CAATSA Sanctions

CAATSA (Countering America’s Adversaries Through Sanctions Act), translated into Turkish as "Amerika'nın Hasımlarıyla Yaptırımlar Yoluyla Mücadele Etme Yasası", is a comprehensive sanctions law adopted by the US Congress in 2017. The law consolidates economic, financial, diplomatic, and defense-related sanctions against Russia, Iran, and North Korea under a single legal framework, establishing a permanent legal basis for US sanctions policy against these countries. Enacted on 2 August 2017 by then US President Donald Trump, CAATSA not only targets these three countries but also authorizes sanctions against third countries, companies, and individuals engaging in "significant transactions" with their defense, intelligence, and energy sectors.

With the adoption of CAATSA, the scope of US sanctions was expanded, and the President’s authority to unilaterally lift or ease sanctions was significantly restricted. This strengthened Congress’s oversight role over sanction decisions, aiming to ensure tighter legislative control over economic sanctions as a tool of US foreign policy.

The law has had major implications in international relations, particularly due to provisions targeting third countries doing business with Russia’s defense and intelligence sectors. Following Türkiye’s purchase of the S-400 air defense system from Russia, sanctions imposed on Ankara made CAATSA one of the most widely debated American sanction mechanisms globally.

The process leading to CAATSA’s enactment stems from geopolitical tensions between the US and Russia that began in 2014. Following Russia’s annexation of Crimea in March 2014 and its support for separatist groups in eastern Ukraine, the Obama administration initiated economic sanctions targeting numerous Russian companies and government officials in the finance, energy, and defense sectors through presidential executive orders.

By 2016, allegations that Russia had interfered in the US presidential election through cyberattacks and disinformation campaigns sparked a new political debate in Washington. US intelligence agencies concluded in their reports that Russia had sought to influence the electoral process, prompting members of Congress to advocate for making sanctions against Russia more durable and legally binding.

During this period, not only Russia but also Iran’s ballistic missile program, nuclear activities, and support for regional armed groups, as well as North Korea’s accelerating nuclear weapons and intercontinental ballistic missile programs, became top priorities in US national security policy. Congress aimed to consolidate sanctions against these three countries under a single law to strengthen the sanction regimes and make it more difficult for future Presidents to unilaterally lift them.

The CAATSA bill was passed with broad support in both the House of Representatives and the Senate. Despite some reservations expressed by President Donald Trump, it was signed into law on 2 August 2017 in accordance with constitutional procedures.

CAATSA is a congressional statute containing comprehensive provisions governing the imposition of sanctions under the US federal legal system. The law consists of three main sections, each regulating sanction mechanisms targeting a specific country.

First Section covers sanctions against Iran. It includes provisions targeting Iran’s ballistic missile activities, operations of the Islamic Revolutionary Guard Corps, individuals and entities alleged to support terrorist organizations, and actors involved in human rights violations.

Second Section regulates sanctions against the Russian Federation. This section details economic measures targeting individuals and institutions linked to Russia’s defense industry, energy sector, financial institutions, cyber activities, and allegations of election interference.

Third Section outlines sanctions against North Korea related to its nuclear weapons program, missile tests, human rights violations, and illicit financing activities.

One of CAATSA’s most notable features is its ability to impose sanctions not only on the target countries but also on third parties engaging in "significant transactions" with specified sectors of these countries. As a result, the law has evolved into a global sanction mechanism affecting not only the directly targeted states but also other nations and companies doing business with their defense and intelligence sectors.

The primary objective of CAATSA is to limit the economic and military capacity of states deemed by the US to pose a threat to national security, restrict their maneuverability within the international system, and deter allied countries from engaging in strategic cooperation with them.

Under the law, the following goals are particularly emphasized:

• Reducing Russia’s defense industry revenues,
• Limiting Iran’s missile program and regional military activities,
• Blocking funding for North Korea’s nuclear weapons development,
• Placing US sanctions policy under congressional oversight,
• Preventing US allies from acquiring Russian defense systems,
• Reducing security risks arising from the potential integration of adversary systems with US defense technologies.

