US sanctions hit one of Türkiye's ten largest banks over Iran
The test Between 26 Oct 2026 and 25 Oct 2027, OFAC designates, or FinCEN finds or proposes to find of primary money-laundering concern under section 311, or the US otherwise bars from correspondent accounts, a bank among Türkiye's ten largest by total assets, over dealings with Iran.
Not under way · Confidence: medium · Reviewed 25 Oct 2026 · Scores from 1 to 10
This page answers: What could happen, how it is scored, and who is exposed?
Using this page
- Read the two scores: Likelihood and Impact are kept apart.
- Check what is happening, each fact with its source.
- Use the calendar for the dates to watch.
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Likelihood ↑ 4 Sep 2026: OFAC designated Golden Global Yatırım Bankası, the first designation of a Türkiye-based bank found for this card (sb0622)
Impact is the average of the four parts, rounded, plus one point when Canada is directly hit on two or more channels, up to 10.
Two separate scales from 1 to 10. Strature never multiplies or merges them.
What changed
Dated, newest first
- Impact 6 to 5.
- Impact 5 to 6.
- EO 14436 of 16 Oct 2026 implements the Graham Act; text names no Iran measure and no Türkiye; Russia limb applies to purchases from 18 Oct 2026 [6]
- Graham Act signed 18 Sep 2026; extends the Iran Sanctions Act (due to lapse 31 Dec 2026) through 2031; ISA authorises secondary sanctions incl. banking restrictions on foreign entities investing in Iran's petroleum sector or supplying its military [8]
- BDDK revoked Bank Mellat's operating licence in Türkiye (branches in Istanbul, Ankara and İzmir) under Banking Law Art. 71; Official Gazette 19 Sep 2026; Treasury sanctioned 36 entities and people over Iran's aviation sector and Mahan Air on 8 Sep, three of them Türkiye-based companies [3]
- CBRT gross reserves US$184.2bn on 4 Sep 2026; 5-year CDS 220 bp as of 9 Sep [7]
Show 2 earlier changes
- Treasury sb0622: Golden Global Yatırım Bankası designated under EO 13902; correspondent services to Iranian banks; tens of millions of dollars for the IRGC-QF; warning of cut-off from the US financial system [1]
- OFAC 4 Sep 2026: three Istanbul Golden Global entities added, tag IRAN-EO13902; no other Türkiye entries [2]
Why it matters
On 4 September 2026 the US Treasury designated Istanbul-based Golden Global Yatırım Bankası and two subsidiaries for serving Iranian banks, and warned that anyone helping Iran evade sanctions risks being cut off from the US financial system. Ankara has since revoked Bank Mellat's licence to operate in Türkiye. The large risk is a step up: a designation or cut-off of one of Türkiye's ten largest banks.
Why Likelihood 3 Pushes: first designation of a Türkiye-based bank found for this card; three Türkiye-based companies designated 8 Sep; EO 14382 tariff tool on Iran's partners; Graham Act extends the Iran Sanctions Act to 2031; a court-approved deferred prosecution agreement already sets sanctions and AML steps for one top-ten bank.
Why Impact 5 Key price: Turkish 5-year CDS (220 bp). Threshold case: one top-ten bank designated or proposed under section 311.
The other facts on file (5)
- US and Halkbank deferred prosecution agreement to end the Iran sanctions case: no admission, no fines; dismissal after a compliance report; OFAC closed its administrative proceedings [4] (10 Mar 2026)
- Judge Richard Berman (SDNY) approved the Halkbank DPA in June 2026; it sets sanctions and AML steps the bank must follow [9] (23 Jun 2026)
- Top ten Turkish banks by end-2025 non-consolidated assets: Ziraat 8.5tn lira first, Halkbank 4.3tn fourth, Kuveyt Türk 1.4tn tenth [10] (25 Feb 2026)
- CBRT indicative rate 31 Dec 2025: US$1 = 42.8457 lira (forex buying) [11] (31 Dec 2025)
- EO 14382 allows added duties, for example 25%, on goods of countries buying from Iran, after a Commerce finding [5] (6 Feb 2026)
Where it sits
How it spreads
Between 26 Oct 2026 and 25 Oct 2027, OFAC designates, or FinCEN finds or proposes to find of primary money-laundering concern under section 311, or the US otherwise bars from correspondent accounts, a bank among Türkiye's ten largest by total assets, over dealings with Iran.
