The U.S. Department of Justice has moved to dismiss criminal charges against Türkiye Halk Bankası following a deferred prosecution agreement that imposes zero financial penalties. The case alleged the Turkish state-owned bank facilitated approximately $20 billion in Iranian sanctions evasion through front companies.
Halkbank shares surged 10% immediately following the announcement. This outcome stands in stark contrast to previous settlements, such as BNP Paribas paying nearly $9 billion in 2014 for similar violations. Under the new terms, Halkbank must retain an independent compliance monitor for a 90-day review period before charges are formally dismissed.
The resolution follows extensive litigation regarding sovereign immunity. The Supreme Court ruled in April 2023 that state-owned entities are not shielded from U.S. criminal prosecution, a decision affirmed by the Second Circuit in October 2024. Despite these legal precedents establishing prosecutorial authority, the DOJ opted for a non-monetary settlement.
Democratic lawmakers have criticized the agreement as potential political interference, questioning the absence of financial consequences for a scheme of this magnitude. While the bank avoids fines, any compliance failures during the monitoring window could reopen the case. The precedent set by the 2018 conviction of a Halkbank executive for individual accountability remains intact despite the corporate dismissal.