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Golden Global Investment Bank was built largely by veterans of state-owned Halkbank, which itself inherited longstanding Iranian banking relationships when Turkey transferred the troubled Pamukbank to it two decades ago.

The same state fund that took control of Pamukbank in 2002 is now exercising shareholder rights covering nearly all of Golden Global.

The US Treasury sanctioned Golden Global, alleging it facilitated tens of millions of dollars in transactions for the Islamic Revolutionary Guard Corps’ Quds Force (IRGC-QF) and was established to help move Iranian oil revenues from China to Turkey for conversion into cash and gold.

Golden Global denies the allegations.

Turkey’s banking regulator moved on September 16 to put shareholder rights covering nearly all of Golden Global under the control of the country’s Savings Deposit Insurance Fund (TMSF).

The decision covers stakes held by three shareholders and excludes dividend rights. It comes three days before a US authorization to wind down dealings involving the bank expires.

Corporate filings show Golden Global drew its founding and subsequent leadership heavily from Halkbank. The bank opened in Istanbul in June 2020 with former Halkbank bankers as chairman and general manager, then recruited other veterans as chief executive, vice chairman, board member and compliance head.

Treasury’s designation does not name any of the Halkbank veterans personally. Their career connections are documented in corporate filings and published biographies; the US allegations concern Golden Global and its subsidiaries.

The sanctions came less than three months after a federal judge dismissed the US criminal case against Halkbank on June 17. That prosecution concerned alleged Iranian sanctions evasion between 2012 and 2016 and ended under a deferred prosecution agreement, without an admission of wrongdoing by Halkbank.

Golden Global faces a separate administrative sanctions action.

From Pamukbank to Halkbank

Pamukbank was a privately owned Turkish deposit bank founded in 1955. It established a representative office in Tehran in 1984 to support business between Turkey and Iran, two decades before becoming part of Halkbank.

Reporting on its opening, the Turkish newspaper Milliyet cited Pamukbank general manager Ibrahim Betil as saying inadequate banking links were hampering trade between the two countries. The bank said its Tehran presence would help financing and communication with Turkish businesses.

Pamukbank came under TMSF control in 2002 and was transferred to Halkbank in November 2004. Its assets, liabilities and branches passed to the state-owned lender, including the Tehran office and accounts Iranian banks already held at Pamukbank.

By 2005, Halkbank was publicly promoting its access to Iran’s oil business. Its annual report described it as the only Turkish bank authorized to open letters of credit directly to the National Iranian Oil Company. The Turkish edition also said its Tehran office helped handle large foreign-trade transactions with Iran.

Former Halkbank executive Hakan Atilla later testified in a US trial that the bank initially made only a preliminary assessment of the Iranian relationships inherited from Pamukbank and returned to them after its 2007 initial public offering. Halkbank itself later dated its Iran-related foreign-trade activity to 2004.

In January 2008, US Treasury Under Secretary Stuart Levey pressed Halkbank’s senior management over those Iranian ties. A US diplomatic cable records him urging the bank to close Iranian correspondent accounts and warning against expanding relationships with Iranian financial institutions seeking international partners.

The pressure continued in 2009, when Treasury officials warned Halkbank about Iranian efforts to disguise transactions. Halkbank officials said they financed documented trade and did not handle third-party, transit or cash-for-goods transactions.

From Halkbank to Golden Global

Golden Global later recruited bankers who had built their careers at Pamukbank and Halkbank, including in international banking, foreign operations and compliance.

The bank received its operating licence in early 2020 and opened for business on June 1. Its founding chairman, Mustafa Akin, had begun his career at Pamukbank in 1986 and managed branches for Pamukbank and Halkbank between 1994 and 2011.

Golden Global’s first general manager, Ozay Balta, had started at Halkbank as an assistant inspector in 2004 and served as a branch manager from 2012 to 2016. His published biography lists no other employer before Golden Global.

Yavuz Yeter became general manager in May 2024. He had joined Pamukbank’s Board of Inspectors in 1996 and moved to Halkbank in the 2004 merger, later serving in senior roles in its International Banking and Structured Finance department.

