Turkey froze the assets of individuals and entities connected to Iran’s nuclear program on Wednesday, according to a presidential decree published in the Official Gazette.
The move comes at a sensitive moment for Turkish state lender Halkbank, which is awaiting a decision on whether the US Supreme Court will review its appeal in a long-running case over alleged violation of sanctions against Iran.
Turkish decree mirrors UN sanctions
The freeze, enacted through Presidential Decree No. 10438, implements United Nations Security Council resolutions and applies to companies and institutions tied to Iran’s nuclear and missile programs. The list includes Iranian state organizations such as the Atomic Energy Organization of Iran, Bank Sepah and its London-based subsidiary Bank Sepah International, the Isfahan Nuclear Fuel Research and Production Center and the Karaj Nuclear Research Center. It also names senior officials including Dawood Agha-Jani and Javad Rahiqi, both linked to uranium enrichment. The decree updates earlier Turkish regulations from 2006, 2015 and 2021 that reflected UN measures on Iran.
Analysts emphasized that the step was largely procedural. Ragıp Soylu, Turkey bureau chief for Middle East Eye, wrote on X that Ankara “simply followed the snapback UN sanctions” rather than taking an independent political stance.
US imposes parallel sanctions
The same day, the US Treasury Department announced sanctions on 21 companies and 17 individuals accused of supporting Iran’s ballistic missile and military aircraft programs, with networks extending through Iran, China, Hong Kong and Germany.
The Treasury said the designations address regional threats, including risks to US forces and international shipping. Iran has steadily expanded the range and accuracy of its missiles in recent years, which Washington and its allies argue threatens regional security.
Halkbank case looms large
The sanctions announcements coincided with the US Supreme Court’s consideration of whether to hear Halkbank’s final appeal in a case over alleged sanctions violations between 2012 and 2016.
Turkish media, citing Bloomberg Intelligence, reported that the bank could face penalties of $1 billion to $2 billion if settlement talks fail — an amount analysts said would be equivalent to roughly 1.5 to 3 times Halkbank’s 2024 adjusted net profit of $672 million.
US prosecutors allege the lender processed more than $1 billion in illicit transactions intended to bypass sanctions. Under federal law criminal fines can reach up to twice the amount of the illegal transactions. A federal appeals court rejected Halkbank’s immunity claims in late 2024, prompting the bank to petition the Supreme Court. Legal analysts note the court may agree to review the case but see Halkbank’s prospects for sovereign immunity as slim.
The bank has not set aside provisions for potential penalties as of its second-quarter 2025 filings. Analysts warn that a large fine could weigh on Halkbank’s capital adequacy ratios, raising the likelihood of state support, as occurred in earlier years when Ankara injected capital into state banks.
Commentary from Bloomberg also suggested that Donald Trump’s return to the presidency could influence negotiations. During his first term in office, Trump was reported to have urged the Justice Department to treat the case more leniently. Still, most observers expect some form of penalty to remain unavoidable, though Turkey may seek concessions in a settlement.
If the Supreme Court declines review and the case proceeds to trial, Halkbank could face steeper fines. Analysts also caution that a conviction might risk restrictions on its access to the US financial system, though such measures would depend on additional regulatory action. Turkish officials say the government would not directly cover any penalty, but analysts suggest Ankara could provide liquidity support to safeguard financial stability.
