Sanctions Screening for Shipping Companies Operating in Turkey: Legal Requirements – 2026 Updated Guide

Learn the 2026 sanctions screening requirements for shipping companies operating in Turkey, including vessel, beneficial owner, charterer, cargo, consignee, dual-use goods, UN sanctions, AIS risks, banking, insurance, and Turkish compliance obligations.

International shipping companies operating in or through Turkey face an increasingly complex sanctions and trade-compliance environment. A vessel may be technically seaworthy and fully compliant with ordinary port requirements while still creating substantial legal exposure because of its owner, charterer, cargo, consignee, beneficial owner, financing structure, previous trading activity, or ultimate destination.

For foreign shipowners, operators, managers, charterers, freight interests, and international trading companies using Turkish ports, sanctions screening should therefore be treated as a transaction-wide compliance process, not merely as a search for the vessel’s name on a sanctions database.

Turkey’s domestic framework is particularly important because United Nations Security Council measures may be implemented through Turkish law. Law No. 7262 on Preventing Financing of Proliferation provides mechanisms for implementing asset-freezing and prohibition decisions concerning persons, entities, and maritime vessels subject to relevant UN Security Council resolutions.

At the same time, shipping companies may have additional exposure to sanctions imposed by other jurisdictions because of their corporate nationality, banking relationships, insurers, contractual arrangements, cargo interests, or counterparties.

A proper 2026 compliance program must therefore answer two separate questions: Which restrictions are legally applicable to the transaction, and which additional sanctions regimes create commercial or contractual exposure?

Are Shipping Companies Legally Required to Conduct Sanctions Screening in Turkey?

There is no single provision stating that every shipping company must conduct an identical database search before every Turkish port call.

However, this does not mean sanctions screening is optional from a practical legal-risk perspective.

Turkey’s sanctions framework includes binding implementation of relevant United Nations Security Council measures. The UN Consolidated Sanctions List contains individuals and entities subject to Security Council measures, and Member States are required to implement the specific restrictions applicable to each listed person or entity. The consolidated list was updated again in May 2026.

Turkey’s Law No. 7262 is especially important for proliferation-financing restrictions. Under the legislation, Presidential decisions published in the Official Gazette can implement asset freezes concerning persons and entities subject to relevant UNSC resolutions and can also implement decisions involving the freezing of maritime vessels and specified prohibitions.

Consequently, shipping companies operating in Turkey should establish a risk-based system capable of identifying transactions that could involve prohibited persons, entities, vessels, cargoes, or activities.

1. Screen the Vessel by IMO Number

The vessel itself should always be screened.

Searching only by ship name is inadequate because vessels can change names repeatedly during their commercial lives.

The IMO number is therefore one of the most important identifiers in maritime sanctions due diligence.

The screening should examine:

• current vessel name;
• previous vessel names;
• IMO number;
• flag State;
• previous flags;
• registered owner;
• technical manager;
• commercial manager;
• recent trading history.

Some UN sanctions regimes specifically identify vessels.

For example, the Security Council’s DPRK sanctions framework maintains a designated-vessels list and provides for measures that may include asset freezes and port-entry bans in specified circumstances.

Accordingly, sanctions screening should never be limited to companies and individuals.

2. Screen the Registered Shipowner

The registered owner should be checked against the sanctions regimes applicable to the transaction.

However, registered ownership is only the beginning of the analysis.

Single-purpose shipowning companies are common in international shipping. A vessel may be registered in the name of a company whose only significant asset is that particular ship.

The fact that the registered owner itself does not appear on a sanctions list does not automatically resolve the compliance question.

The company may be owned or controlled by another person or entity that creates sanctions exposure.

3. Identify and Screen Beneficial Ownership

Beneficial ownership is one of the most important elements of modern maritime sanctions compliance.

Shipping companies should determine who ultimately owns or controls the relevant counterparty where the transaction presents elevated risk.

The analysis may need to move through several corporate layers.

Warning signs include:

• recently incorporated holding companies;
• nominee shareholders;
• unexplained offshore structures;
• frequent changes in ownership;
• ownership transfers immediately before a voyage;
• multiple companies using identical contact details;
• unusual management structures;
• inability to identify the ultimate controlling person.

Where the ownership structure cannot reasonably be understood, the transaction should be treated as higher risk until satisfactory evidence is obtained.

4. Screen Charterers and Sub-Charterers

Screening only the shipowner is insufficient.

A vessel may be controlled commercially by a time charterer, voyage charterer, bareboat charterer, or sub-charterer.

The chartering chain should therefore be reviewed where appropriate.

This is particularly important because the charterer may nominate the:

• cargo;
• loading port;
• discharge port;
• shipper;
• receiver;
• trading route.

A clean shipowner can still become involved in a high-risk transaction because of instructions issued by a problematic charterer.

Charterparty sanctions clauses should therefore allow owners to respond appropriately to voyage orders that would expose the vessel or owner to applicable sanctions.

5. Screen the Shipper, Consignee, and Cargo Owner

Sanctions screening should extend to the principal cargo interests.

