The failure of the senior leadership in Turkey to allow the country's law enforcement and prosecutorial agencies to adequately investigate corruption, in connection with massive Iran sanctions facilitation operations, means that the Iran sanctions evasion schemes are not ending anytime soon. This is not good news for compliance officers at international banks whose clients trade with Turkish companies.
To add to the problem, the President of Turkey has announced that he will be making an official visit to Iran in February. Many observers of Turkish politics believe that Turkey will continue to ease itself closer to Iran, expanding its abilities as a sanctions facilitator, moving away from its relationship with the United States, and increasing trade between the countries manyfold.
Bottom line: kindly check all client large transactions with Turkish companies and government agencies, lest you be facilitating something that ends up in Tehran, aiding its WMD, or ballistic missile programs, and your bank draws an OFAC civil penalty as the result.
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