Iranian gas-for-gold scheme and the Halkbank prosecution (2012-2026)

The Iranian gas-for-gold scheme converted Iranian petroleum revenue held in Turkish lira into gold and, later, allegedly disguised trade flows. The subsequent prosecution of traders, a Halkbank executive and Halkbank itself made the episode one of the best documented sanctions-evasion cases. It also produced a long-running dispute over whether and when a foreign state-owned corporation may claim immunity from United States criminal process.

Sanctions design and transaction chain

Section 1245 of the United States National Defense Authorization Act for Fiscal Year 2012 pressured foreign financial institutions to reduce petroleum transactions with Iran. Iran's receipts accumulated in restricted local-currency accounts that could be used for permitted bilateral trade. Turkish purchases of Iranian gas therefore created lira balances at Halkbank.

Gold provided one route out. Traders used Iranian funds to purchase precious metal in Turkey and move value through Turkey and the United Arab Emirates. The legal treatment changed over time. The Iran Threat Reduction and Syria Human Rights Act of 2012 narrowed access to precious metals, with operative dates and exceptions that must be applied to the conduct alleged in each period.

United States prosecutors alleged that Reza Zarrab's network later disguised transfers as humanitarian food trade and routed transactions through the United States financial system. Zarrab pleaded guilty in 2017 and testified for the prosecution. Mehmet Hakan Atilla, a Halkbank deputy general manager, was convicted in January 2018. Those adjudicated outcomes do not establish every allegation later made against the bank or untried Turkish officials.

Halkbank proceedings

The United States indicted Halkbank in October 2019 for fraud, money laundering and sanctions offences. The bank argued that the Foreign Sovereign Immunities Act barred the prosecution. In 2023, the United States Supreme Court held that the Act does not provide immunity in criminal proceedings and returned the common-law question to the lower courts.

On 22 October 2024, the Court of Appeals for the Second Circuit rejected Halkbank's claim to common-law immunity. The Supreme Court denied the bank's petition for certiorari on 6 October 2025.

The institutional case then ended without a trial. Halkbank and the United States entered a deferred-prosecution agreement in March 2026. An independent compliance review was completed in May. The government moved for a nolle prosequi, and the district court dismissed the indictment with prejudice on 17 June 2026. Halkbank admitted no criminal wrongdoing and paid no criminal or administrative penalty under the agreement. The dismissal resolved the prosecution; it did not adjudicate the indictment's allegations in the government's favour.

Assessment

This is a main-sequence case because both sides used access to financial and commodity networks for strategic ends. United States restrictions sought to constrain Iranian petroleum revenue. The Iranian and Turkish-linked transaction chain sought to preserve access through local currency, gold and trade documentation.

The case demonstrates adaptation to rule design. A restriction on dollar clearing shifted activity into local currency. Restrictions on precious metals shifted alleged conduct into trade-based laundering. Enforcement then used the return of transactions to New York, documentary evidence and individual cooperation to reconstruct the network. The result is not proof that all intermediary jurisdictions will comply. It is evidence that layered evasion creates new records, participants and legal exposures.

See also

Iranian sanctions-evasion networks (2012-present) · Trade-based money laundering · Third-country intermediary routing · Sanctions-busting · Financial intelligence (FININT)

Sources

1. United States Department of Justice, 'Turkish Bank Charged in Manhattan Federal Court for Its Participation in a Multibillion-Dollar Iranian Sanctions Evasion Scheme', 15 October 2019.
2. Supreme Court of the United States, '*Turkiye Halk Bankasi A.S. v United States*, 598 U.S. 264', 19 April 2023.
3. United States Court of Appeals for the Second Circuit, '*United States v Turkiye Halk Bankasi A.S.*, 23-808', 22 October 2024.
4. Supreme Court of the United States, 'Docket 24-1144', certiorari denied 6 October 2025.
5. United States Department of Justice, 'Turkish Banker Convicted of Conspiring to Evade U.S. Sanctions Against Iran', 3 January 2018.
6. United States Department of Justice, 'Turkish National Arrested for Conspiring to Evade U.S. Sanctions Against Iran, Money Laundering and Bank Fraud', 21 March 2016.
7. United States Congress, 'National Defense Authorization Act for Fiscal Year 2012', section 1245.
8. United States Congress, 'Iran Threat Reduction and Syria Human Rights Act of 2012', section 504.
9. Richard Nephew, The Art of Sanctions (Columbia University Press, 2018).
10. United States District Court for the Southern District of New York, government declaration supporting nolle prosequi in *United States v Turkiye Halk Bankasi A.S.*, filed 17 June 2026.
11. Luc Cohen and Canan Sevgili, 'Judge formally ends US prosecution of Turkey's Halkbank after Trump deal', Reuters, 17 June 2026.