The shipper named on the bill of lading should be screened where appropriate, as should the consignee and known cargo owner.

Depending on the transaction, the review may also extend to:

notify parties, traders, brokers, intermediate buyers, sellers, and ultimate receivers.

A cargo may pass through several companies before reaching the ultimate recipient.

The compliance objective is therefore not simply to determine who appears on the bill of lading, but to understand the commercial transaction sufficiently to identify significant sanctions risks.

6. Determine the Ultimate End User

End-user screening is particularly important for sensitive goods.

A consignee may be an ordinary trading company while the goods are ultimately destined for another industrial, military, governmental, or technological end user.

This becomes especially important for dual-use goods.

Turkey’s 2026 import framework includes a specific communiqué concerning the approval of documents relating to dual-use materials and technologies, together with separate controls affecting weapons, certain chemicals, and other sensitive products.

Turkey also applies a catch-all approach in strategic export controls: even goods not appearing on a control list may potentially require authorization where concerns exist regarding their possible use in weapons-of-mass-destruction-related activities.

Shipping companies carrying technically sophisticated goods should therefore avoid relying exclusively on generic commercial descriptions such as “machinery,” “electronics,” or “industrial equipment.”

7. Screen Cargo Origin and Destination

Country risk remains important.

The screening process should establish:

Where was the cargo manufactured?
Where was it loaded?
Who sold it?
Who owns it?
Where will it be discharged?
Where is its ultimate destination?

These questions may produce different answers.

Routing goods through an intermediary country does not necessarily change their legal origin or ultimate destination.

Documentation should therefore be examined for inconsistencies between certificates of origin, bills of lading, commercial invoices, customs documents, packing lists, and purchase contracts.

8. Review Turkish Customs and Import Restrictions

Sanctions compliance and customs compliance are separate but closely connected.

Turkey’s Ministry of Trade maintains specific 2026 import controls covering sensitive categories, including dual-use materials and technologies and other regulated goods.

Product-safety inspections also apply to numerous industrial categories, including certain steel products, pipe fittings, machinery, electrical equipment, and other goods.

The 2026 Import Regime was additionally amended in July 2026, including changes affecting tariff classifications and the identification of products subject to particular import-testing requirements.

Shipping companies should therefore ensure that sanctions screening is coordinated with customs classification and trade-control analysis.

9. Screen Banks and Payment Channels

A legally permissible shipment can still encounter serious problems if the payment chain involves a restricted financial institution.

The compliance review may therefore need to cover:

• charter-hire payments;
• freight;
• bunker payments;
• port expenses;
• cargo payments;
• letters of credit;
• guarantees;
• insurance premiums;
• claims payments.

International shipping frequently involves payments in multiple currencies passing through correspondent banks.

A transaction may consequently be rejected or frozen by a bank even where the underlying voyage is not prohibited under Turkish law.

The sanctions clauses in financing and commercial agreements should therefore be reviewed before the voyage begins.

10. Review P&I and Insurance Restrictions

Insurance is another critical compliance layer.

Shipowners should verify whether P&I, hull and machinery, cargo, pollution, and other relevant coverage remains available for the proposed voyage.

Sanctions clauses may restrict the insurer’s obligation to provide cover, make payments, provide security, or reimburse losses where doing so would expose the insurer to applicable sanctions.

This can become particularly serious following:

• collision;
• pollution;
• cargo damage;
• vessel detention;
• crew claims;
• salvage;
• wreck removal.

The worst time to discover a sanctions-related insurance problem is after a casualty has already occurred.

11. Investigate AIS Irregularities

AIS data can provide important compliance information.

An unexplained period of AIS inactivity does not automatically establish sanctions evasion. Technical failures, safety issues, and other legitimate explanations may exist.

Nevertheless, repeated or strategically timed AIS gaps should be investigated when accompanied by other warning signs.

The IMO has specifically expressed concern about shadow-fleet practices involving obscured vessel identities, AIS deactivation, opaque ownership, insufficient insurance, and high-risk ship-to-ship transfers.

A sanctions screening program should therefore consider vessel behavior as well as database results.

12. Examine Ship-to-Ship Transfer History

Ship-to-ship transfers are lawful and common maritime operations.

However, STS operations may create heightened sanctions risk where they obscure cargo origin or trading history.

Relevant questions include:

• Which vessels participated?
• Where did the transfer occur?
• Were AIS systems operating normally?
• What cargo was transferred?
• Do cargo quantities match?
• Is there a credible chain of documentation?
• Were either vessel’s ownership or flag recently changed?

The IMO has highlighted the increased safety, environmental, liability, and sanctions-evasion concerns associated with opaque high-seas STS operations involving shadow-fleet tankers.

13. Monitor Changes After Initial Screening

Sanctions screening should not be treated as a one-time exercise.

A counterparty that was clear when the charterparty was signed may later become designated.

Ownership may change.

The vessel may change flag.

The consignee may be substituted.

Payment instructions may change.

The cargo may be redirected.

Sanctions lists themselves are also updated. For example, the UN Consolidated Sanctions List was updated in May 2026, while individual sanctions regimes may receive later amendments.

