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LEGAL SERVICES

Economic Sanctions and Export Controls

Legal support for sanctions risk in cross-border transactions, product and technology controls, licensing processes and internal compliance.

Legal assessment in cross-border trade

With whom, what, where and under what conditions are you trading?

Economic sanctions may restrict certain persons, entities, countries, sectors or transactions. Export controls may cover not only goods but also software, technology, the end user and the intended use. Searching for the counterparty’s name in a list is not enough on its own to explain the legal position of a transaction.

Güneş & Güneş Law Firm provides advice and representation to exporters, importers, manufacturers, technology companies, distributors, logistics operators, financial institutions and investors in their Türkiye-related transactions. The contract, product information, ownership structure, payment flow and shipment flow are assessed together.

Pre-transaction review, identifying the permits that may apply, building in-house compliance and managing any dispute that arises are planned as separate scopes of work, according to need.

Is a payment or shipment pending?

Preserve the letter from the bank or the competent authority, the transaction documents and any stated deadline. Until the reason for the hold is identified, do not proceed with the transaction by changing the party, payment or shipment details.

Review the first steps

Practice areas

Our services in sanctions and trade compliance

The scope of legal work, from preparing the transaction through review, disputes and implementation of a decision, is set out in the groups below.

Sanctions risk

Country links, list screening, ownership, control and licenses.

Review the scope

Export controls

Products, technology, end users, re-exports and digital transfers.

Review the scope

Contracts and investment

Sales, distribution, supply, impediment to performance, acquisitions and investment.

Review the scope

Payments and logistics

Bank controls, trade finance, insurance and transport.

Review the scope

Internal compliance

Transaction approval, records, training, audit and the link to the Financial Crimes Investigation Board (MASAK).

Review the scope

Review and disputes

Internal reviews, administrative proceedings, listing decisions, litigation and arbitration.

Review the scope

Sanctions risk, counterparty review and permits

4 work topics

Transaction and country-link analysis

  • Identifying the legal links among the parties, banks, product, service and trade flow
  • Separate assessment of Türkiye’s regulations and any applicable foreign sanctions regimes
  • Separating primary prohibitions, secondary sanctions risk and commercial contract obligations

Screening of parties, companies and vessels

  • Reviewing distinguishing details such as company name, former names, address, registration number and vessel identity
  • Determining which list and which restriction a potential match rests on
  • Recording the date of the review, the source used and the reasons for the decision

Ownership, control and beneficial owner

  • Assessing direct and indirect ownership structure and ultimate beneficial owner information
  • Reviewing voting rights, power to appoint management, concerted action arrangements and indicators of actual control
  • Applying the OFAC, EU and United Kingdom tests under their own rules

Licenses, exemptions and applications to competent authorities

  • Assessing the conditions and limits of the license, permit or exemption suited to the transaction
  • Preparing the application file, the grounds, supporting documents and the follow-up plan
  • Coordinating with legal counsel authorized in the relevant country for proceedings before foreign authorities

Products, technology and export controls

4 work topics

Product and technology classification

  • Reviewing the control list based on the technical catalog, composition, function and performance data
  • Separating the customs tariff code (GTİP) from the export control classification
  • Legal assessment of the ECCN or the relevant control item with information from technical experts and the manufacturer

Dual-use items and sensitive areas

  • Assessing goods, software and technologies that may have both civilian and military uses
  • Determining the competent authority and the permit procedure in Türkiye according to the nature of the product
  • Coordinating with the special regulations in the defense, nuclear, chemical and biological fields

End user and end use

  • Reviewing the consistency of the end-user statement, commercial capacity and the stated use
  • Assessing use-based controls that may apply even to a product or party that does not appear on a list
  • Determining the need for additional documents and review where the use, intermediary or final destination is unclear

Re-export and digital transfer

  • Assessing the legal scope of shipment via a third country and of in-country transfer
  • Reviewing the EAR connection with regard to U.S.-origin content and certain foreign direct product rules
  • Addressing source code, technical data, remote access and technical assistance together with the transfer rules

