A banker was convicted for his role in a scheme to engage in transactions for the Government of Iran and for conspiracy to evade U.S. sanctions.
A jury found Mehmet Hakan Atilla guilty of providing the Iranian government and other entities with access to the U.S. financial system through his role as an executive at Turkish state-owned Halkbank. Mr. Atilla was found to have acted in violation of the International Emergency Economic Powers Act ("IEEPA") and associated sanctions banning U.S. financial institutions from facilitating transactions on behalf of Iranian entities. Prosecutors alleged that Mr. Atilla, in concert with gold trader Reza Zarrab and others, engaged in and concealed transactions that supplied currency and gold to Iranian entities through the Turkish bank. Mr. Atilla and his co-conspirators also were found to have created false and fraudulent documents in order to conceal evidence of the banned transactions. This included taking steps to misrepresent the illicit dealings as humanitarian transactions involving food, which would have exempted the transactions from the sanctions.
Mr. Atilla was convicted of (i) conspiring to defraud the United States, (ii) violating IEEPA, (iii) bank fraud and (iv) money laundering. Sentencing before the Honorable Richard M. Berman is scheduled for April 11, 2018.
Mr. Zarrab was a cooperating witness for the government and pled guilty shortly before trial to various crimes arising out of the same conduct of which Mr. Atilla was convicted. His sentencing has not yet been scheduled.
Commentary / Todd Blanche
This case was an unusual and highly publicized prosecution by the DOJ. It is not often that DOJ targets individuals for violating IEEPA, and even more uncommon when the defendants have high-level connections to a foreign government. The bank at which Atilla was an official is partially owned by the government of Turkey, and the case further strained diplomatic relations between the United States and Turkey. Global politics aside, the case demonstrates the care that a financial institution should take to ensure that its bankers, no matter where they are working, comply with the U.S. sanctions requirements.
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