Trump's DOJ Dropped a Turkish State Bank's Alleged $20 Billion Iran Sanctions Case Without a Fine

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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 · A Sanctions Case Became a Diplomatic Bargain — select a subtopic

1.1 — Six Charges Gone, No Fine

1.2 — What Prosecutors Said the Bank Had Done

1 · A Sanctions Case Became a Diplomatic Bargain

1.1 · A Sanctions Case Became a Diplomatic Bargain

Six Charges Gone, No Fine

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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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

[2]Superseding Indictment S6, October 15, 2019, reproduced in Joint Appendix, Turkiye Halk Bankasi A.S. v. United States, No. 21-1450 (U.S., November 14, 2022), printed pp. 1-4 and 33-36, paragraphs 1-7, 78 and 82-85

[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)

[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)

[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

1.2 · A Sanctions Case Became a Diplomatic Bargain

What Prosecutors Said the Bank Had Done

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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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

[2]Superseding Indictment S6, October 15, 2019, reproduced in Joint Appendix, Turkiye Halk Bankasi A.S. v. United States, No. 21-1450 (U.S., November 14, 2022), printed pp. 1-4 and 33-36, paragraphs 1-7, 78 and 82-85

[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)

[6]United States v. Turkiye Halk Bankasi A.S., No. 20-3499, Second Circuit opinion (October 22, 2024), pp. 2-8 and 40-44

[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)

2 · What the Government Gave Up

2 · What the Government Gave Up — select a subtopic

2.1 — The Deal Reached Beyond the Criminal Case

2.2 — Terrorism Victims Got No Bank Payment

2 · What the Government Gave Up

2.1 · What the Government Gave Up

The Deal Reached Beyond the Criminal Case

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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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

[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)

[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)

[8]Government's Unopposed Motion to Dismiss, United States v. Stephen K. Bannon, No. 1:21-cr-00670-CJN, ECF 207 (February 9, 2026)

[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

[10]Docket, United States v. Zarrab, No. 1:15-cr-00867 (S.D.N.Y.), CourtListener docket 4356296, descending order, updated October 2, 2026

2.2 · What the Government Gave Up

Terrorism Victims Got No Bank Payment

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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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

[2]Superseding Indictment S6, October 15, 2019, reproduced in Joint Appendix, Turkiye Halk Bankasi A.S. v. United States, No. 21-1450 (U.S., November 14, 2022), printed pp. 1-4 and 33-36, paragraphs 1-7, 78 and 82-85

[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)

[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

[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

3 · The Government Got Its Dismissal

3 · The Government Got Its Dismissal — select a subtopic

3.1 — Hostages Returned; Stable Peace Had Not Followed

3.2 — A Permanent End

3 · The Government Got Its Dismissal

3.1 · The Government Got Its Dismissal

Hostages Returned; Stable Peace Had Not Followed

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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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

[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)

[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

[12]International Committee of the Red Cross, Israel and the occupied territories: Release and transfer operations under ceasefire agreement completed (January 29, 2026), news release reproduced by Agenparl

[13]UN OCHA, Humanitarian Situation Report, 2 October 2026 (page dated October 5), Overview

3.2 · The Government Got Its Dismissal

A Permanent End

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.

Read the full chapter — all the detail, fully footnoted →

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

[2]Superseding Indictment S6, October 15, 2019, reproduced in Joint Appendix, Turkiye Halk Bankasi A.S. v. United States, No. 21-1450 (U.S., November 14, 2022), printed pp. 1-4 and 33-36, paragraphs 1-7, 78 and 82-85

[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)

[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)

[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

[10]Docket, United States v. Zarrab, No. 1:15-cr-00867 (S.D.N.Y.), CourtListener docket 4356296, descending order, updated October 2, 2026

[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

[14]Senators Adam Schiff, Richard Blumenthal, Charles Schumer, Ron Wyden and Raphael Warnock, letter to Acting Attorney General Todd Blanche (April 15, 2026), p. 1