Contracts, supply relationships and investment

4 work topics

Sales and distribution contracts

  • Preparing sanctions and export control undertakings to fit the specific transaction
  • Regulating end-use, resale, document-provision and change-notification obligations
  • Negotiating breach, audit, cost-sharing and liability provisions

Suspension, termination and force majeure

  • Assessing the effect of a new sanction on the performance of an existing contract
  • Reviewing notice, suspension, adaptation, termination and damages options under the governing law
  • Addressing the availability of a license, any transition period and loss-mitigation obligations together

Supplier and intermediary contracts

  • Determining the responsibilities of distributors, agents, commission agents and sub-suppliers
  • Establishing document access, audit rights and an internal procedure for reporting a risky request
  • Assessing the consistency between contractual undertakings and actual transaction data

Mergers, acquisitions and investment

  • Legal review of the target company’s past transactions for sanctions and export control issues
  • Preparing provisions on representations and warranties, indemnification, conditions precedent to closing and permits
  • Coordinating the post-acquisition compliance plan with any separate investment permits required

Payments, financing, logistics and sector-specific transactions

4 work topics

Bank holds and payment problems

  • Reviewing the bank’s request for information, its reasons for refusing or holding, and the transaction documents
  • Distinguishing among a legal asset freeze, a transaction prohibition and the bank’s risk policy
  • Preparing an accurate and complete disclosure file and the application to the bank or the competent authority

Trade finance and insurance

  • Assessing sanctions provisions in letters of credit, guarantees, financing and insurance contracts
  • Reviewing disputes over presentation, payment, security and insurance coverage
  • Separating the permit condition from the financing provider’s independent assessment

Transport, transit and maritime trade

  • Assessing links to carriers, vessels, operators, ports, intermediaries and routes
  • Reviewing consistency among cargo, transport and insurance documents and any applicable sector restrictions
  • Analysis of delivery, storage, demurrage and contractual liability where a shipment is held

Energy, technology and financial services

  • Assessing sector-specific restrictions particular to the product, service and parties
  • Reviewing transaction links in software, technical services and crypto asset services
  • Assessing risk on the basis of the specific activity and date, rather than general assumptions based on a country’s name

Trade compliance program and internal controls

4 work topics

Company-specific trade compliance program

  • Risk assessment according to the business model, markets, products and transaction volume
  • Preparing management responsibility, the authority matrix and transaction approval procedures
  • Allocating duties among the legal, sales, finance, procurement and logistics teams

Transaction controls and record-keeping

  • Identifying control points at customer acceptance, order, shipment, payment and change
  • Evaluating screening alerts and keeping exception decisions and records traceable
  • Establishing an appropriate arrangement for retention periods, access authority, trade secrets and personal data

Training, audit and improvement

  • Preparing employee and manager training with case examples suited to each role
  • Reviewing controls against sample transactions and reporting gaps
  • Reflecting changes in legislation and the business model in policies

Link to MASAK and other compliance areas

  • Separating sanctions screening from controls on preventing money laundering and the financing of terrorism
  • Assessing the organization’s status as an obliged entity and the notification duties specific to the file
  • Coordination with anti-bribery, data protection and internal reviews

Review, administrative applications and dispute management

4 work topics

Suspicious transaction flow and internal review

  • Determining the scope of the event and preserving existing records lawfully
  • Proportionate review of the relevant employee, contract, payment and shipment information
  • Preparing a legal plan for corrective measures, whether notification is required and subsequent steps

Administrative review and sanctions proceedings

  • Assessing information requests, official notifications (tebligat), decisions and the applicable time limits
  • Preparing defenses, objections, permits and other administrative applications
  • Representation before competent authorities in Türkiye and coordination with local counsel in foreign proceedings

Listing and false match

  • Clarifying a false identity or company match with supporting documents
  • Determining the routes for review, delisting or judicial review of a listing decision
  • Preparing the file according to the authority and procedural requirements of each sanctions regime

Contract disputes, litigation and arbitration

  • Assessing claims relating to payment, delivery, impediment to performance, termination and damages
  • Reviewing the governing law, jurisdiction or arbitration clause and the need for interim legal protection
  • Addressing sanctions links separately in the recognition, enforcement and execution of a decision

Defining the transaction correctly

Five key distinctions that change the outcome

The right distinction at the outset determines what information is needed and which route of application is to be assessed.

