delete, alter, or recreate documents after a concern has been identified.

Consequences of Non-Compliance

Depending on the facts, sanctions-related customs violations may lead to:

• Refusal of customs clearance
• Detention of goods
• Additional customs duties
• Administrative penalties
• Licence cancellation
• Asset freezing
• Bank account restrictions
• Contract termination
• Customs investigations
• Criminal proceedings
• Anti-smuggling allegations
• Reputational damage
• Loss of financing or insurance
• Exclusion from international supply chains

The consequences may arise under Turkish law, foreign law, contractual obligations, or several regimes simultaneously.

Sanctions Due Diligence in Investments and Acquisitions

Before investing in or acquiring a Turkish company, foreign investors should examine whether the target:

• Trades with high-risk countries
• Screens customers and suppliers
• Identifies beneficial ownership
• Imports or exports dual-use goods
• Uses high-risk distributors
• Has blocked or rejected payments
• Has received bank compliance inquiries
• Has changed shipping routes
• Has ongoing customs investigations
• Maintains reliable end-user documents
• Has written sanctions policies
• Trains employees
• Audits customs brokers and logistics providers

Historical violations may remain within the acquired company after closing, particularly in share acquisitions.

2026 Sanctions Compliance Assessment

In 2026, foreign investors should assume that sanctions screening is a continuous obligation rather than a one-time onboarding exercise.

The United Nations Consolidated List is updated when individuals or entities are added, amended, or removed. Businesses should therefore rescreen active customers, suppliers, beneficial owners, and other relevant parties at appropriate intervals.

Companies should also monitor changes in Turkish law, presidential decisions, United Nations measures, foreign sanctions regimes relevant to their corporate group, and the compliance requirements of banks, insurers, carriers, and commercial partners.

The strongest compliance systems combine legal review with accurate customs data, beneficial ownership analysis, product knowledge, transaction monitoring, and documented management oversight.

Frequently Asked Questions

1. Does Turkey apply United Nations sanctions?

Turkey has legislation governing the implementation of relevant United Nations Security Council measures, including rules concerning terrorism financing, proliferation financing, prohibited transactions, and asset freezing.

2. Do European Union sanctions automatically apply in Turkey?

Not automatically as Turkish domestic law. However, they may affect a Turkish transaction through European parent companies, banks, insurers, carriers, contractual obligations, or financing arrangements.

3. Can a transaction be lawful in Turkey but rejected by a foreign bank?

Yes. A foreign bank may apply the sanctions rules of its own jurisdiction or internal risk policies even where Turkish law does not expressly prohibit the transaction.

4. Should every customer be screened?

Companies should apply risk-based screening to relevant parties, including customers, suppliers, intermediaries, beneficial owners, banks, carriers, and end users.

5. Are customs brokers responsible for sanctions screening?

Customs brokers may have their own obligations, but using a broker does not eliminate the importer’s or exporter’s responsibility to maintain effective compliance controls.

6. What are dual-use goods?

Dual-use goods are products, software, or technology capable of both civilian and military or security-related use.

7. Is checking the United Nations list once sufficient?

No. Lists and ownership structures may change. Active relationships should be rescreened periodically and when material transaction details change.

8. What should a company do if a customer appears on a sanctions list?

The transaction should be paused, identifying information should be verified, records should be preserved, and legal advice should be obtained before goods or funds are transferred.

9. Can incorrect customs classification create sanctions risk?

Yes. Misclassification may conceal a controlled product or prevent the application of a required licence, restriction, or compliance review.

10. Should sanctions risks be reviewed before acquiring a Turkish company?

Yes. Sanctions and customs compliance should form part of legal due diligence, especially where the target conducts international trade or operates in sensitive industries.

Client-Focused Sanctions and Customs Legal Support

Sanctions compliance requires more than checking a customer’s name against a list. Companies must evaluate ownership, control, goods, payment routes, logistics, destination, end use, customs documentation, and foreign-law exposure.

Fırat Fesih Kaya Law Office advises foreign investors, multinational companies, importers, exporters, manufacturers, logistics providers, distributors, and financial stakeholders on Turkish customs law, sanctions compliance, restricted-party screening, customs investigations, export controls, transaction due diligence, and compliance-program development.

Early legal review can prevent blocked shipments, rejected payments, administrative penalties, contractual disputes, and serious reputational damage.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower, Office No:148, 06520 Balgat, Çankaya, Ankara, Turkey

Contact Fırat Fesih Kaya Law Office for strategic, confidential, and business-focused legal support concerning sanctions compliance and customs transactions in Turkey.

Legal Disclaimer: This article provides general information and does not constitute legal advice. Sanctions obligations depend on the parties, products, destination, payment route, applicable jurisdiction, ownership structure, end use, and specific facts of each transaction.