Tuesday, September 1, 2020


We finally were able to examine the 4-page Protective Order issued in the Halkbank case, and it does provide some insight into whether the Government intends to charge any other parties to the massive Iran oil sanctions evasion scheme; It definitely does.

To explain the situation:

(1) Halkbank has certain rights to pre-trial discovery; that means the US Attorney must provide evidence, documents, and even testimony under those rights.

(2) While there is such an obligation to provide such discovery materials to the defendant, it must be "consistent with safety considerations and the confidentiality of ongoing investigations." This information will include personal and confidential information of third parties.

(3) It appears that there are other Persons of Interest and the prosecution does not want the defendant to alert them that they are targets of the investigation. Such individuals may flee to countries from where they cannot be extradited, or alter their identities to make apprehension difficult or even impossible.

(4) All defense counsel co-counsel, Turkish counsel, paralegals, investigators, translators and litigation support personnel who are assisting in the defense shall be signing a copy of the Protective Order.

Who are the individuals whose names will be revealed in Discovery ? We assume they are the other participants in the oil-for-gold sanctions evasion scheme, meaning Babak Zanjani, Alireza Monfrared, and the other partners in crime not known outside the law enforcement and intelligence community. There will be others, whether they be Turkish, Iranian or Venezuelan businessmen, money launderers from the Caribbean or Panama, or other offshore tax haven players. You can expect that Halkbank will not be the last defendant named in this case.

This case may also be one vehicle through which the Department of Justice comes down on Malta's money laundering pipeline, given the relationship between Pilatus Bank's Ali Sadr Hasheminejad and the Reza Zarrab Organization. Only time will tell how, and when the hammer of justice comes down on the money launderers, sanctions evaders, and corrupt officials, there will be casualties.

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