Key distinctions in a trade compliance review
TopicWhat does it mean?What do we check?
List screening and whether the transaction is permissibleA name match is an indicator for review. The accuracy of the match, the type of list and its effect on the transaction are determined separately.The party’s identity, ownership, product, use, country, bank and date are assessed together.
Ownership and controlOFAC’s 50 percent rule and the EU and United Kingdom ownership and control tests are not the same.A single percentage threshold or calculation method does not apply to all regimes.
GTİP and control classificationThe customs tariff code and the ECCN or dual-use control item are different classifications.Technical specifications, the control list and use information are reviewed. The EAR99 designation also does not mean that a license is unnecessary in every transaction.
Freezing, transaction prohibition and bank refusalAn asset freeze, a prohibition on a specific transaction and the bank’s own risk decision can have different consequences.The written reasons, the applicable norm, the possibility of a permit and the authority to apply to are kept distinct.
Primary and secondary sanctions riskFor a direct legal prohibition, the jurisdictional link is examined. Under some regimes, non-U.S. persons may also face secondary sanctions risk tied to certain activities.It is not assumed that every foreign rule applies automatically in Türkiye, or that the risk ends when no foreign link exists.

OFAC match clarification (opens in a new tab)BIS end-use clarification (opens in a new tab)

Legal framework

The scope and link of each regime are reviewed separately

Coordination with legal counsel authorized in the relevant country may be needed for a permit, notification, representation or lawsuit in a foreign country.

Türkiye and the United Nations

In Türkiye, Laws No. 6415 and No. 7262, the relevant decisions and product-based export rules apply within their own scopes. The implementation of a UN decision in Türkiye, an asset measure and an export permit are not the same review. Current Official Gazette (Resmî Gazete) decisions and the records of the competent institutions are checked in the file.

Review the official source (opens in a new tab)

United States: OFAC and BIS

OFAC’s financial sanctions and BIS’s export controls have separate authorities and permit systems. Direct or indirect aggregate ownership of 50 percent or more by blocked persons can affect, for OFAC purposes, a company that is not named on a list. Control alone does not create an automatic block under this rule; other prohibitions are examined separately.

Review the official source (opens in a new tab)

European Union

In EU sanctions, besides ownership, control and the indirect provision of funds for someone’s benefit are also significant. For dual-use items, Regulation 2021/821, the current annexes and member state practice are assessed together. Sectoral bans, service bans, exemptions and authorization provisions are determined from the relevant regulation.

Review the official source (opens in a new tab)

United Kingdom

The UK Sanctions List is read together with the relevant sanctions regulation. The OFSI guidance sets out, for ownership, a holding of more than 50 percent in shares or voting rights, together with separate control criteria. The holdings of different persons are not automatically aggregated using the OFAC method without examining joint exercise of rights and control facts.

Review the official source (opens in a new tab)

Transit through a country, use of a different currency or the involvement of a third person does not, on its own, remove a sanctions or export control obligation.

Current source notes

Recent developments affecting transaction planning

A new regulation may require an existing order, contract or control policy to be reviewed again.

EU dual-use items list

September 14, 2026 · adoption versus entry into force

The European Commission adopted the regulation updating the Annex I list of Regulation 2021/821. The official announcement provides for entry into force upon publication in the Official Journal after the usual two-month review period. For this reason, the adopted text should not automatically be treated as replacing the list in force as of October 4, 2026.

