Sanctions in the Maritime Sector: Turkey’s Path to Compliance and Impact on the Bunker Industry

On December 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented new sanctions against Iran, which in turn brought back into focus the vessels and maritime companies previously sanctioned due to sanctions imposed on Russia. This situation highlighted once again the impact of international sanctions on the maritime sector and underscored the importance of compliance with sanctions for parties involved with these vessels or companies.

The maritime sector, which carries more than half of global trade, is at the center of international sanctions. Global regulatory authorities such as the U.S. (OFAC), the United Kingdom (OFSI), and the European Union (EU) are increasing oversight over the sector through sanctions and making it mandatory for companies to operate within the legal framework.

In this article, we address the scope of global sanctions and the compliance requirements in the maritime sector, while also discussing Turkey’s role in this process and the measures companies need to take.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposes comprehensive sanctions targeting the maritime sector.

• Individuals and entities outside of the U.S. may face sanctions if they conduct business with sanctioned parties.
• Iran, North Korea, Venezuela, and Syria are prioritized on OFAC’s sanctions list.
• Trading with individuals, companies, and vessels listed on the U.S. “Specially Designated Nationals” list is prohibited.
• The OFAC Guidelines detail critical factors the maritime sector must be aware of, such as AIS manipulation, fake documents, and ship-to-ship cargo transfers, which are deceptive activities.

The Office of Financial Sanctions Implementation (OFSI) in the United Kingdom independently enforces sanctions following Brexit.

• A ban on port access for Russian vessels has been imposed, and restrictions have been placed on energy trade
• OFSI requires companies to closely monitor their compliance processes by imposing heavy fines for sanction violations.

EU sanctions are applied to support international peace and security.

• EU sanctions target countries such as Russia, Iran, North Korea, and Syria.
• EU sanctions cover not only EU citizens but also all transactions occurring within the EU border.

Critical Compliance Requirements for the Maritime Sector

1. Companies must regularly check the compliance of their trade partners and transactions with sanction lists.
   • S. SDN List: Individuals and entities published by OFAC.
   • UK Consolidated List: The UK’s sanctions
   • EU Sanctions Map: An interactive map showing sanctioned parties published by the EU.
2. Customer Due Diligence (KYC) processes enhance the transparency of business relationships.
   • Identify Ultimate Beneficiaries: Under the 50% Rule, if an individual who holds more than 50% of a company’s shares is on the sanctions list, that company is also considered to be under sanctions.
   • Collect UBO Information: By gathering the identity details of ultimate beneficial owners, potential risks can be detected in advance.
3. Financial transactions are one of the most critical points of compliance with sanctions. Transactions conducted in U.S. dollars, euros, or British pounds may be subject to sanctions imposed by the relevant countries.
4. For sanctions compliance, companies must: Develop written policies, Conduct risk assessments, Ensure staff training is not neglected.
5. Checking past transactions against sanction lists is an effective method for detecting potential violations and making voluntary disclosures

Turkey Perspective: Increased Sanctions Awareness

Due to its strategic location, Turkey is one of the countries directly affected by global sanctions. In recent years, awareness among Turkish companies regarding compliance with international sanctions has increased, and they have been observed to act more cautiously in this regard. Reviewing past transactions, identifying business relationships with risky parties, and ensuring compliance with current sanctions lists contribute to positioning Turkish companies as reliable players in international trade.

Turkish shipyards and port operators, especially in relation to vessels carrying sanction risks, prefer to contact international authorities directly before initiating transactions. For instance, when a vessel requests repair, maintenance, or bunkering services, contact is made with U.S. or other relevant authorities to confirm the vessel’s current status, the existence of necessary licenses, and whether the transaction is in compliance with the legal framework. Such proactive steps not only ensure legal compliance but also allow companies to maintain their international reputation.

Bunker Services: Increasing Responsibility Under Sanctions

Bunker service providers are among the most affected actors in the maritime sector due to sanctions. Sanctions not only cover the provision of fuel to vessels but also extend to the financial and operational processes involved in these services. Turkish bunker companies are increasingly sensitive to compliance with international sanctions in this context.

• Providing services to vessels listed on sanctions lists can result in financial and commercial restrictions. However, it is necessary to thoroughly examine not only the vessel but also the vessel owner, operator, or other associated parties.
• Bunker companies inquire about the existence of relevant licenses associated with the vessel before providing services and, when necessary, contact the U.S. or other relevant authorities directly. This communication ensures that the transaction complies with sanctions and verifies the validity of the required licenses.
• Sanctions closely monitor payments made, especially those conducted in U.S. dollars.

Turkish bunker service providers conduct thorough assessments before providing services and avoid risky transactions. For example:

• Sanctions List Check: Lists such as OFAC, the UK Consolidated List, and the EU Sanctions Map are regularly reviewed, and risks related to commercial parties are
• International Communication: Direct contact with the U.S. Treasury Department or other authorities is made to confirm the legal requirements regarding the transaction. This step ensures that the validity of any existing licenses is verified and the transaction is legally secure.

Bunker service providers understand that compliance with sanctions is not only a legal obligation but also critical for operational sustainability and reputation management. Through proactive approaches, internationally compliant processes, and risk analyses, Turkish companies are strengthening their position in international trade.

In this process, regular checks, transparency, and effective communication with international authorities are key elements that enhance a company’s resilience against sanctions.

At Sodac Law, we support companies in the maritime and bunker sectors in complying with international sanctions, managing risks, and securing their operations. Feel free to contact us for professional support and consultancy regarding sanctions.