The Office of Foreign Assets Control (OFAC), the US Treasury bureau that runs American sanctions programmes, added Golden Global Yatirim Bankasi, Golden Global Varlik Kiralama and Golden Global Portfoy Yonetimi to its blacklist on Friday 4 September under Executive Order 13902, the authority Treasury uses against firms operating in Iran's financial sector1. Treasury says the group "facilitated tens of millions of dollars' worth of transactions for the Islamic Revolutionary Guard Corps-Qods Force" and supplied "key correspondent banking access"2. It says the bank "was established for the purpose of enabling Iran's rahbar network to transfer oil revenues from China to Turkey, where it could then be converted to cash and gold"3. OFAC listed the three as separate legal persons within one group.
Correspondent banking is the account one bank holds at another so that money can cross a border. A Turkish institution needs one at an American bank to touch dollars at all. Removing it does not require a Turkish court, a Turkish regulator or any Turkish cooperation, which is why a listing published in Washington on a Friday afternoon has effect in Istanbul before the weekend. The instrument works on the correspondent relationship, and every counterparty holding one now has to decide whether to keep it.
OFAC issued General Licence CC alongside the designation, authorising transactions "ordinarily incident and necessary to the wind down" of dealings with the three institutions until 12:01 a.m. eastern daylight time on 19 September4. It reaches any entity the three own half or more of, and it requires money owed to blocked persons to be paid into blocked, interest-bearing accounts in the United States. A payment already in flight does not arrive: it halts at an American bank and sits there, owed to a company that cannot touch it. Paragraph (b) leaves transactions otherwise prohibited by the order still prohibited, so the licence is a permission to exit rather than a permission to trade. Bradley T. Smith, the OFAC director, signed it5.
The action continues a campaign rather than opening one. Operation Economic Outcast sanctioned nearly 60 Iran-linked people, firms and vessels on 24 August, and Treasury Secretary Scott Bessent warned that month that buyers of Iranian oil faced an economic reckoning. What arrived went after the account the money lands in rather than the buyer who sends it. Treasury's release gives no dates for the conduct it describes, so it establishes neither when the alleged route operated nor whether it operates now. No Turkish government response has been found, and several Turkish state sites did not answer our checks in the days afterwards6.
