As of 8:00 a.m. EDT / 3:00 p.m. Türkiye time on September 22, 2026. This brief reviews developments from September 21 through September 22.

A Turkish defense and aerospace manufacturer — which has not been publicly identified — signed a joint venture agreement on September 20 with a U.S. Tier 1 aerospace component supplier to establish a manufacturing facility in the United States for structural aerospace components. The JV will be incorporated in Delaware, with the Turkish partner holding a 49% interest and the U.S. partner holding 51%. The initial investment commitment is approximately $85 million over three years.

This transaction illustrates the growing interest of Turkish defense and aerospace manufacturers in establishing U.S. manufacturing presence to qualify for U.S. government and prime contractor supply chains. The 49/51 ownership structure is a deliberate design choice: it preserves U.S. control for ITAR and DFARS compliance purposes while giving the Turkish partner meaningful economic participation.

Key legal considerations include: ITAR registration and licensing for the JV entity and its Turkish employees; DFARS domestic content requirements if the JV intends to supply to U.S. government prime contractors; the treatment of Turkish-origin intellectual property contributed to the JV; and the governance provisions of the JV agreement, including deadlock resolution, buy-sell mechanisms, and exit rights. The Turkish partner should also assess whether the transaction requires notification to Turkish defense procurement authorities under applicable Turkish export control regulations.

The Bureau of Ocean Energy Management announced the results of its September 2026 Gulf of Mexico oil and gas lease sale on September 21. The auction attracted $1.8 billion in high bids across 312 tracts, with major bidders including Shell, Chevron, and BP. The auction reflects continued industry interest in deepwater Gulf of Mexico exploration despite the energy transition.

For Turkish energy companies evaluating U.S. offshore energy investments, BOEM lease auctions provide a direct entry point into U.S. offshore production. However, the capital requirements, technical complexity, and regulatory framework of deepwater Gulf of Mexico operations are substantial. Turkish companies are more likely to access U.S. offshore energy exposure through equity investments in listed E&P companies or through participation in onshore shale plays with lower capital thresholds.

Ecolab completed the operational separation of its divested water treatment chemicals business from its retained operations on September 21, following the earlier KKR acquisition. The separation involved the migration of approximately 2,400 employees, the transfer of 18 manufacturing facilities, and the establishment of transitional service agreements covering shared IT, finance, and supply chain functions.

Industrial carve-outs of this complexity typically require 12-18 months of post-closing separation work. The transitional service agreements are a critical bridge during this period, and their scope, pricing, and termination provisions should be carefully negotiated to avoid creating long-term operational dependencies.

The Turkish defense aerospace JV is a significant cross-border transaction with complex ITAR, DFARS, and export control implications. Turkish defense manufacturers pursuing U.S. market access through JV structures should engage specialized U.S. defense and export control counsel early in the transaction process.

This publication is for general informational purposes only and does not constitute legal advice.