Review the official source (opens in a new tab)

BIS Affiliates Rule

Temporary suspension · until November 9, 2026

The regulation dated November 12, 2025 suspended the changes to the Affiliates Rule for the period November 10, 2025–November 9, 2026. The text provides for application to resume on November 10, 2026 unless there is a new extension or amendment. This suspension does not remove OFAC’s 50 percent rule or other EAR prohibitions.

Review the official source (opens in a new tab)

United Kingdom lists

January 28, 2026 · move to a single list

In United Kingdom sanctions records, the UK Sanctions List has become the single source. The former OFSI consolidated list is no longer updated. The screening source used by companies, the new record identifiers and list-update processes should be reviewed accordingly.

Review the official source (opens in a new tab)

EU sanctions on Russia

July 23, 2026 · 21st package

The package includes changes in finance, crypto asset services, energy, transport and export restrictions. Some persons and entities with third-country links are also covered. The relevant annex, the product or service, the transitional provision and the date of entry into force must be checked separately for the transaction.

Review the official source (opens in a new tab)

OFAC match assessment

September 9, 2026 · updated clarification

OFAC updated its clarification in FAQ 5 on evaluating potential name matches. Identity verification, the type of restriction, any permit or exemption and the records to be kept are treated as separate stages. A screening software alert does not, on its own, replace a legal decision.

Review the official source (opens in a new tab)

The source in effect on the day of the transaction governs. Sanctions lists, general licenses, exemptions and product lists may change. The dated summary here is not a current determination of compliance for any particular party or transaction.

Source review and content preparation date: October 4, 2026. Regulations that have been adopted but have not yet entered into force are noted separately.

Pending transactions and time limits

What should be done at the first stage?

Decisions made under pressure from a notification or a shipment must also rest on a documented legal assessment.

A payment was held or refused

Collect the bank’s written explanation, the transaction reference and the documents it has requested. How the payment will be handled should not be decided until the legal freezing decision has been separated from the bank’s policy.

A shipment or technology transfer is planned

The product, technical data, parties, end user and destination are clarified. Without determining the necessary permits and transaction conditions, work does not proceed on the basis of the contract or the customer’s statement alone.

An official notification, information request or review has been received

Preserve the entire document, the time of service and the response deadline. Do not alter any records. Notification, defense and objection obligations are calculated separately under the relevant regime.

A risky transaction was noticed within the company

Preserve documents and correspondence lawfully and refer the matter to the designated person. Any ongoing transaction, whether notification is required and corrective steps are assessed specifically to the file.

There is no single time limit for every application. As the competent authority, country, decision and requested action change, so do the time limit and the effect of the application. A license or consultation request does not remove a prohibition by itself and does not suspend legal time limits.

Our approach

From the initial assessment to implementation and follow-up

The scope of the service, responsibilities, the specialist expertise required and the work to be delivered are determined together with the needs of the file.

  1. Scope of the work and urgency

    The parties, the transaction, the current stage and any approaching deadline are identified. Conflict of interest, representation and document-sharing conditions are assessed.

  2. Transaction and party map

    The product or service, ownership structure, end use, countries, banks and transport flow are reviewed together.

  3. Applicable rules

    The links to Türkiye and the relevant foreign regimes, product class, prohibitions, permits, exemptions and notification conditions are determined.

  4. Options and work plan

    A reasoned legal assessment, missing information, applications to be made and the allocation of tasks are shared with the client.

  5. Documents, contracts and applications

    Contracts and files are prepared within the agreed scope; the process is conducted with the competent institution, bank or local counsel.

  6. Follow-up and updates

    Decisions, conditions and time limits are monitored. Information is provided at key stages; for recurring transactions, the control arrangement is reviewed.

Continuing control

A compliance program should be part of everyday transactions

A ready-made policy text does not, on its own, cover a company’s products, markets and decision-making processes. The program is built around the actual workflow and the responsible teams.