For higher-risk transactions, screening should therefore be repeated at appropriate stages, including before performance or payment where necessary.

14. Maintain Written Sanctions Screening Records

A sophisticated compliance program should produce evidence.

Companies should preserve:

• screening results;
• timestamps;
• corporate documents;
• beneficial ownership information;
• vessel searches;
• cargo documentation;
• end-user declarations;
• legal opinions;
• internal approvals;
• escalation records.

The purpose is not merely defensive.

Documented due diligence allows the company to demonstrate why a transaction was approved, rejected, or escalated.

15. Create a Red-Flag Escalation Procedure

Automated screening software cannot replace legal judgment.

Potential red flags should trigger enhanced review rather than automatic commercial approval.

Important warning signs include:

• sanctions-list matches;
• unexplained ownership structures;
• recent vessel name or flag changes;
• repeated AIS gaps;
• unusual STS transfers;
• last-minute consignee changes;
• inconsistent cargo documentation;
• unusual payment routes;
• reluctance to disclose beneficial ownership;
• cargo descriptions inconsistent with technical documents.

Where several red flags appear together, the risk increases significantly.

What Changed or Matters in 2026?

The central Turkish sanctions framework remains anchored in existing legislation, particularly Law No. 7262 for relevant proliferation-financing and UNSC implementation measures. However, companies should not confuse a lack of entirely new sanctions legislation with a static compliance environment.

Sanctions lists continue to change during 2026. The UN Consolidated List was updated on May 21, 2026, while regime-specific lists may be updated separately.

Turkey’s trade-control environment has also evolved during 2026. Current import communiqués include specific controls for dual-use materials and technologies, while July 2026 amendments changed parts of the Import Regime and tariff framework.

Shipping companies operating in Turkey should therefore use current screening data and current customs rules for each transaction rather than relying on compliance checks completed months earlier.

Frequently Asked Questions

1. Is sanctions screening mandatory for every shipping transaction in Turkey?

There is no single universal rule requiring every shipping company to perform an identical screening procedure for every transaction. However, applicable Turkish sanctions, asset-freezing, trade-control, customs, and proliferation-financing rules can create serious liability, making risk-based sanctions screening essential.

2. Does Turkey implement United Nations sanctions?

Yes. Relevant UNSC measures are implemented through Turkey’s domestic legal framework. Law No. 7262 specifically provides mechanisms concerning asset freezes and prohibitions, including measures involving maritime vessels.

3. Should shipping companies screen vessels by name or IMO number?

Both should be checked, but the IMO number is particularly important because vessel names and flags can change.

4. Should beneficial owners be screened?

Yes, particularly in higher-risk transactions. Screening only the registered company may fail to identify sanctions exposure arising through ownership or control.

5. Should charterers also be screened?

Yes. Charterers and relevant sub-charterers may control cargo selection, trading routes, nominated ports, and counterparties.

6. Are dual-use goods regulated in Turkey in 2026?

Yes. Turkey’s 2026 import framework contains specific provisions concerning documentation for dual-use materials and technologies.

7. Does an AIS gap prove sanctions evasion?

No. AIS interruptions can have legitimate explanations. However, unexplained AIS gaps combined with suspicious ownership changes, STS transfers, or cargo documentation may justify enhanced due diligence.

8. Can a vessel itself be subject to UN sanctions?

Yes. Certain sanctions regimes specifically provide for measures concerning vessels. The DPRK sanctions framework, for example, maintains a designated-vessels list and includes port-entry and asset-freezing measures in specified circumstances.

9. How often should sanctions screening be repeated?

The frequency should reflect the transaction’s risk. Higher-risk voyages may justify screening at contracting, before loading, before port entry, before payment, and whenever ownership, cargo, consignee, destination, or other material circumstances change.

10. What should a shipping company do after finding a sanctions match?

The transaction should not simply proceed on the assumption that the match is irrelevant. The company should verify the identity, determine which sanctions regime applies, examine ownership and control, preserve the screening evidence, and obtain legal advice before taking further action.

Legal Support for Maritime Sanctions Compliance in Turkey

Sanctions compliance in international shipping is no longer limited to checking whether a vessel appears on a sanctions list. Effective due diligence may require examination of the vessel, registered owner, beneficial owner, manager, charterer, cargo owner, shipper, consignee, end user, banks, insurers, cargo origin, destination, AIS history, and ship-to-ship transfers.

Fırat Fesih Kaya provides legal assistance to foreign shipowners, shipping companies, operators, managers, charterers, cargo interests, and international trading companies concerning sanctions screening, Turkish maritime compliance, customs and trade controls, vessel restrictions, and sanctions-sensitive transactions.

A carefully structured pre-voyage sanctions review can help identify legal risks before a vessel is exposed to cargo detention, payment problems, insurance disputes, port restrictions, or high-value contractual claims.

Working with an experienced maritime lawyer from the beginning can help shipping companies establish defensible compliance procedures, evaluate complex sanctions matches, and protect their commercial interests when operating in Turkey.

For a case-specific assessment or maritime sanctions compliance review, you may contact our office.

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