The U.S. Treasury Department on September 4, 2026 designated Türkiye-based Golden Global Yatirim Bankasi Anonim Sirketi, known as Golden Global Bank, and two subsidiaries under Executive Order 13902, saying the bank helped provide Iran with international banking access and facilitated tens of millions of dollars in transactions linked to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).
The action was announced as part of Treasury’s Operation Economic Outcast. OFAC added Golden Global Bank, Golden Global Varlik Kiralama Anonim Sirketi and Golden Global Portfoy Yonetimi Anonim Sirketi to the Specially Designated Nationals and Blocked Persons List.
Treasury alleges bank supported movement of Iranian oil revenues
According to Treasury, Golden Global Bank was established to help Iran’s rahbar network transfer oil revenues from China to Türkiye, where the funds could then be converted into cash and gold by money exchangers. Treasury also said the bank knowingly offered correspondent banking services to Iranian financial institutions, enabling transactions through accounts controlled by the IRGC-QF and its proxies.
Treasury specifically linked the activity to accounts associated with Turkish businessman Sitki Ayan and his companies. OFAC sanctioned Ayan’s network in 2022 over allegations that it moved hundreds of millions of dollars connected to IRGC-QF oil sales.
Golden Global Bank was designated under E.O. 13902 for operating in Iran’s financial sector and for knowingly engaging, on or after January 10, 2020, in a significant transaction involving goods or services used in connection with that sector. Its two Türkiye-based subsidiaries were designated for being owned or controlled by, or acting for or on behalf of, Golden Global Bank.
Blocking and secondary-sanctions implications
As a result of the designations, property and interests in property of the blocked persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. Entities owned directly or indirectly, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked.
OFAC also issued Iran General License CC, authorising the wind-down of certain transactions involving persons blocked on September 4, 2026.
Treasury warned that foreign financial institutions that knowingly conduct or facilitate certain significant transactions for persons designated under the relevant authority may face secondary-sanctions exposure, including restrictions or prohibitions on maintaining correspondent or payable-through accounts in the United States.
The designation is a sanctions action, not a criminal conviction. For financial institutions, it is particularly relevant because Treasury is explicitly targeting correspondent-banking access and financial intermediaries it says are being used to move Iranian funds across jurisdictions.
