Risk Level:
99% May harm your business future; Persons or entities that engage in transactions with this entity will be exposed to sanctions or subject to an enforcement action;

Working with this entity means supporting Iranian Regime, Regime Terrorist Activities & development of WMD

Top Alert – Entity designated / sanctioned for terror, WMD and human rights violation

Allegedly laundered $20 billion of Iranian oil and gas revenue from 2012 to 2016 in violation of U.S. sanctions on Iran;

From approximately 2012, up to and including approximately 2016, TÜRKİYE HALK BANKASI A.S. (“Halkbank”) was a foreign financial institution organized under the laws of and headquartered in Turkey. The majority of Halkbank’s shares are owned by the Government of Turkey. Halkbank and its officers, agents, and co-conspirators directly and indirectly used money service businesses and front companies in Iran, Turkey, the United Arab Emirates, and elsewhere to violate and to evade and avoid prohibitions against Iran’s access to the U.S. financial system, restrictions on the use of proceeds of Iranian oil and gas sales, and restrictions on the supply of gold to the Government of Iran and to Iranian entities and persons. Halkbank knowingly facilitated the scheme, participated in the design of fraudulent transactions intended to deceive U.S. regulators and foreign banks, and lied to U.S. regulators about Halkbank’s involvement;

High-ranking government officials in Iran and Turkey participated in and protected this scheme. Some officials received bribes worth tens of millions of dollars paid from the proceeds of the scheme so that they would promote the scheme, protect the participants, and help to shield the scheme from the scrutiny of U.S. regulators;

The proceeds of Iran’s sale of oil and gas to Turkey’s national oil company and gas company, among others, were deposited at Halkbank, in accounts in the names of the Central Bank of Iran, the National Iranian Oil Company (“NIOC”), and the National Iranian Gas Company. During the relevant time period, Halkbank was the sole repository of proceeds from the sale of Iranian oil by NIOC to Turkey. Because of U.S. sanctions against Iran and the anti-money laundering policies of U.S. banks, it was difficult for Iran to access these funds in order to transfer them back to Iran or to use them for international financial transfers for the benefit of Iranian government agencies and banks. As of in or about 2012, billions of dollars’ worth of funds had accumulated in NIOC and the Central Bank of Iran’s accounts at Halkbank;

Halkbank participated in several types of illicit transactions for the benefit of Iran that, if discovered, would have exposed the bank to sanctions under U.S. law, including (i) allowing the proceeds of sales of Iranian oil and gas deposited at Halkbank to be used to buy gold for the benefit of the Government of Iran; (ii) allowing the proceeds of sales of Iranian oil and gas deposited at Halkbank to be used to buy gold that was not exported to Iran, in violation of the so-called “bilateral trade” rule; and (iii) facilitating transactions fraudulently designed to appear to be purchases of food and medicine by Iranian customers, in order to appear to fall within the so-called “humanitarian exception” to certain sanctions against the Government of Iran, when in fact no purchases of food or medicine actually occurred. Through these methods, Halkbank illicitly transferred approximately $20 billion worth of otherwise restricted Iranian funds;

Senior Halkbank officers, acting within the scope of their employment and for the benefit of Halkbank, concealed the true nature of these transactions from officials with the U.S. Department of the Treasury so that Halkbank could supply billions of dollars’ worth of services to the Government of Iran without risking being sanctioned by the United States and losing its ability to hold correspondent accounts with U.S. financial institutions;

The purpose and effect of the scheme in which Halkbank participated was to create a pool of Iranian oil funds in Turkey and the United Arab Emirates held in the names of front companies, which concealed the funds’ Iranian nexus. From there, the funds were used to make international payments on behalf of the Government of Iran and Iranian banks, including transfers in U.S. dollars that passed through the U.S. financial system in violation of U.S. sanctions laws;

Halkbank is charged with (1) conspiracy to defraud the United States, (2) conspiracy to violate the International Emergency Economic Powers Act (“IEEPA”), (3) bank fraud, (4) conspiracy to commit bank fraud, (5) money laundering, and (6) conspiracy to commit money laundering;

Conspired with Iranian-Turkish businessman Reza Zarrab, who ran a network of front companies in Turkey and the United Arab Emirates and held a contract with Iran’s Sarmayeh Exchange; Zarrab accessed Iranian assets at Halkbank, including accounts held by the Central Bank of Iran, the National Iranian Oil Company (NIOC), and the National Iranian Gas Company;

Naftiran Intertrade Company also held funds in an account at Halkbank;

Senior bank officers participated in the scheme and concealed it from U.S. Treasury officials, including general manager Suleyman Aslan, deputy general manager Mehmet Hakan Atilla, Levent Balkan, and general manager Ali Fuat Taskesenlioglu; high ranking Iranian and Turkish officials were also involved in the scheme, including Turkish Minister of Economic Affairs Mehmet Zafer Caglayan, who took over $70 million in bribes, and then-Prime Minister Recep Tayyip Erdogan; U.S. authorities arrested Zarrab in March 2016 and Atilla in March 2017, charging them along with Caglayan, Aslan, Balkan, Abdullah Happani, Camelia Jamshidy, Mohammad Zarrab, and Hossein Najafzadeh, who remain at large; Zarrab pleaded guilty in October 2017 and testified against Atilla, who was found guilty in May 2018 and sentenced to 32 months in prison, and following his release was appointed to lead Turkey’s stock exchange;

Iranian banks involved in facilitating the scheme included Credit Institution for Development, Eghtesad Novin Bank, Bank Keshavarsi, Bank Parsian, Bank Pasargad, Bank Saman, and Bank Sarmayeh (including its front company, Toseh Tejarat); companies that carried out the scheme included Royal Holding, Royal Denizcilik ve Endustriyei Madenler, Safir Altin Ticaret Ithalat Ihracat, Volgam Gida, Mars Kiymetli Madenler ve Gida, Centrica General Trading, Atlantis Capital General Trading, Durak Doviz, and Tasbasi Doviz ve Kiymetli Madenler Ticaret;

Also Known As:
People’s Bank

Banking Sector






Person of interests:
Myrat Arabow
Memet Hakkan Atilla

Reason for the color:
» Turkish Bank Charged In Manhattan Federal Court For Its Participation In A Multibillion-Dollar Iranian Sanctions Evasion Scheme;

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IFMAT Color Guide

We sort entities who are connected with terrorist activities, in two sections, first by risk and second by geolocation.
GeoLocation divisions are divided into two fields, Black List and Gray List.
BlackList is a list of all companies, organizations and figures who originate from Iran.
GrayList is a list of all companies, organizations and figures out of Iranian borders, and doing business with Iran.
We identify risk of entities by COLOR selection, each color marks the risk level of the entity.(by declining order)
Designated / Sanctioned / Illicit entities
Entities affiliated with Designated / Sanctioned / Illicit entities.
Entities sanctioned in the past for Terror or Illicit activities / WMD related / Human rights violations.
Entities in a problematic sector - Sector controlled by the Top Alert entities.
Legitimate entities - we cannot determine whether an entity is completely green, and that is due to the facts that the Iranian economy is not transparent enough for us. Be sure.