By Sinan Ciddi & Ahmad Sharawi
Thursday, April 23, 2026
With a military blockade in
place in the Strait of Hormuz, the Trump administration is pivoting
toward economic warfare against the Islamic Republic. The
Treasury Department has provided the
United Arab Emirates and Oman with a list of banks in their jurisdictions that
enable Iranian illicit activity. This early warning — extended to China and
Hong Kong — is intended to make clear that any financial support for Tehran
will trigger U.S. repercussions. The key challenge now is inconsistent
enforcement, particularly regarding Turkey.
The Turkish regulatory and commercial environment remains
a critical conduit for Tehran’s access to hard currency and for sustaining
global financial channels.
A network of Iranian-linked exchange houses operates outside the formal banking system in major
cities such as Istanbul and Ankara. These entities often allow users to
transfer funds without opening bank accounts, offering near-instant settlement
with minimal documentation — hallmarks of Iran’s shadow banking architecture.
Because Iran is barred from the global SWIFT financial messaging system, these
currency exchange houses have become highly attractive tools for evading
sanctions with limited regulatory oversight.
Washington has targeted some of these networks under
counterterrorism authorities. In 2024, the Treasury Department designated Seyyed
Mohammad Mosanna’i Najibi, an Iranian-Turkish national who managed currency
exchange businesses in both countries, as a terrorist. According to Treasury,
Najibi used these entities to circumvent U.S. sanctions — holding funds for
Iran’s Ministry of Defense in accounts outside Iran, facilitating revenue from
Iranian oil sales, and transferring money to suppliers tied to the Ministry of
Defense and the Islamic Revolutionary Guard Corps (IRGC). Israel also
sanctioned two Turkish entities in 2025 for providing and facilitating millions
of dollars to the IRGC-Quds Force.
Even more alarming is that Turkey continues to host a
U.S.-sanctioned Iranian bank, Bank Mellat, on its own soil. Bank Mellat is an
institution linked to financing the
Basij, the IRGC’s paramilitary arm. Rather than forcing its closure, Turkish
authorities treat the bank as a legitimate, supervised entity, allowing it to
remain operational despite it being sanctioned, indicating that Ankara’s
regulatory framework permits entities tied to Iran to persist despite their
violations of U.S. sanctions.
Bank Mellat’s lending largely stays in Iran, so its
branches in Turkey act as extensions of the Iranian system. The bank holds
deposits linked to its Tehran headquarters and the sanctioned Central
Bank of Iran. Its 2024 annual report states it can rely on capital support from
Iran. Turkey’s permissive environment allows Bank Mellat to operate, weakening
U.S. sanctions enforcement.
The pass that Turkey has seemingly received is worse when
one considers the Trump administration’s decision not to punish other Turkish
financial entities that have helped Iran evade U.S. sanctions, which were
supported and facilitated by the government of Turkey.
In 2019, Turkish public lender Halkbank was indicted in
the U.S. for running a brazen sanctions evasion scheme. At least two of the
bank’s employees were convicted during Trump’s first term for their involvement
in efforts to purchase illicit Iranian natural gas, paid for with gold. By
March 2026, Trump’s Justice Department decided to enter into a deferred
prosecution agreement with Halkbank — one of the largest violators of U.S.
sanctions on Iran.
According to findings by the U.S. Treasury Department and
the Justice Department, Halkbank facilitated at least $13 billion in transactions on
behalf of Iran between March 2012 and July 2013, with some estimates placing the total closer to $20 billion. A
portion of those funds is believed to have supported Tehran’s regional proxy
network.
Congressional reports suggest that, from 2012 to 2018,
Iran spent about $16 billion each year to back militant clients across the
Middle East. Treasury guidelines allow civil penalties up to twice the value of
illicit proceeds, which could expose Halkbank to fines of up to $40 billion. Separately, Kuveyt Türk Bank is now
facing litigation in the U.S. District Court for the Eastern
District of New York over allegations that it routed Hamas-linked dollar
transactions through U.S. banks.
Turkish President Recep Tayyip Erdoğan has pursued direct
policies to promote the survival of Iran’s regime. This is somewhat
understandable: There is little doubt that the Iran war is placing a severe
strain on the foundations of Turkey’s economy. Every $10 increase in global oil
prices is estimated to widen the country’s current account deficit by roughly $3 to $5.1 billion. Turkey already grapples
with one of the highest inflation rates
in the world — currently exceeding 30 percent annually — intensifying pressure
on Erdoğan’s government to rein in rising consumer prices. Additionally, Ankara
is justifiably concerned about a potential for Iranian refugee flows,
which would heighten existing levels of frustration for the Erdoğan government.
Legitimate worries aside, however, Erdoğan prefers the survival of the Tehran regime. For him, a
weakened but still Islamist regime in Tehran may be more strategically useful
than a democratic government that could realign Iran with the West.
Iran’s network of regional proxies has long shaped the
balance of power in the Middle East. As long as groups like Hezbollah in
Lebanon and Hamas in Gaza remain armed and active, Israel faces persistent
security pressure.
In this environment, a perpetually threatened Israel
creates space for Erdoğan to cast Turkey as a central diplomatic and political
actor. By inserting itself into moments of crisis, Ankara can seek to elevate
its role as a regional power broker.
Washington should intensify enforcement against
Iran-linked financial networks in Turkey. This includes targeting exchange
houses, front companies, and urging Ankara to shut down sanctioned entities,
such as Bank Mellat. The Treasury and Justice departments should be prepared to
invoke Section 311 of the Patriot Act to designate institutions like Kuveyt Türk
as primary money-laundering concerns. This would cut them off from the U.S.
financial system and send a clear signal: No bank — Turkish or otherwise — can
use American financial channels to fund Iranian terror without consequence.
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