As of August 25, 2026. This update highlights material U.S. legal and regulatory developments relevant to Turkish and international businesses with U.S. operations, investments, supply chains or financial connections.

Sanctions risk remains a central issue for businesses that touch the U.S. financial system, use U.S.-origin goods or technology, employ U.S. persons, or transact through U.S.-linked banks and service providers. Iran-related restrictions continue to require careful review of parties, ownership, end use, payment routes and the role of intermediaries. Syria-related activity likewise requires a current, transaction-specific assessment rather than reliance on historic assumptions about a market, customer or license position.

For a cross-border business, the key question is rarely limited to whether a direct counterparty appears on a sanctions list. A compliant review should also consider beneficial ownership, control, aliases, freight forwarders, banks, insurers, technology providers, end users and the commercial purpose of the transaction. OFAC's 50 Percent Rule can extend blocking consequences to entities owned, directly or indirectly, individually or in the aggregate, 50 percent or more by blocked persons even when the entity is not separately named on the SDN List.

Businesses should maintain a documented escalation process for transactions with a geographic, ownership, product or payment nexus to Iran or Syria. That process should distinguish between a potential sanctions match, a prohibited transaction, a transaction that may be authorized under a general license, and a matter requiring specific legal advice or a license application.

Useful controls include:

• Rescreening customers, suppliers, beneficial owners and payment instructions before shipment or payment release.
• Reviewing U.S.-person involvement, U.S.-origin content, U.S. dollar clearing and U.S.-based software or cloud services.
• Confirming end use and end user information for goods, technology and services.
• Including sanctions representations, audit rights, information covenants and suspension rights in relevant contracts.
• Preserving records of screening, ownership analysis, approvals and any decision to decline or block activity.

U.S. tax rules for controlled foreign corporations (CFCs) can affect U.S. shareholders of foreign subsidiaries and, in some structures, the tax planning, reporting and cash-management decisions of multinational groups. CFC analysis is highly fact dependent: ownership attribution, voting rights, value, entity classification, related-party arrangements, tested income, Subpart F income and global intangible low-taxed income (GILTI) considerations can all matter.

For Turkish groups with U.S. investors, U.S. subsidiaries, U.S. founders or U.S. tax-resident shareholders, the legal entity chart should be reviewed alongside the tax reporting calendar. A corporate structure that appears commercially straightforward may create unexpected reporting or inclusion consequences when ownership changes, financing is introduced, intellectual property is licensed, or cash is moved among related entities.

A practical CFC review should begin with a current ownership chart that identifies direct and indirect owners, voting and value rights, tax residency and related-party relationships. The group should then reconcile that chart with board approvals, shareholder agreements, capitalization records, intercompany agreements and prior tax filings.

Management should also establish a process for flagging events that can change the analysis, including acquisitions, redemptions, option exercises, reorganizations, debt restructurings, changes in entity classification, new intercompany service arrangements and transfers of intellectual property. Early coordination among legal, finance and tax teams is usually less costly than correcting a reporting position after year-end.

Federal Trade Commission activity continues to underscore that consumer-facing claims, digital practices and competition-sensitive conduct should be reviewed together. Marketing statements about price, origin, performance, subscriptions, cancellation, artificial intelligence or data use can create exposure when they are not supported, clearly disclosed or implemented consistently with the customer experience.

For companies entering the U.S. market, the compliance task is not limited to reviewing a website at launch. Claims made through distributors, marketplaces, influencers, sales teams, mobile applications and customer-support scripts should be governed by the same approval process. Product teams should also assess whether data collection, consent flows, retention practices and vendor arrangements match the representations made to users.

A useful readiness review can cover the following areas:

• Substantiation for objective advertising and product-performance claims.
• Clear pricing, renewal, cancellation and refund disclosures.
• Consistency between privacy notices, consent mechanisms and actual data practices.
• Controls over reseller, affiliate and influencer communications.
• Competition-law review of distribution restrictions, pricing communications and competitor information exchanges.

DHS-related compliance issues can arise through customs, immigration, forced-labor, cybersecurity and supply-chain channels. The appropriate response depends on the business model, but a common theme is the need for operational evidence. Policies alone are not enough if the company cannot show how it identifies risk, trains personnel, investigates red flags and documents corrective action.

Importers and companies sourcing internationally should maintain supplier due diligence that is proportionate to the product, country, industry and known risk indicators. Employers should ensure that hiring, work authorization and recordkeeping processes are current. Businesses handling sensitive systems or data should understand their vendor dependencies and incident-response responsibilities.

For companies with U.S. operations or U.S.-linked transactions, the following actions can help convert regulatory developments into a manageable compliance program:

1. Update sanctions screening and escalation protocols for Iran- and Syria-related risk indicators.
2. Refresh ownership charts and identify whether CFC analysis or U.S. international tax reporting may be implicated.
3. Audit high-visibility consumer claims, subscription flows, privacy notices and third-party marketing channels.
4. Map DHS-facing risks across imports, suppliers, workforce processes and critical vendors.
5. Assign owners, deadlines and evidence requirements for remediation items, then report progress to management or the board.

This publication is provided for general information only and does not constitute legal or tax advice. Sanctions, tax, consumer-protection and DHS-related obligations are fact specific; businesses should obtain advice tailored to the relevant transaction, ownership structure and operating footprint.