Not under wayChannels 4 on the card
- Dollar clearingA large bank cut off loses dollar payments for its clients.
- Bank fundingForeign lenders review lines to all Turkish banks (Strature's view).
- Relations with WashingtonWould reopen the Iran issue the Halkbank deal ended (Strature's view).
- Trade with IranTurkish banks cut remaining Iran business.
Who is exposed
- Sectors
- Banks and insurers, Energy and pipelines
- Goods
- Gold
- Companies
- Golden Global Yatırım Bankası (SDN, OFAC 4 Sep 2026), Halkbank (deferred prosecution agreement with US DOJ, Mar 2026; court-approved Jun 2026), Bank Mellat, Türkiye operations (licence revoked, Sep 2026)
Three scenarios and their signposts
- S1
Small designations only
OFAC keeps naming small banks, exchange houses and traders; large banks stay clear.
- S2
Ankara pre-empts
The BDDK closes or restricts more Iran-linked entities itself.
- S3
A large bank hit
A top-ten bank is designated or faces a section 311 proposal.
| Path | Signpost |
|---|---|
| S1 | The 8 Sep 2026 designations of three Türkiye-based companies |
| S1 | Further IRAN-EO13902 designations of Türkiye-based non-banks |
| S2 | Further licence withdrawals in the Official Gazette |
| S3 | A Treasury warning naming the Turkish banking sector, or a FinCEN advisory on Türkiye |
No probability is given for the three paths.
Forecasts
Strature forecast linked to this risk
Strature forecast F-0074: 61% (21 Aug 2026) · resolves by 20 Nov 2026
A forecast is a probability on a dated question. The Likelihood score above is a separate judgement and is never turned into a percentage.
The forecast register lists every forecast and how it is scored.
The other side
Türkiye's move against Bank Mellat and the Halkbank deal show Ankara can show compliance before the US acts, which keeps its large banks clear of the dollar risk (Strature's view). Turkish banks that show they have no Iran exposure may find European and US lenders more willing to fund them (Strature's view).
Connected in Strature
- Turkey
- Iran
- United States
- The US cuts off a UAE-licensed bank or exchange house over Iran Shares a channel: The same US campaign against Iran's financial outlets.
- The US lifts its Graham Act waiver and puts secondary tariffs on a buyer of Russian oil Shares a channel: The 2026 act covers Russia and Iran.
Sources
11 sources, numbered as the text cites them
- Treasury Severs Iranian Regime's Financial Lifelines in Türkiye (sb0622). US Department of the Treasury · 4 Sep 2026 · Official · confidence high · retrieved 25 Oct 2026
- Iran-related Designations (recent actions, 4 Sep 2026). US Treasury, OFAC · 4 Sep 2026 · Official · confidence high · retrieved 25 Oct 2026
- İran merkezli Bank Mellat'ın Türkiye'deki faaliyet izni iptal edildi. Euronews Türkçe · 19 Sep 2026 · News · confidence medium · retrieved 25 Oct 2026
- Turkey's Halkbank says US agrees to end lawsuit over Iran sanctions. The New Arab · 10 Mar 2026 · News · confidence medium · retrieved 25 Oct 2026
- Addressing Threats to the United States by the Government of Iran (EO 14382). The White House · 6 Feb 2026 · Official · confidence high · retrieved 25 Oct 2026
- Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (EO 14436). The White House · 16 Oct 2026 · Official · confidence high · retrieved 25 Oct 2026
- Summary of the Monetary Policy Committee Meeting (2026-42). Central Bank of the Republic of Türkiye · 17 Sep 2026 · Official · confidence high · retrieved 25 Oct 2026
- US President signs Russia and Iran sanctions bill with new tariff powers. Baker McKenzie Sanctions News · 21 Sep 2026 · Industry · confidence medium · retrieved 26 Oct 2026
- Court OKs bid to drop Halkbank sanctions case. Florida Bulldog · 23 Jun 2026 · News · confidence medium · retrieved 26 Oct 2026
- Türkiye'nin en büyük 10 bankası geçen yıl 674,8 milyar lira kâr elde etti. Capital · 25 Feb 2026 · News · confidence medium · retrieved 26 Oct 2026
- Indicative exchange rates, 31.12.2025 (bulletin 2025/249). Central Bank of the Republic of Türkiye · 31 Dec 2025 · Official · confidence high · retrieved 26 Oct 2026
Reviewed 25 Oct 2026 · version 1 · last change: reviewed · All risks