  • Responsibilities and decision-making authority set by management
  • Risk assessment by product, country, customer and transaction type
  • Counterparty review when a business relationship is established and upon significant changes
  • Controls before orders, shipments, payments and technology transfers
  • Assessment and senior approval procedure for unclear or matching transactions
  • Monitoring of permit conditions, records and retention periods
  • Training and case studies suited to employees’ duties
  • Auditing of controls, remedying of gaps and monitoring of legislation

OFAC compliance framework (opens in a new tab)EU due diligence guidance (opens in a new tab)

The reasons for a decision should be visible

The information used in the review, the gaps, the applicable rules and the decision made are recorded. Using a screening system or an external service provider does not replace the company’s own obligations or the need for a legal assessment.

Preparing for a consultation

Documents that may be useful in the initial review

Not every document is needed in every file. The scope of the review, the need for information and the method of sharing are determined in the consultation.

Transaction, party and product information

  • The full name, country and registry details of the parties and their roles in the transaction
  • Direct and indirect ownership chart, share and voting-right information
  • Product catalog, technical specifications, the known GTİP and control classification
  • The end user, the purpose of use and the end-user statement
  • Sales, distribution, supply or technology license agreements
  • Order, invoice, transport, insurance and shipment plan

Payment, permit and review records

  • Bank information requests, the payment reference and the written refusal or hold explanation
  • Existing licenses, permits, the basis for exemptions and their conditions
  • Dated results of any screening carried out and evaluation records
  • Letters from competent authorities, decisions and records of service
  • Relevant correspondence, transaction history and an event timeline
  • If any, compliance policies, approval records and training and audit reports

A short summary is enough for first contact. State the countries concerned, the product or service, the stage of the transaction, the problem and any approaching deadline. Trade secrets, bank and identity documents are not requested in the first form; the secure sharing method is determined separately.

Coordination with technical experts and local counsel

For product classification, technical data from the manufacturer, engineer or customs broker may be needed. The need for a binding opinion, a license, an administrative application or representation in a foreign country is planned together with an attorney authorized in that country. Technical data, legal assessment and the institution’s decision are separate areas of responsibility.

The source document, the assumptions of the review and information gaps are clearly recorded. A technical expert opinion or a private report is not treated as a substitute for the permit of the competent authority.

Our center and scope of work

From Antalya to Türkiye and to international transactions

Legal representation in Türkiye and the work of authorized legal counsel in the foreign country are planned together according to the needs of the file.

Based in Antalya, serving all of Türkiye

Güneş & Güneş Law Firm was founded in Kemer on March 18, 1999 by Attorney Umut Güneş. Since 2007, from its physical headquarters in Antalya, it organizes services for advisory, administrative application and dispute processes in all 81 provinces of Türkiye, taking into account the requirements of jurisdiction and representation.

The scope of work across Türkiye does not mean there is a physical office in every province. The competent authority and the local procedural requirements are determined according to the nature of the file.

Cross-border files with a Türkiye link

Transactions of companies and persons resident abroad that have a Türkiye link may be conducted through online meetings, secure document sharing and communication in Turkish, English, German and Russian.

The applicable legal order, authority to represent, use of foreign documents, translation and confidentiality conditions are assessed separately according to the nature of the file.

When a local procedure abroad is required

The selection of an attorney authorized in the relevant country or of a cooperating law firm, a preliminary consultation on the client’s behalf, the scope and agreement for the engagement, the transaction plan, the document flow, deadline monitoring and regular updates are coordinated. Local representation is carried out by an attorney authorized in that country. The fees, expenses and responsibilities of coordination and of local representation are determined separately.

The firm’s approach

A specific transaction, a clear scope and regular updates

Legal work is carried out on the basis of the information and documents relating to the client’s transaction.

The file as a whole

Contract, product, ownership, payment and logistics information is assessed without being separated from one another.

Reasoned options

The conditions of the permit, additional review, contract amendment, application or dispute options are explained.

Defining responsibilities

The tasks to be undertaken by the company team, the technical expert and the local counsel are defined clearly.

Confidentiality and follow-up

Information is used to the extent required by the legal assessment and the agreed service; key stages are shared with the client.

