What Happened on June 29, 2026

On June 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed seven entries from the Specially Designated Nationals and Blocked Persons List (SDN List) under the RUSSIA-EO14024 program. All seven are Turkish companies and individuals previously designated for supporting Russia’s military-industrial base through sanctions evasion. For nearly three years, this Turkish sanctions evasion network served as one of the channels for supplying Russia with machine tools and dual-use electronic components.

The removed entries are:

• Megasan Elektronik Ticaret ve Sanayi Anonim Sirketi (Istanbul)
• SSGCTM CNC Takim Tezgahlari Makine Sanayi ve Ticaret Limited Sirketi (Konya)
• Minyon Kesici Takimlar Makine Sanayi ve Ticaret Limited Sirketi (Konya)
• Hidropark Hidrolik Pnomatik San ve Tic Ltd Sti (Istanbul)
• AYTT CNC Takim Tezgahlari Makine Sanayi ve Ticaret Limited Sirketi (Konya)
• AYTT CNC Machine Tools San Trade Ltd Sti (Konya — alternate name of the preceding entity)
• Recep Cetin Aydin (individual, Konya)
• Gurhan Aydin (individual, Konya)

This marks the first instance in which OFAC has simultaneously removed an entire group of third-country subjects designated exclusively under the Russia sanctions program. Not a single Russian national appears among the delisted parties.

Who Was Listed and Why

All seven parties were added to the SDN List between December 2023 and October 2024 pursuant to Executive Order 14024. In every case, the basis for designation was operating or having operated in the manufacturing or technology sector of the Russian Federation economy, or directly supporting Russia’s military-industrial base.

Turkey emerged as one of the primary transit jurisdictions for sanctioned goods and technology entering Russia after February 2022. OFAC repeatedly warned of secondary sanctions risk for foreign companies conducting Russia-related trade in violation of applicable restrictions.

Three Waves of Designation

The parties removed today were designated in three separate sanctions packages.

December 2023. As part of a sweeping package targeting more than 150 individuals and entities across 17 jurisdictions, OFAC designated Megasan Elektronik. The company had supplied dual-use electronic components to Russia, including integrated circuits and tantalum capacitors.

August 2024. In a separate action, OFAC designated Istanbul-based Hidropark, a distributor of hydraulic and pneumatic equipment.

October 2024. In the largest of the three packages (the “Third-Country Sanctions Evaders” action targeting 275 individuals and entities), OFAC designated AYTT CNC, SSGCTM CNC, Minyon Kesici, and both individuals, Gurhan Aydin and Recep Cetin Aydin. By this point, OFAC had already identified several interlinked Turkish companies and individuals, pointing to a broader network of intermediaries used to supply Russia’s military-industrial base.

The AYTT Network: AYTT CNC, SSGCTM, and Minyon Kesici

One of the most illustrative elements of the Turkish network disclosed by OFAC in the October 2024 package was a cluster of companies bound by shared ownership and corporate ties.

AYTT CNC Takim Tezgahlari Makine Sanayi ve Ticaret Limited Sirketi is a Konya-based company trading in computer numerically controlled (CNC) machine tools. It was managed by Gurhan Aydin, who exported tool products and CNC machine tools and components to Russian entities, including U.S.-designated Tool Company Gut.

Recep Cetin Aydin co-owned AYTT CNC and simultaneously controlled two affiliated companies, SSGCTM CNC and Minyon Kesici. He was designated for operating in the manufacturing sector of the Russian Federation economy, a formulation indicating that OFAC tied his conduct directly to that sector, rather than treating it merely as assistance to a designated third party.

All three companies, located within the same district of Konya, supplied Russia with lathes and metal-cutting tools. The example illustrates how a substantial part of the Turkish intermediary network was built on a combination of ownership overlap and commercial ties concentrated within a single industrial region.

Megasan Elektronik: Semiconductors for Russia’s Defense Industry

Megasan Elektronik Ticaret ve Sanayi A.S. is an Istanbul-based distributor of discrete semiconductor components, including diodes and transistors. According to OFAC, in February 2023 the company made dozens of shipments to Russian end-users, including integrated circuits, equipment for receiving, converting, and transmitting data, and tantalum capacitors.

These items fall within the category of high-priority dual-use goods whose export to Russia is subject to heightened scrutiny by U.S. regulators – OFAC and the Bureau of Industry and Security (BIS) – as well as several other governments. This is why OFAC placed Megasan on the SDN List in December 2023, alongside other electronics suppliers from Turkey, China, and other jurisdictions.

Hidropark: Hydraulics and Machine Tools

Hidropark Hidrolik Pnomatik San. ve Tic. Ltd. Sti. is likewise an Istanbul-based company specializing in hydraulic and pneumatic equipment. In addition to its core product line, it supplied Russian counterparties with CNC machine tools and machining centers.

What Delisting Means

Removal from the SDN List is neither a rehabilitation nor an acknowledgment that the original designation was erroneous. Delisting means that OFAC has concluded that the basis for maintaining sanctions against the relevant parties no longer exists. This may reflect a change in behavior, cessation of the sanctioned activity, satisfaction of settlement conditions, or other circumstances that OFAC is not required to disclose publicly.

From the date the SDN List update is published, any transactions with the removed parties that were previously blocked solely by reason of their SDN status become permissible, provided no other sanctions basis applies. Blocked assets are subject to unblocking pursuant to applicable procedures.

It is important to note that delisting on its own does not resolve questions relating to potential violations committed while a party was on the list. If third parties transacted with the designated individuals or entities during that period without an applicable license, this can carry serious consequences. The Turkish sanctions evasion network is a further reminder that delisting opens new possibilities for future transactions, but it does not close the book on the prior designated period.

Practical Takeaways

Today’s delisting is notable for several reasons. First, all seven removed parties are Turkish nationals or legal entities, making this a rare instance of a group exit of third-country subjects designated solely under the Russia sanctions program with no Russian national among those removed.

Second, the delisting spans companies from three distinct designation waves in 2023 and 2024, which suggests a systematic OFAC review of the continued justification for the restrictions, rather than a response to any single petition.

Third, the removal of the two individuals (Gurhan Aydin and Recep Cetin Aydin) together with their affiliated companies once again shows that OFAC is willing to lift sanctions against specific persons when the circumstances underlying the designation have changed.

For individuals and organizations currently on the SDN List on similar grounds (participation in the supply of dual-use goods to Russia through third countries), today’s action confirms that delisting in 2026 is not only possible but actively used by OFAC where the relevant conditions are met. It nonetheless requires sustained legal work, documentary evidence of changed conduct, and a well-structured approach to engaging with OFAC.