Stock Markets March 9, 2026

Halkbank Enters Deferred Prosecution Deal with U.S. Justice Department, Judge Says

Agreement follows long-running U.S. criminal prosecution accusing the Turkish state bank of aiding Iran to evade sanctions

By Leila Farooq
Halkbank Enters Deferred Prosecution Deal with U.S. Justice Department, Judge Says

A U.S. judge disclosed that Turkish state-owned Halkbank and the U.S. Department of Justice have reached a deferred prosecution agreement in a protracted criminal case alleging the bank helped Iran skirt American economic sanctions. The filing provided no additional details about the terms of the agreement. The prosecution, dating to 2019, includes charges of bank fraud, money laundering and conspiracy linked to alleged transfers of Iranian oil proceeds and the use of front companies and money handlers in multiple countries.

Key Points

  • Halkbank and the U.S. Department of Justice have reached a deferred prosecution agreement, announced in a court filing that gave no further terms.
  • The 2019 indictment accuses the bank of bank fraud, money laundering and conspiracy tied to alleged efforts to help Iran evade U.S. economic sanctions, including transferring restricted funds and converting oil revenue into gold and cash.
  • This prosecution has moved through multiple levels of the U.S. judiciary, including district court, the 2nd U.S. Circuit Court of Appeals, and the U.S. Supreme Court, with pivotal rulings in 2020, 2021, 2023, October 2024 and a decision left standing in October 2025.

A federal judge in New York said on Monday that Halkbank, the Turkish state-controlled lender, and the U.S. Department of Justice have reached a deferred prosecution agreement in the long-running criminal case against the bank. The court filing announced the deal but did not disclose its terms or any other specifics.

Prosecutors originally accused Halkbank of fraud, money laundering and conspiracy, alleging the bank assisted Iran in evading U.S. economic sanctions. The indictment claims the bank moved restricted funds, converted oil revenue into gold and cash for Iranian interests, and fabricated food shipments to justify transfers of oil proceeds. U.S. authorities contend the alleged scheme used money services and front companies operating in Iran, Turkey and the United Arab Emirates.

Halkbank has consistently pleaded not guilty to charges of bank fraud, money laundering and conspiracy. The case has also been a frequent source of diplomatic tension between Washington and Ankara. Turkish President Tayyip Erdogan has publicly criticized the prosecution, calling it an unlawful and ugly action. Erdogan previously said he discussed Halkbank with then-President Donald Trump during a White House meeting and a subsequent phone call, and that Trump told him "the Halkbank problem is finished for us." Those comments followed the 2019 indictment filed during President Trump’s first term.

The prosecution grew out of a cluster of related criminal cases focused on sanctions-evasion schemes. A prominent figure in those proceedings was Turkish-Iranian gold trader Reza Zarrab, who in 2017 pleaded guilty to bank fraud, money laundering and conspiracy charges and later testified at trial. Zarrab has not yet been sentenced. Another related defendant, former Halkbank executive Mehmet Hakan Atilla, was convicted in 2018 of bank fraud and conspiracy following testimony from Zarrab. Atilla served most of a 32-month sentence and returned to Turkey in 2019. He has denied wrongdoing.

The legal path for Halkbank’s case has been complex and has traversed several layers of the U.S. judiciary. In 2020, U.S. District Judge Richard Berman ruled that the bank did not merit immunity from prosecution. The 2nd U.S. Circuit Court of Appeals in Manhattan upheld that conclusion the next year, though it reached the result on different legal grounds, finding that the bank could be prosecuted under the Foreign Sovereign Immunities Act because the alleged misconduct involved commercial activity that falls outside the statute’s protections.

In 2023, the U.S. Supreme Court temporarily set aside the prosecution despite acknowledging that congressional protections against civil liability for foreign states and their instrumentalities do not automatically apply in criminal cases. Instead, the Court directed the 2nd Circuit to undertake a more detailed review of whether longstanding common law principles of immunity could shield the bank. The appeals court concluded in October 2024 that such common law protections did not apply, and Halkbank subsequently filed a second appeal to the Supreme Court. The agreement reported on Monday was announced after the U.S. Supreme Court in October 2025 let stand a federal appeals court decision that allowed the prosecution to proceed.

The court filing announcing the deferred prosecution agreement did not provide additional information about its provisions, including whether the deal includes fines, compliance conditions, admissions of wrongdoing, or other remedial measures. Given the limited disclosure in the filing, the precise legal and financial consequences for Halkbank remain unclear based on the information available from the court document.


Summary

The U.S. Justice Department and Halkbank have entered a deferred prosecution agreement in a long-running case alleging the bank helped Iran evade U.S. sanctions. The announcement was made in a court filing that did not include details of the deal. The prosecution, initiated by U.S. authorities in 2019, stems from allegations involving transfers of oil proceeds, use of front companies, and the conversion of restricted funds into gold and cash.

Risks

  • Uncertainty about the specific terms of the deferred prosecution agreement - financial penalties or compliance obligations have not been disclosed. This creates legal and operational uncertainty for the banking sector, especially state-owned lenders with international operations.
  • Ongoing reputational and diplomatic tensions - the case has strained U.S.-Turkey relations, and unclear outcomes could sustain diplomatic frictions affecting broader geopolitical and economic interactions between the two countries.
  • Potential for related enforcement actions - the prosecution developed from linked criminal cases involving gold trading and former bank executives, indicating continued legal exposure for parties and sectors connected to sanctions-evasion schemes, particularly finance and commodities sectors.

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