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U.S. Indicts Turkey’s Halkbank for Illegal Transfer of Billions of Dollars to Iran
By Harut Sassounian
Halkbank, whose majority shareholder is the Turkish government, pleaded not guilty in New York on March 31, 2020, to criminal charges that it helped Iran illicitly transfer tens of billions in dollars and gold, wrote Aykan Erdemir and Philip Kowalski in an essay published on April 3 by the Foundation for Defense of Democracies, a policy institute based in Washington, D.C.
On October 15, 2019, the Federal Southern District Court of New York accused Halkbank of “fraud, money-laundering and sanctions offenses,” alleging that Halkbank and its executives aided Iranian-Turkish gold trader Reza Zarrab in a “multi-billion dollar scheme to circumvent U.S. sanctions on Iran.”
Initially, Halkbank refused to appear in court “claiming that the criminal charges are beyond the U.S. court’s jurisdiction,” Erdemir and Kowalski wrote. However, when “prosecutors proposed escalating contempt fines which could have totaled $1.8 billion after eight weeks,” the bank agreed to respond to the court charges.
Originally, the Turkish and Iranian officials had concocted a scheme to exchange gas for gold to circumvent the U.S. sanctions, by claiming that the gold was headed not to Iranian government entities but to Iran’s “private sector.” Erdemir and Kowalski stated that “the scheme ultimately yielded the Iranian regime some $13 billion in Turkish gold between 2012 and 2013. Once the U.S. Congress introduced legislation to close the ‘golden loophole’ in 2013, Iran used Turkish front companies to issue invoices for fake transactions of food and medicine that fall under the humanitarian exception to U.S. sanctions. In one infamous case of over-invoicing, a Turkey-based luxury yacht company used Halkbank to sell nearly 5.2 tons of brown sugar to Iran’s Bank Pasargad at the price of approximately $240 per pound.”
This scheme was first exposed in December 2013 by Turkish investigators who implicated then Prime Minister Recep Tayyip Erdogan, several of his ministers and other senior officials, including Halkbank’s managers. Erdogan shut down the probe by firing the police officials, prosecutors and judges!
The scandal resurfaced in March 2016 when Iranian-Turkish ring-leader Reza Zarrab was arrested in Miami after he flew to Florida to visit Disney World with his family.
In March 2017, U.S. authorities arrested Halkbank Deputy CEO Mehmet Hakan Atilla upon his arrival in New York. Zarrab pleaded guilty and agreed to testify in court against Atilla. Zarrab confessed that he had bribed senior Turkish ministers and top Halkbank executives. He even implicated Erdogan in the corruption scheme, stating that Erdogan had personally approved the illegal actions.
“Halkbank’s Atilla received a 32-month prison sentence in May 2018, a significantly shorter one than prosecutors had originally sought,” according to Erdemir and Kowalsky. “After Atilla’s return to Turkey, Erdogan rewarded the convicted sanctions buster by appointing him CEO of the Istanbul stock exchange, following the president’s established pattern of rewarding other senior accomplices of Zarrab with cushy appointments.”
Erdogan personally appealed to Pres. Trump and other senior officials to block the court case of Halkbank, claiming that US courts have no right to try Turkish citizens. The Courthouse News Service reported that “One of Zarrab’s shell companies, Royal Holding A.S., listed its address as a 35th floor unit in Trump Towers Istanbul. Before pleading guilty to money laundering, sanctions evasions and bribery, Zarrab retained Trump’s personal attorney Rudy Giuliani to lead a campaign of shadow diplomacy that echoed the one in Ukraine. Shuttling between Turkey’s capital of Ankara and the White House, Giuliani met with Erdogan, Trump, former Secretary of State Rex Tillerson, and other senior U.S. and Turkish officials in an attempt to negotiate a prisoner swap. The New York Times reported that Tillerson resisted the White House pressure for a deal that would have effectively killed the Zarrab case.”
Erdogan’s and Giuliani’s efforts succeeded in stalling the prosecution for almost two years, but ultimately failed when the U.S. Attorney’s Office for the Southern District of New York went forward with the charges last October.”
Senator Ron Wyden, the Senate Finance Committee’s top Democrat, told Courthouse News Service: “It sure looked like Donald Trump was doing the bidding of Erdogan and Giuliani, and there were real questions about whether this was about getting Halkbank off the hook, even though there were allegations that they were orchestrating the largest sanctions evasion scheme in history.”
During President Trump’s Senate impeachment inquiry earlier in 2020, Senators Wyden, Robert Menendez and Sherrod Brown asked a joint question which was read aloud in the Senate by Chief Justice John Roberts: “Has the president engaged in a pattern of conduct in which he places his personal and political interests on top of the national security interests of the United States?”
Wyden told Courthouse News Service: “Donald Trump has significant financial interest in Turkey,” referring to Trump Towers Istanbul. “We read regularly that his family has forged personal relationships with important Turkish officials. And so, you have to ask — which is what is part of our inquiry — whether the Trump policy toward Turkey is in a significant way colored by his personal and political interests and not the national security of the country.” If Halkbank is found guilty of violating U.S. sanctions, the court could impose a hefty penalty, regardless of Tump’s wishes.
