The State Department revealed on April 5 that previously announced US sanctions on Turkey’s military-industrial sector would come into effect on April 7 with the publication of a US Federal Register notice.
US sanctions under the CAATSA law, or the “Countering America’s Adversaries Through Sanctions Act” (Public Law 115-44), were initially announced by former Secretary of State Mike Pompeo on December 14, in response to Turkey’s purchase of the S-400 surface-to-air missile system from Russia.
Previously, the three titles of CAATSA had been focused on Russia, Iran, and North Korea. Washington and some of Turkey’s NATO allies had objected strenuously to this procurement decision, noting that sanctions were likely, but Turkey refused to back down.
In legal terms, the sanctions applied to Turkey are considered secondary sanctions under CAATSA because the Turkish companies opted to conduct transactions with entities previously listed on the US List of Specified Persons (LSP). Under CAATSA, the LSP is the list of Russian entities that are considered “primary sanctions targets” due to previously identified Russian foreign policy decisions in Ukraine, cyberspace, and intrusion in the 2016 U.S. elections. 
Readers of New Europe may recall that the Trump administration took the initiative last December to design and announce sanctions ahead of a looming Congressional deadline at that time, which as a result gave the Executive Branch more freedom to design the sanctions program.
Not a full arms embargo
Washington’s list of sanctions is less than a full arms embargo; readers will also recall Turkey had previously been ejected from the American F-35 fighter jet program. The focus of the US sanctions is a relatively narrow band of Turkey’s defense industrial structure, much of which remains highly dependent on US technology and requires US authorization for technology re-exports.
The State Department explained last December 14 its rationale for the sanctions. “Today, the United States is imposing sanctions on the Republic of Turkey’s Presidency of Defense Industries (SSB) pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act for knowingly engaging in a significant transaction with Rosoboronexport, Russia’s main arms export entity, by procuring the S-400 surface-to-air missile system. The sanctions include a ban on all U.S. export licenses and authorizations to SSB and an asset freeze and visa restrictions on Dr. Ismail Demir, SSB’s president, and other SSB officers.”
Those other senior SSB officers to be sanctioned have now been named. They include Faruk Yigit, SSB’s vice president; Serhat Gencoglu, SSB’s head of the Department of Air Defense and Space and Mustafa Alper Deniz, program manager for SSB’s Regional Air Defense Systems Directorate.
The Crete model
Since December, there have been occasional Turkish media reports that something like the “Crete model” might be fleshed out and agreed to allow US sanctions to be removed. This is a reference to the transfer of Russian S-300s purchased by Cyprus in the late 1990s to the Greek island of Crete, to avoid having the system bombed by Turkey while under installation in Cyprus.
A similar scenario for the S-400’s would have them stored in their shipping boxes or transferred to third countries, but Turkey’s activation of the S-400 system’s radars would now seem to preclude a solution of this type. Nonetheless, media reports of exploratory statements/trial balloons from Turkish officials regarding a similar arrangement continue to circulate.
US sanctions for Turkey’s S-400 procurement come into effect
Sanctions had been announced by Trump administration last December
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