In this regard, CAATSA is not merely an economic sanctions law but is also regarded as a key instrument of US global defense and security strategy.

CAATSA was specifically designed to target three countries:

Russia is the country subject to the broadest sanctions provisions under the law. Entities in the defense industry, intelligence agencies, energy companies, financial institutions, and government officials may be sanctioned. Third countries engaging in significant commercial transactions with Russia’s defense industry also face sanction risks.

Sanctions against Iran are justified on grounds of its ballistic missile program, activities of the Islamic Revolutionary Guard Corps, nuclear pursuits, and alleged support for groups designated by the US as terrorist organizations. Individuals and companies doing business with Iran in specific sectors may also face secondary sanctions.

Provisions targeting North Korea focus on its nuclear weapons development, intercontinental ballistic missile program, human rights violations, and illicit financing networks. The law enables sanctions against companies trading with North Korea and financial institutions facilitating these activities.

One of the most frequently applied provisions of CAATSA internationally is Section 231. This section mandates sanctions against foreign individuals, companies, and state institutions engaging in "significant transactions" with Russia’s defense and intelligence sectors.

Under this provision, the US President is required to assess significant defense agreements between Russia’s Ministry of Defense, Russian state defense companies, or Russian intelligence agencies and foreign entities. If such a transaction is determined to fall within the scope of the law, the President must apply at least five of the sanction options listed in CAATSA.

The term "significant transaction" is not defined by a specific monetary threshold in the law. Instead, factors such as the economic scale, strategic nature, impact on defense capabilities, and potential consequences for US national security interests are considered. Consequently, each transaction is evaluated on a case-by-case basis.

Türkiye’s purchase of the S-400 air defense system from Russia was evaluated by the US administration under Section 231 of CAATSA, leading to sanctions imposed on the Presidency of Defense Industries in December 2020.

The foundation of CAATSA sanctions against Türkiye lies in Ankara’s decision to procure the S-400 Triumf air defense system from Russia. This decision emerged as the culmination of Türkiye’s long-standing efforts to strengthen its national air defense capabilities.

Since the 1990s, Türkiye has prioritized acquiring long-range air and missile defense systems in its defense planning. Events such as the Gulf War, ballistic missile threats from Iraq, the Syrian civil war, and the growing missile capabilities in the region highlighted Türkiye’s urgent need in this domain. Although NATO-deployed Patriot systems provided temporary contributions to Türkiye’s air defense, Ankara aimed to acquire a system integrated into its own inventory for the long term.

In this context, the US Patriot, European SAMP/T, Russian S-400, and Chinese HQ-9 systems were evaluated. Türkiye sought not only to purchase ready-made systems but also to establish a model involving technology transfer, joint production, and contributions to its domestic defense industry.

After prolonged negotiations, Türkiye and Russia signed an agreement in September 2017 for the purchase of the S-400 air defense system worth approximately $2.5 billion. The deal attracted widespread international attention as it marked the first time a NATO member purchased a Russian-made advanced strategic air defense system.

The first components of the S-400 systems arrived at Mürted Air Base near Ankara in July 2019, marking the beginning of the most critical phase of the defense crisis between Türkiye and the US.

The US administration opposed Türkiye’s decision to purchase the S-400 from the outset. Washington’s primary concern was that Russian-made systems are technically incompatible with NATO’s integrated defense infrastructure and could compromise alliance security.

US officials argued that the simultaneous deployment of S-400 systems alongside F-35 fighter jets could enable Russia to collect sensitive data on the aircraft’s radar signature. According to Washington, Russian radar systems analyzing the F-35’s flight characteristics could undermine the aircraft’s low-observable (stealth) technology, creating an intelligence risk.

The US also asserted that NATO member states’ defense infrastructures are largely based on Western technologies and warned that integrating Russian strategic systems could negatively affect the alliance’s collective defense planning.

Türkiye rejected these claims, stating that the S-400 systems would not be integrated into NATO networks and would operate independently without posing any security risks. Ankara also emphasized that it had been compelled to seek alternatives due to the US’s failure to supply Patriot systems under acceptable conditions for many years.

