Halkbank Escapes Criminal Conviction as EY Delivers Clean Sanctions and AML Review

US Justice Department Moves to Dismiss Halkbank Charges Three Months After DPA, Citing Clean EY Compliance Review

Three months after reaching a deferred prosecution agreement (DPA), the U.S. Department of Justice has asked a federal court in Manhattan to dismiss all criminal charges against Türkiye Halk Bankası A.Ş. (Halkbank), the Turkish state-owned lender. The motion cites a highly favourable independent review by Ernst & Young (EY) of the bank's sanctions and anti-money laundering (AML) controls, which found no areas of non-compliance.

In a court filing submitted on or around June 10, 2026, in the U.S. District Court for the Southern District of New York before U.S. District Judge Richard Berman, prosecutors from the Manhattan U.S. Attorney's Office stated that Halkbank had fully satisfied the conditions of the March 2026 DPA.

A joint letter from both the government and Halkbank informed the court: "Across its entire review of the bank's sanctions and AML-compliance program, EY did not identify any area of non-compliance."

Background on the Long-Running Case

Halkbank was indicted in 2019 during the first Trump administration on charges including bank fraud, money laundering, and conspiracy.

Prosecutors alleged the bank helped Iran evade U.S. sanctions by secretly transferring approximately $20 billion in restricted funds. The scheme allegedly involved

• Converting Iranian oil revenue into gold and cash, and
• Using fake food shipment documents to justify transfers of oil proceeds.

The case wound through multiple courts, including a Supreme Court ruling in October 2025 that allowed the prosecution to proceed despite Halkbank's arguments for foreign sovereign immunity as a Turkish state-owned entity.

The Deferred Prosecution Agreement (March 2026)

On March 9, 2026, the DOJ and Halkbank reached a DPA that paused the prosecution without any admission of guilt, without fines or penalties, and without a guilty plea. Key terms included:

• A prohibition on Halkbank conducting or facilitating any transactions that benefit Iran.
• The requirement to hire an independent compliance monitor to review its sanctions and AML programs.
• Halkbank hired EY (its Turkish affiliate) to conduct the mandated review.

Judge Berman paused the case for 90 days to allow Halkbank to demonstrate compliance. The DPA was widely viewed as easing a major irritant in U.S.-Turkey relations, which have warmed significantly under the second Trump administration.

Turkish President Recep Tayyip Erdoğan had previously called the case "unlawful and ugly" and later quoted President Trump as saying, after their meetings, that "the Halkbank problem is finished for us."

The Path to Dismissal

Following the successful EY review, the DOJ formally moved to dismiss the charges, stating it has no intention of prosecuting the bank. The motion reflects that Halkbank has met all conditions of the DPA. Both sides submitted the joint letter supporting dismissal.

Halkbank shares rose sharply on the Istanbul stock exchange when the DPA was first announced in March. A final dismissal would fully resolve the six-year legal saga.

Geopolitical Context

The resolution comes amid improved U.S.-Turkey ties as NATO allies and follows Turkey's reported role in diplomatic efforts related to the 2025 Israel-Hamas ceasefire and hostage releases. The original charges had strained bilateral relations for years.

Next Steps

Judge Berman is expected to rule on the motion in the coming days or weeks. If granted, the charges against Halkbank will be dismissed with prejudice, ending the case permanently.

Halkbank and its representatives had no immediate public comment beyond the joint court filing. The bank has maintained its not-guilty position throughout the proceedings.

This outcome underscores the DOJ's use of DPAs in complex international sanctions cases when companies demonstrate robust remedial compliance efforts and also reflects broader U.S. foreign policy priorities.

Sources

1. Reuters – "US Department of Justice formally moves to drop Halkbank case" (June 11, 2026) https://www.reuters.com/legal/government/us-department-justice-formally-moves-drop-halkbank-case-2026-06-11/
2. Global Investigations Review (GIR) – "DOJ moves to drop Halkbank charges" (recent, ~June 2026) https://globalinvestigationsreview.com/just-sanctions/article/doj-moves-drop-halkbank-charges
3. Bloomberg (syndicated) – Details on joint letter and EY findings (via The Age / SMH, June 11, 2026) https://www.theage.com.au/world/middle-east/us-iran-war-live-updates-trump-says-tehran-is-playing-us-for-suckers-as-us-military-resumes-strikes-on-iran-20260611-p605rc.html (or SMH equivalent)
4. Reuters – Original DPA announcement and background (March 9, 2026) https://www.reuters.com/business/finance/turkeys-halkbank-us-justice-department-deferred-prosecution-agreement-judge-says-2026-03-09/
5. Bloomberg – "US Asks to Drop Iran Sanctions Case Against Turkey's Halkbank" (June 11, 2026) https://www.bloomberg.com/news/articles/2026-06-11/us-asks-to-drop-iran-sanctions-case-against-turkey-s-halkbank

All information is based on court filings, official statements, and reputable news reporting as of June 11–15, 2026. For the most current status, check the U.S. District Court for the Southern District of New York (SDNY) docket for United States v. Halkbank.