Scope of work and fees

Advisory work, contract work, the compliance program, internal review, administrative applications and litigation are determined as separate items of work. The attorney’s fee and the scope of the technical expert, translation, local advisor, court fees and other expenses are clarified in the consultation and reflected in the agreement.

Frequently asked questions

On sanctions and export controls

The answers below explain the general framework. For a specific transaction, the parties, product, country link and the regulations on the date of the transaction are assessed together.

What is the difference between sanctions compliance and export control?

Sanctions may restrict certain parties, countries, sectors or transactions. Export control may give rise to permits or prohibitions depending on goods, software, technology, destination, end user and end use. Because the same transaction may be subject to both areas, the reviews are carried out together.

Can Turkish companies be affected by foreign sanctions?

They may be, depending on the transaction’s link to the relevant legal order. A foreign shareholder, bank, person, product or service link, secondary sanctions provisions and contractual obligations may matter. That a company is established in Türkiye does not mean that all foreign regimes apply automatically or that none of them matters.

Review the official source (opens in a new tab)

Can a transaction go ahead if the counterparty does not appear on a list?

No such conclusion can be drawn on that basis alone. Ownership and control may affect a party that is not on the list. There may also be prohibitions based on product, service, use or country. The screening result is only one element of the transaction review.

Review the official source (opens in a new tab)

Is a name similarity a definitive sanctions match?

No. The accuracy of the match is examined through the company name, address, registry, date of birth or other distinguishing details. Which list and which restriction are involved is also determined; the alert and the reasons for the review are recorded.

Review the official source (opens in a new tab)

How is OFAC’s 50 percent rule assessed?

Direct or indirect aggregate ownership of 50 percent or more by one or more blocked persons is examined. In layered structures, the blocked status of intermediate companies matters; simply multiplying shares may lead to a wrong result. The relevant OFAC clarification and the program rules are applied together.

Review the official source (opens in a new tab)

Can the same ownership test be used for OFAC, the EU and the United Kingdom?

The same formula should not be applied. The effect of control, the share threshold and the joint assessment of different persons’ rights may vary by regime. A separate result is reached on the basis of current texts and the company’s actual management structure.

Review the official source (opens in a new tab)

Does a GTİP code replace the export control classification?

No. GTİP is the customs tariff classification. The export control item or ECCN may be determined by technical function, performance and other characteristics. The product name or invoice description alone may not be sufficient.

Does EAR99 mean sale to any country without a permit?

No. EAR99 does not mean that the product is outside the scope of the EAR. There may be licenses and prohibitions depending on the end user, end use or destination. The specific transaction is assessed separately.

Review the official source (opens in a new tab)

If a product is not on a control list, is any other control needed?

Rules based on use and user may still matter. Additional review is needed particularly where the end use is unclear or the competent authority has issued a notification. Each regime’s non-list control conditions are determined from its own text.

Review the official source (opens in a new tab)

Is the sending of software and technical data by email also reviewed?

Depending on the product and the legal link, electronic transfer, access to source code, technical assistance or disclosure to certain persons may also fall within the scope of control. That no physical goods are shipped does not make the review unnecessary.

Review the official source (opens in a new tab)

Can a product manufactured in Türkiye be subject to U.S. export controls?

It may be, because of certain U.S.-origin controlled content or the foreign direct product rules. Not every U.S. component has the same effect. The production, content, technology and destination link must be reviewed technically and legally.

Review the official source (opens in a new tab)

Does the suspension of the BIS Affiliates Rule remove all restrictions?

No. The temporary suspension concerns only the relevant Affiliates Rule changes. OFAC sanctions, existing BIS list restrictions and other end-use or country controls are assessed separately. For the current timetable, the official text in the developments section of the page should govern.

Review the official source (opens in a new tab)

Does obtaining an export license also guarantee bank payment?

No. An export permit and a financial sanctions permit may differ. The bank’s applicable obligations, the transaction documents and its own risk assessment also matter. The scope of the permit and the payment terms are reviewed together.