Following the commencement of S-400 deliveries, the US administration began evaluating various sanction options against Türkiye. After approximately 18 months of diplomatic engagement, the US Department of the Treasury announced on 14 December 2020 that CAATSA sanctions would be applied to Türkiye.

The legal basis for these sanctions was Section 231 of CAATSA, which authorizes sanctions against individuals and entities engaging in "significant transactions" with Russia’s defense sector.

The US administration concluded that Türkiye’s agreement with Rosoboronexport, Russia’s state defense export company, for the S-400 system fell within the scope of this provision.

Thus, Türkiye became the first NATO member, apart from India, to be sanctioned under CAATSA due to its acquisition of Russian defense systems.

The US clarified that the sanctions were directed not at the Turkish state but specifically at the Presidency of Defense Industries; however, the decision was widely viewed as the beginning of a long-term trust crisis in bilateral relations.

The sanctions announced by the US Department of the Treasury directly targeted the Presidency of Defense Industries. As a result, SSB was barred from obtaining US export licenses, and American companies were prohibited from engaging in new defense industry exports to the agency.

Under these sanctions:

• New licenses for the export of US defense technology and equipment to SSB were suspended.
• US financial institutions and international financial organizations were restricted from providing credit to SSB.
• American companies faced significant difficulties in pursuing new defense projects with the agency.
• Access to US Export-Import Bank credits and other financing opportunities was blocked.

Although these sanctions did not directly target the Turkish Armed Forces, they created challenges in acquiring US-origin subsystems and technologies essential for defense industry projects.

Under CAATSA, sanctions were not limited to institutions but also applied to certain senior officials.

The US Department of the Treasury imposed sanctions on:

• President of the Presidency of Defense Industries İsmail Demir,
• Deputy President Mustafa Alper Deniz,
• Director of the Air and Missile Defense Department Serhat Gençoğlu,
• Director of the Regional Air Defense Systems Program Faruk Yiğit.

As a result, any potential assets these individuals held in the US were frozen, financial transactions between them and US citizens were prohibited, and their entry into the US was restricted. It was also indicated that American companies doing business with these sanctioned individuals could face additional legal penalties.

Türkiye assessed the sanctions decision as contrary to international law and the spirit of alliance. Ankara maintained that the S-400 system was acquired solely to meet national security needs, would not be integrated into any NATO system, and that sovereign states have the right to procure defense systems from any country of their choice to fulfill their defense requirements.

In statements by the Ministry of Foreign Affairs, the US decision was declared incorrect, and Washington was urged to reverse its stance. Türkiye also stated that the sanctions harmed strategic cooperation between the two countries and were incompatible with NATO solidarity.

Ankara emphasized that the issue could be resolved through dialogue and technical consultations rather than sanctions and at various times proposed that a joint technical commission examine the impact of the S-400 systems on NATO infrastructure. However, the US administration did not respond favorably to this proposal, and CAATSA sanctions remained in effect.

The imposition of sanctions marked the beginning of a new phase in Türkiye-US defense relations. Several joint defense industry projects between the two countries slowed down, technology transfer processes became more difficult, and trust issues became more visible.

At the same time, Türkiye accelerated its efforts toward localization in the defense industry, announcing increased investment in domestic projects in areas such as engines, electronic systems, missile technologies, and air defense. Reducing dependence on foreign suppliers became a more prominent strategic priority for Türkiye following the sanctions.

Türkiye’s purchase of the S-400 air defense system from Russia not only triggered CAATSA sanctions but also directly affected its position in the F-35 Joint Strike Fighter Program, where it had been a long-standing partner and investor. Türkiye joined the program in 1999 and subsequently participated in its production process, contributing financially and producing various components of the aircraft through Turkish defense industry companies. Under the program, Turkish companies manufactured fuselage parts, landing gear components, cockpit displays, composite structures, and various subsystems, with Türkiye’s total contribution estimated at approximately $1.4 billion.

