Trump's DOJ Dropped a Turkish State Bank's Alleged $20 Billion Iran Sanctions Case Without a Fine
Chapter 1 — A Sanctions Case Became a Diplomatic Bargain
Chapter 2 — What the Government Gave Up
Chapter 3 — The Government Got Its Dismissal
1 · A Sanctions Case Became a Diplomatic Bargain
1.1 — Six Charges Gone, No Fine
1.2 — What Prosecutors Said the Bank Had Done
Trump's Justice Department permanently ended six charges against Turkey's state-owned Halkbank, accused of moving approximately $20 billion in restricted Iranian funds. The bank paid no fine and admitted no wrongdoing. The prosecutor's filing says the deal arose from ceasefire diplomacy Trump took part in. Terrorism victims got no bank payment.
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Prosecutors charged Halkbank in 2019, during Trump's first term, alleging it moved restricted Iranian money through gold purchases and fictitious food and medicine transactions. They also alleged official bribery. A bank executive was convicted and a co-conspirator pleaded guilty; Halkbank pleaded not guilty and was never tried.
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2 · What the Government Gave Up
2.1 — The Deal Reached Beyond the Criminal Case
2.2 — Terrorism Victims Got No Bank Payment
The March 2026 agreement required no fine and no admission from the bank, and it released Treasury's claims for the indicted conduct. Its special ban on Iran-related transactions involving U.S. persons lasted only until dismissal. Halkbank promised to answer Treasury's questions and to help recover co-conspirator Reza Zarrab's assets, within Turkish legal limits. The public docket also records a July 14, 2026 judgment ordering Zarrab to forfeit his interest in a boat valued at $288,690 and currency valued at $88,102.59.
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Lawyers for 1,121 terrorism victims and relatives said their clients hold over $10 billion in unpaid judgments against Iran. They alleged Halkbank hid assets needed to collect and argued DOJ denied their rights to notice and consultation. Dismissal also ended the government's forfeiture demands. Others may still seek relief, but the victims' own U.S. suit was dismissed in 2021.
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3 · The Government Got Its Dismissal
3.1 — Hostages Returned; Stable Peace Had Not Followed
3.2 — A Permanent End
The government's defense: ending the case served Gaza ceasefire and hostage diplomacy that Turkey aided. The hostage goal was achieved: the ICRC reported the transfer of 20 living hostages and recovery of the final deceased hostage's remains. Stable peace had not followed: the UN reported daily airstrikes in Gaza in September 2026. Halkbank's required review was favorable; it tested 2025 transactions, while the charges concerned 2012 through 2016.
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Berman approved the dismissal on June 17, 2026, permanently ending the bank's charges without trial. Reuters reported that Halkbank shares rose as much as 8.4% afterward. In an April 15, 2026 letter, five senators wrote that every other publicly announced deferred prosecution agreement by this administration had required millions in fines or forfeiture unless the defendant could show an inability to pay. The charge is selective relief for a foreign leader's state bank at the expense of a trial and a criminal enforcement opportunity that could have supported terrorism victims' compensation.
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Full Source Index
Primary Sources
- [1]Michael D. Lockard, Declaration and Nolle Prosequi, United States v. Turkiye Halk Bankasi A.S., S6 15 Cr. 867 (RMB), ECF 771 (filed June 17, 2026), with Judge Richard M. Berman's signed June 17 endorsement · federal court filing and signed order, third-party copy
- [2]
- [3]Deferred Prosecution Agreement dated March 6, 2026 and cover letter, United States v. Turkiye Halk Bankasi A.S., ECF 759 (filed March 9, 2026) · federal court filing, CourtListener/RECAP copy
- [5]Robert Weigel, Gibson Dunn, letter to Judge Richard Berman dated June 15, 2026, filed as ECF 772 on June 17, 2026, pp. 1-6 · victims' counsel's court submission, CourtListener/RECAP copy
- [6]United States v. Turkiye Halk Bankasi A.S., No. 20-3499, Second Circuit opinion (October 22, 2024), pp. 2-8 and 40-44 · federal appellate opinion, third-party copy
- [8]Government's Unopposed Motion to Dismiss, United States v. Stephen K. Bannon, No. 1:21-cr-00670-CJN, ECF 207 (February 9, 2026) · federal court filing, CourtListener/RECAP copy
- [9]Joint letter regarding compliance with the DPA, United States v. Turkiye Halk Bankasi A.S., ECF 766 (June 10, 2026), pp. 2-3, 6-12 · joint federal court filing, third-party copy
- [10]Docket, United States v. Zarrab, No. 1:15-cr-00867 (S.D.N.Y.), CourtListener docket 4356296, descending order, updated October 2, 2026 · court docket mirrored by CourtListener/RECAP
- [11]GAO, U.S. Victims of State Sponsored Terrorism Fund: Options for Increasing Deposits and Their Potential Impacts, GAO-24-106863 (May 2024), pp. 1-2 and footnote 4 · Government Accountability Office report
- [12]
- [13]UN OCHA, Humanitarian Situation Report, 2 October 2026 (page dated October 5), Overview · official United Nations humanitarian report
- [14]
Secondary Sources
- [4]Luc Cohen and Canan Sevgili, Reuters, Judge formally ends US prosecution of Turkey's Halkbank after Trump deal (June 17, 2026; eKathimerini syndication June 18) · reporting (Reuters, captured syndication)
- [7]Humeyra Pamuk and Jonathan Spicer, Reuters, Turkey floated $100 million Halkbank settlement idea at White House last month, sources tell Reuters (October 7, 2025; eKathimerini syndication October 8) · reporting (Reuters, captured syndication; two unnamed sources familiar with talks)