If a general license or exemption exists, is a separate review still needed?

Yes. There may be conditions relating to the party, product, activity, date, amount, record-keeping or reporting. Another prohibition may continue. The existence of an exemption does not mean that the same result applies to every similar transaction.

Review the official source (opens in a new tab)

If the bank is not making a payment, what information is needed first?

It should be clarified whether the payment has been refused, held or legally blocked. The written reasons, the transaction reference, the party information and the requested documents are reviewed. The route of application can be determined only after this distinction.

Review the official source (opens in a new tab)

Is adding a sanctions clause to the contract enough?

A contract provision does not remove actual controls or legal obligations. Provisions on notification, document provision, end use, audit, suspension and liability should fit the transaction and should also be monitored in practice.

Does a new sanction terminate the contract automatically?

Not in every case. The governing law, the contract provisions, the nature of performance, the possibility of a permit or transition, notice and loss-mitigation obligations are assessed. A force majeure or termination outcome is not accepted automatically.

Is sanctions screening done only at customer onboarding?

Depending on the risk and the legislation, re-screening is needed at later stages. A change in ownership, lists, products, end user, shipment or the payment flow may call for a new assessment. The frequency of controls is set according to the company’s business model.

Should the vessel, carrier and port also be reviewed?

Yes, depending on the scope of the transaction. The identity of the vessel and operator, port, carrier, insurer and cargo links may affect the applicable restrictions. Looking only at the names of the seller and buyer may not be sufficient.

Does paying with a crypto asset change a sanctions obligation?

A change in the means of payment does not remove a party or transaction prohibition. The service provider used, the transfer and the party links are reviewed separately. Regulations specific to crypto asset services may also apply.

How are records preserved in a compliance review?

Original documents and electronic records relating to the transaction are preserved unaltered. Access authority, retention period, professional secrecy, personal data and trade secret obligations are assessed together. Unlimited retention or public sharing is not appropriate for every record.

Is notification mandatory if a non-compliance is identified?

Depending on the regime, the organization’s status and the nature of the event, mandatory notification or voluntary disclosure options may arise. The authority, scope and time limit are determined in the file. Self-disclosure is not immunity from penalty or a guarantee of a favorable outcome.

Is direct representation before an authority abroad available?

Local representation and authority to apply depend on the rules of the relevant country. Where necessary, the work is coordinated with an attorney authorized in that country or a cooperating law firm. The scope, responsibility, fees and information-sharing conditions are determined separately.

What should I share in the first meeting, and when does representation begin?

It is enough to briefly state the countries concerned, the type of transaction, the product or service, the problem and any approaching deadline. The sharing of sensitive documents is planned separately. A consultation request does not, on its own, mean that the matter has been accepted or that representation has begun; the scope, the agreement and the required authorization are completed separately.

Sources and information

Legislation and official clarifications

The sources, with their dates and scope, are listed below. The entry into force, additional lists and permit conditions specific to a transaction are rechecked in each file.

Open the source links

Legal information note

This page is for general information purposes; it does not constitute, for any particular transaction, a determination of sanctions compliance, a product classification, a license decision, a legal opinion or a commitment to a result. Obligations, the jurisdictional link, the route of application and time limits vary according to the circumstances of the specific case. A consultation request does not by itself establish an attorney–client relationship.

Content preparation date: October 4, 2026.

Legal consultation

Briefly describe your transaction and the problem you face.

You may request a consultation about sanctions risk, export controls, product or technology transfer, a bank transaction, a license, a contract, a compliance program or a review process.

State the countries concerned and any approaching deadline. For a time-sensitive matter, protect your own application timetable separately instead of waiting for a reply.

Open the consultation request page

Information provided to us is kept confidential and is used only to the extent required by the legal assessment and the agreed service. Trade secret, identity, bank and investigation documents are not requested in the first form; the secure sharing method is determined separately. Do not share e-Devlet, Registered Electronic Mail (KEP), e-signature, bank or portal passwords. You can review the explanations in Confidentiality and Information Security.