The US administration argued that the co-location of S-400 systems with F-35 aircraft in Türkiye posed a security risk and initially suspended Türkiye’s participation in the program. In July 2019, it officially announced Türkiye’s removal from the F-35 program. As a result, F-35 fighter jets scheduled for delivery to Türkiye were withheld, Turkish pilots’ training activities in the US were terminated, and Turkish defense industry companies’ roles in the production chain were gradually transferred to other countries.

Türkiye contended that its removal from the F-35 program was legally and contractually unjustified, asserting that it had fulfilled its obligations as a partner country that contributed financially to the program. Ankara maintained that the S-400 procurement should not nullify Türkiye’s rights as a program partner and has engaged in discussions with the US on multiple occasions regarding the undelivered aircraft and financial contributions to the program.

Although CAATSA sanctions directly targeted the Presidency of Defense Industries, they also created indirect effects across many areas of the defense industry. Due to the requirement for export licenses for US-origin technologies and subsystems, supply chains for certain projects were delayed, accelerating efforts to identify alternative suppliers.

Constraints on the use of US-origin products in defense projects—particularly in engine technologies, avionics, electronic warfare equipment, optical components, and various critical subsystems—spurred accelerated efforts toward domestic production. During this period, Türkiye prioritized increasing the localization rate in its defense industry and launched new projects in areas such as engine development, radar systems, air defense technologies, electronic components, and ammunition production.

As Turkish defense industry companies sought to establish alternative supply chains, partnerships were developed with manufacturers in Europe and Asia, and investments in the development of national systems were increased. Policies aimed at reducing dependence on foreign suppliers became more visible after the CAATSA sanctions.

Following its removal from the F-35 program, Türkiye turned to modernizing its F-16 fleet to maintain the effectiveness of its existing fighter aircraft inventory. In October 2021, Ankara formally applied to the US to purchase 40 new F-16 Block 70 fighter jets and 79 modernization kits for its existing fleet.

The application became a subject of prolonged debate in the US Congress, particularly in connection with Türkiye’s foreign policy and Sweden’s NATO accession process. After approximately two years of negotiations, objections in Congress largely subsided following Türkiye’s approval of Sweden’s NATO membership, and in 2024 the US administration approved the sale.

The F-16 procurement process was viewed as a significant development in rebuilding defense relations between the two countries, demonstrating that cooperation in the defense sector had not been entirely terminated.

Türkiye’s fifth-generation national fighter aircraft, the KAAN project, emerged as one of the most important initiatives in the defense industry following CAATSA. Developed by Turkish Aerospace Industries (TUSAŞ), the first prototype of KAAN completed its maiden flight in 2024 and has become a cornerstone of Türkiye’s long-term air force modernization plan.

The initial production blocks of KAAN are planned to use US-made General Electric F110 engines. Consequently, engine procurement remains a critical issue in Türkiye-US defense relations.

In 2026, the US administration issued a formal notification to Congress indicating its intent to sell approximately $700 million worth of F110 fighter jet engines and related equipment to Türkiye, sparking assessments that a new chapter in defense cooperation between the two countries may be beginning. It was noted that the sale could proceed if Congress does not object within a specified period.

Despite CAATSA sanctions, Türkiye-US defense relations have not been fully severed. As NATO allies, the two countries have continued cooperation on numerous issues, including Black Sea security, counterterrorism, energy security, the war in Ukraine, and developments in the Middle East.

Since 2023 and 2024, high-level diplomatic engagement between the two sides has intensified. Discussions between defense ministries and foreign affairs institutions have addressed the F-16 process, defense industry cooperation, NATO coordination, and regional security matters.

In 2025 and 2026, particularly following the potential return of Donald Trump to the US presidency, assessments emerged that a more pragmatic approach toward Türkiye might be adopted. The progress of the F-16 sale, positive developments regarding F110 engines, and sustained high-level diplomatic contacts have created a foundation for renewed discussions on the future of CAATSA sanctions.

As of 2026, efforts toward normalization in defense industry relations between Türkiye and the US have become more prominent. Although CAATSA sanctions imposed after Türkiye’s acquisition of the S-400 air defense system remain in effect, the intensification of diplomatic contacts and initiatives to rebuild defense cooperation have reignited discussions on the future of these sanctions.