Senate Confirms Ambassador Nominees to Armenia, Azerbaijan

Ambassador-designates Lynne M. Tracy (left) and Earle D. Litzenberger (right)
Senate Foreign Relations Committee Ranking Member Robert Menendez Reiterates Key Concerns
WASHINGTON, D.C. – In the final days of the 115th Congress, last week, the U.S. Senate confirmed by a voice vote Ambassadorial nominees Lynne M. Tracy and Earle D. Litzenberger to represent the United States in Armenia and Azerbaijan, respectively.
Last month, during the Senate Foreign Relations Committee (SFRC) business meeting on the nominations, Ranking Member Robert Menendez (D-NJ) explained his support for both candidates, as well as the importance of strong U.S.-Armenia relations.
“Armenia and the Caucasus region will continue to be vital to regional and global security. According to the OSCE, Armenia’s elections over the weekend met international standards. I look forward to supporting the government’s efforts to build strong democratic institutions, a vibrant Armenian economy, and oppose any efforts to violate Armenia’s sovereignty,” Ranking Member Menendez said.
During Ambassador-designate Tracy’s nomination hearing she promised to support Armenia’s “remarkable” democratic reforms. As to questions at the hearing by SFRC Ranking Member Menendez and Senator Ed Markey (D-MA) on the Armenian Genocide, she agreed that “1.5 million Armenians were deported, massacred, or marched to their death in the final years of the Ottoman Empire” in 1915, but fell short of properly categorizing the killings as genocide.
“Throughout my time in the Senate, I have advocated for an honest accounting of the Armenian genocide. I believe we have a moral imperative to recognize the atrocities that were committed against the Armenian people. Ms. Tracy’s experience in Russia and Central Asia positions her to help navigate U.S. policy in this critical time. I support this nomination, but expect to work closely with Ms. Tracy on how she will encourage an honest acknowledgement of the Armenian Genocide, support Armenia’s ongoing efforts to ensure accountable, citizen-responsive governance, and support efforts to reach a peaceful settlement of the Nagorno-Karabakh conflict,” he added.
During the SFRC business meeting, Senator Menendez also noted the importance of safety in Artsakh (Nagorno Karabakh), and his expectations for the U.S. Ambassador selected to be the representative in Azerbaijan.
“I support Mr. Litzenberger’s nomination and expect to have close and continuing dialogue with him on how he will urge the Azeris to step back from any threatening behavior that could disrupt the line of contact in Nagorno Karabakh, support respect for human rights, and support efforts to reach a peaceful settlement of the Nagorno Karabakh conflict,” Senator Menendez said.
The hearing for Ambassador-designate Litzenberger occurred in October, wherein he restated the U.S. position condemning violence along the line of contact, which undermines the peace process and violates the 1994 cease-fire agreement.
“We appreciate the important issues raised by Senators Robert Menendez and Ed Markey during the confirmation process. We look forward to working with the new Congress to ensure robust assistance to further Armenia’s democratic development,” Armenian Assembly Executive Director Bryan Ardouny said.
Former U.S. Ambassador to Armenia, Richard Mills, concluded his tenure in Yerevan in October 2018, whereas former U.S. Ambassador to Azerbaijan, Robert Cekuta, concluded his tenure in Baku in March of 2018. Interestingly, the post of U.S. Ambassador in Ankara has been vacant since October 2017, with no nomination pending.
Biographies:
Lynne M. Tracy of Ohio is a Career Member of the Senior Foreign Service, Class of Minister-Counselor, currently serving as Senior Advisor for Russia Affairs at the U.S. Department of State. Previously, she served as Deputy Chief of Mission at the U.S. Embassy in Moscow, Russia; Deputy Assistant Secretary for Central Asia in the Bureau of South and Central Asian Affairs at the Department of State; Deputy Chief of Mission at the U.S. Embassy in Ashgabat, Turkmenistan; and Principal Officer at the U.S. Embassy Branch Office in Astana, Kazakhstan. Additionally, Ms. Tracy served as the Principal Officer at the U.S. Consulate in Peshawar, Pakistan, where she was awarded the Secretary’s Award for Heroism. She is the recipient of the State Department’s Distinguished Honor Award. Ms. Tracy earned her B.A. from the University of Georgia and J.D. from the University of Akron.
Earle (Lee) Litzenberger is a career member of the Senior Foreign Service with the rank of Minister Counselor. He has served as the Senior Advisor in the Bureau of Political-Military Affairs (PM) since January 2018. Mr. Litzenberger has served as Deputy Chief of Mission to the U.S. Mission to NATO, Brussels (2014-2017), the U.S. Embassy in Belgrade, Serbia (2010-2013) and the U.S. Embassy in Bishkek, Kyrgyzstan (2006-2009). He was the NATO Deputy Senior Civilian Representative in Kabul, Afghanistan (2013-2014). His other overseas assignments include the U.S. Mission to the European Union, Brussels, and the U.S. Embassies in Kazakhstan, Bulgaria and Algeria, and the U.S. Consulate General in Marseille, France. Mr. Litzenberger has also served at the Department of State in Washington, in the Office of the Deputy Secretary, the Bureau of Near Eastern Affairs, and the Bureau of Political-Military Affairs. He holds a B.A. in History from Middlebury College and an M.S. in Strategic Studies from the U.S. Army War College. Mr. Litzenberger speaks French, Russian, Bulgarian and Serbo-Croatian.