On June 10, 2026, federal prosecutors in the Southern District of New York filed for an order of nolle prosequi requesting the dismissal of all charges filed against Türkiye Halk Bankasi, A.Ş. (“Halkbank”) with prejudice. The Declaration, submitted by an Assistant United States Attorney and Co-Chief of the Illicit Finance and Money Laundering Unit, provides that the dismissal is consistent with the terms of a recent Deferred Prosecution Agreement (“DPA”) reached between Halkbank and the U.S. government. It also furthers significant U.S. foreign policy and national security interests, including multilateral efforts to secure the release of hostages, resolve the conflict in Gaza, and pursue a stable peace in the region. The order of nolle prosequi was granted by the court on June 17, 2026.
On October 15, 2019, federal prosecutors charged Halkbank for fraud, money laundering and sanctions violations that allegedly occurred between approximately 2012 and 2016. According to the superseding indictment, Halkbank used front companies in Turkey, the United Arab Emirates and Iran to enable the Iranian regime to access the U.S. financial system and evade restrictions on the use of oil and gas revenue and the supply of gold to the government of Iran. Federal prosecutors charged Halkbank with six counts: (1) conspiracy to impair the U.S. Department of the Treasury’s enforcement of economic sanctions laws; (2) conspiracy to violate the International Emergency Economic Powers Act (“IEEPA”) and related Executive Orders; (3) bank fraud; (4) conspiracy to commit bank fraud; (5) money laundering; and (6) conspiracy to commit money laundering.
On March 6, 2026, Halkbank and the U.S. government entered into a DPA, which arose from significant diplomatic and national security considerations associated with the “complex, multi-faceted, and multi-lateral efforts to arrange a ceasefire between Israel and Hamas.” An important component of the diplomatic discussions between the U.S. State Department and the Republic of Türkiye involved the resolution of the Halkbank matter on “mutually agreeable terms.” The resulting DPA required Halkbank to retain an anti-money-laundering and compliance expert — ultimately Ernst & Young’s Turkish affiliate (“EY”) — to review Halkbank’s U.S. sanctions compliance and anti-money-laundering policies and procedures and prepare a Compliance Report that was submitted to the bank, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”), and the U.S. Attorney’s Office. According to a joint letter submitted to the court on June 10, 2026, EY completed its report on May 11, 2026, satisfying Halkbank’s obligation under the DPA. As a result, the government moved to dismiss all charges in the indictment with prejudice by June 10, 2026, in accordance with their agreement.
Declaration and Nolle Prosequi | Joint letter re DPA compliance report Halkbank