During this period, cooperation within the NATO framework, Black Sea security, the war in Ukraine, developments in the Middle East, and Türkiye’s role in regional security policies have served as key pillars sustaining strategic dialogue between Washington and Ankara. Although occasional disagreements persist, the fact that defense-related contacts have not been fully severed has strengthened assessments that relations can be restructured.

The progress of Türkiye’s procurement of F-16 Block 70 fighter jets and modernization kits, followed by the US administration’s notification of intent to sell F110 fighter jet engines, has been viewed as developments signaling the reinvigoration of defense dialogue between the two countries.

In July 2026, Foreign Minister Hakan Fidan stated that diplomatic efforts to lift CAATSA sanctions were ongoing. Fidan indicated that Türkiye and the US had entered a more constructive phase in defense industry cooperation and that necessary diplomatic and technical steps were being taken toward the removal of sanctions.

Fidan emphasized that CAATSA sanctions had negatively affected not only defense industry cooperation but also the strategic partnership between two NATO allies, highlighting the importance of closer cooperation between the two countries in the current international security environment.

In his remarks, Fidan specifically pointed to recent positive developments in the defense sector, noting that efforts to rebuild a climate of trust between the two sides were continuing. Reiterating Türkiye’s longstanding position, he affirmed that CAATSA sanctions were incompatible with the spirit of alliance and stated that the current issues could be resolved through dialogue.

Following Donald Trump’s return to the US presidency, assessments emerged that the Washington administration might adopt a more pragmatic approach toward Türkiye’s defense relations. Trump previously indicated that problems in the sale of Patriot systems during the Obama administration had contributed to the emergence of the S-400 crisis and argued that Türkiye’s circumstances should be taken into account.

In 2026, the US administration’s formal notification to Congress regarding the sale of F110 fighter jet engines to Türkiye strengthened assessments that a new chapter in defense relations between the two countries may be opening. In addition, the progress of the F-16 procurement process and the continuation of high-level contacts have increased expectations that the sanctions may be reconsidered.

However, since CAATSA is a congressional law, the process of lifting sanctions is not solely dependent on the President’s political will. Within the US legal framework, Congress’s role and legal procedures remain decisive in modifying or removing sanctions.

CAATSA is not a presidential executive order but a federal law enacted by the US Congress. Therefore, lifting or modifying the sanctions requires a more complex legal process compared to other sanction programs.

Under the law, the President may delay certain sanctions or grant exemptions under specific circumstances, but complete removal of sanctions requires Congress’s involvement. In particular, the President’s authority to unilaterally lift or significantly ease sanctions against Russia is limited.

Therefore, the removal of CAATSA sanctions against Türkiye depends not only on positive developments in bilateral relations but also on the balance of power in US domestic politics, Congress’s stance, and the broader US sanctions policy toward Russia.

As of 2026, a more positive atmosphere has emerged in Türkiye-US relations compared to previous years. The progress of the F-16 sale, initiatives regarding F110 engine sales, continued cooperation within NATO, and intensifying high-level diplomatic contacts demonstrate both sides’ willingness to resolve defense-related issues through dialogue.

Foreign Minister Hakan Fidan’s statements indicating that necessary steps are being taken toward lifting sanctions further signal that the process is advancing on a diplomatic level. However, since CAATSA is a federal law and its legal foundation was established by Congress, a swift conclusion to the process is not expected in the short term.

On the other hand, Türkiye’s unchanged position regarding the S-400 systems means that the fundamental justification for the sanctions remains in place. Therefore, the complete removal of sanctions will depend on the overall trajectory of Türkiye-US relations, the US sanctions policy toward Russia, Congress’s approach, and the possibility of new defense-related agreements between the two countries.

Current diplomatic developments indicate a strengthened resolve toward normalizing relations. However, the complete lifting of CAATSA sanctions is viewed as a multi-stage process requiring not only political statements but also a coordinated assessment of US domestic legal mechanisms and foreign policy priorities.