Yeter was therefore in senior international-banking roles during the period when Halkbank advertised its access to the National Iranian Oil Company and received Levey’s warning. That chronology does not establish that he handled the Iranian business. Atilla assigned responsibility for the Iranian accounts and Tehran office to a separate department.

Yeter later moved into senior central-bank roles. From 2016 to 2019 he held a banking-and-financial-institutions post at Turkey’s central bank. From 2020 to 2023 he served as its representative and economic attaché in Frankfurt, then advised its Istanbul office before joining Golden Global.

Coskun Cabuk joined Halkbank in the 2004 merger and worked across inspection, corporate banking and regional coordination, according to Golden Global’s 2025 annual report. The report gives no dates for those individual posts.

Cabuk stayed at Halkbank until 2017, then ran its leasing subsidiary, Halk Finansal Kiralama, until 2024. Golden Global shareholders elected him to the board for two years in March 2025 but his seat ended only a year later. Cabuk became general manager of Turkland Bank in July 2026.

The Halkbank connection also extended to compliance. Golden Global’s 2025 annual report identifies Cigdem Sefer as head of regulation and compliance. She began at Halkbank in 1996 and worked in its foreign operations, international banking and compliance units before joining Golden Global in November 2025.

Her unit’s responsibilities include evaluating correspondent relationships, screening customers and transactions against national and international sanctions, and overseeing obligations relating to money laundering, terrorism financing and proliferation financing.

Gold, cash and correspondent banking

Correspondent banking—the use of other banks to process payments and gain access to financial systems abroad—is central to Treasury’s allegations against Golden Global.

Treasury alleges the bank knowingly provided such services to Iranian financial institutions, enabling transactions through accounts controlled by the IRGC-QF and its proxies. It places Golden Global within Iran’s rahbar system, which it describes as a network of companies coordinating overseas payments for Iranian banks through foreign accounts and money exchangers.

The alleged network used correspondent banking, gold and cash to move funds.

The Treasury identifies Turkish businessman Sitki Ayan and his companies among the networks involved. OFAC sanctioned that network in 2022. Golden Global says it has had no direct or indirect dealings with those individuals..

Golden Global’s own figures show substantial growth in those areas of its business. Its 2025 report lists 45 accounts held at 20 banks in 17 countries and 66 accounts hosted for 25 banks from 16 countries. Those 25 banks are not identified.

Fees paid for foreign settlement services rose 56 percent in 2025 to 482 million lira. The bank also reported playing a critical role in settling $1.8 billion in gold transactions in 2025, nearly three times the $613 million reported a year earlier.

Physical banknote trading reached $4.4 billion, an increase of about 70%. Golden Global also reported $21.9 billion in interbank foreign-exchange trades, nearly double the previous year, and $14.5 billion in currency swaps, more than twice the 2024 total.

The reports document substantial activity in the same types of services Treasury says the Iranian network used. Those aggregate figures do not, on their own, establish which transactions involved sanctioned parties.

The September 19 deadline

Treasury designated Golden Global under Executive Order 13902, which targets specified sectors of Iran’s economy, including finance. It placed the action within Operation Economic Outcast, a campaign announced in August to intensify pressure on Iran’s remaining financial and trading channels.

The sanctions are already in effect. OFAC’s General License CC provides limited authorization for transactions ordinarily necessary to wind down dealings involving Golden Global and other covered entities. That authorization expires at 12:01 a.m. Eastern time on September 19.

The license carries conditions, including a requirement that payments to blocked persons go into blocked, interest-bearing accounts in the United States. When it expires, transactions covered by the licence lose that authorization.

Treasury has also warned that foreign financial institutions conducting or facilitating certain significant transactions on behalf of designated entities could face prohibitions or restrictions on their US correspondent accounts.

For Golden Global, whose business reaches counterparties across more than a dozen countries, the immediate pressure therefore extends beyond its Istanbul office to the institutions connecting it to the international financial system.



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