The US Department of Justice has moved to dismiss its criminal case against Türkiye Halk Bankası, better known as Halkbank, after reaching a deferred prosecution agreement that requires zero financial penalties from the Turkish state-owned bank. The case, which alleged Halkbank helped Iran dodge US sanctions by funneling roughly $20 billion through a web of front companies, had been grinding through courts since 2019.
From indictment to handshake
Halkbank was indicted in October 2019 for an alleged scheme involving the movement of approximately $20 billion in Iranian funds through a network of front companies. The scale alone made it one of the largest sanctions-evasion cases the DOJ had ever pursued.
The bank fought hard to kill the case before it ever reached trial. Halkbank argued that as a sovereign-owned entity, it enjoyed immunity from US criminal prosecution. That argument made it all the way to the Supreme Court, which ruled in April 2023 that sovereign immunity does not shield state-owned entities from criminal prosecution. The Second Circuit followed up in October 2024 by rejecting common-law immunity claims, clearing the path for the case to proceed.
The DPA does require Halkbank to employ an independent compliance monitor to oversee its adherence to US sanctions and anti-money laundering rules. After a 90-day compliance review period, the charges get dismissed entirely.
