Compliance challenges of Turkish banks and companies in the face of OFAC sanctions

This thesis explores the impact of international sanctions—particularly those imposed by the U.S. Office of Foreign Assets Control (OFAC)—on the Turkish banking system, with a specific focus on domestic legal compliance mechanisms. The starting point of the study lies in the recognition that, as an economy deeply integrated into the global financial sys-tem, Turkey cannot remain unaffected by extraterritorial sanction regimes. The thesis examines the scope of OFAC's authority, the types of sanctions it enforces, its mechanisms of implementation, and the far-reaching consequences these measures have even beyond U.S. borders. It then turns to the Turkish banking sector, analyzing how local institutions respond through internal compliance programs, the role of MASAK regula-tions, risk-based approaches, and the legal obligation to report suspicious transactions. The legitimacy and boundaries of such sanctions are also discussed within the framework of World Trade Organization (WTO) principles. Rather than limiting itself to normative analysis, this study attempts to bridge the gap be-tween law and practice by considering real-world implementation challenges and institu-tional hesitations. Combining a legal perspective with practical insights drawn from direct professional experience, this thesis offers a critical and solution-oriented approach for building a more resilient sanctions compliance infrastructure in Turkey. Keywords: Banking Law, Sanctions, OFAC, Prevention of Laundering Proceeds of Crime Law , MASAK, FATF. Numeric Code of the Scientific Field: 51501