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In the Courts
Turkish Banker Conspired to Evade U.S. Sanctions
Turkish banker, Mehmet Hakan Atilla, who aided the Government of Iran in evading United States sanctions, was recently convicted following a bench trial in the Southern District of New York. Mr. Atilla was convicted of conspiracies to defraud the United States, to commit bank fraud, to commit money laundering, and to violate the International Emergency Economic Powers Act (IEEPA), along with one substantive count of bank fraud.
Beginning in 1979, under the IEEPA, the U.S. President found that Iranian Government's policies constituted an extraordinary threat to national security, foreign policy, and the economy of the United States. Accordingly, the United States instituted numerous economic sanctions against Iran and Iranian entities to combat that threat. The sanctions prohibited, among other things, financial transactions involving the United States or United States persons and the Government of Iran or Iranian entities.
Mr. Atilla used his position as the Deputy General Manager of International Banking at Halkbank to assist the Government of Iran in completing financial transactions and evading the sanctions. In doing so, Mr. Atilla created false documents to disguise prohibited transactions and made the transactions appear to involve food payments, as food payments fall within the humanitarian exemption to sanctions, thereby disguising Mr. Atilla's illegal transactions as exemptions. This false categorization induced United States banks to unknowingly process international financial transactions in violation of the IEEPA.
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