Türkiye revokes Bank Mellat’s Istanbul branch licence under a prudential clause, with no findings published

Türkiye’s Banking Regulation and Supervision Agency (BDDK) revoked the operating licence of Bank Mellat Merkezi Tahran İstanbul Türkiye Merkez Şubesi — the Istanbul branch of Iran’s Bank Mellat, whose designation in the Turkish register names its Tehran head office — by a decision of its Board, Kurul Kararı no. 11572 of 18 September 2026, published in Resmî Gazete no. 33375 on Saturday 19 September. The act is one operative sentence. It records that the Board, at its meeting of 18 September, examined letter no. E-32521522-101.02.02[61]-203345 of the same date and its annexes, and revoked the licence under Article 71(1)(b) of Banking Law no. 5411. It contains no findings, no evidence and no reasoning. Subparagraph (b) allows revocation where it emerges that a bank’s continued operation endangers the rights of depositors and participation-fund holders and the confidence and stability of the financial system. That is the wording of the statute, not a finding: some coverage has presented it as something the regulator said or established, but the Board published no finding of its own under the limb. Whatever it concluded sits in the letter.

The mechanism is the story. Article 71(1)(b) is a domestic prudential power; it requires no finding about Iran or about sanctions, and the decision mentions neither. Bank Mellat has been under US sanctions for most of the past two decades: OFAC designated it on 25 October 2007 under Executive Order 13382, the counter-proliferation authority, in a listing that reached “all offices worldwide”; under the JCPOA it moved to the Executive Order 13599 list, and on 16 October 2018 OFAC deleted it from that list and added it to the SDN List, tagged [IRAN] [SDGT] [IFSR]. The Istanbul branch operated throughout. Nothing retrieved establishes that the Turkish act responds to US sanctions, and we do not draw that conclusion. The timing does sit inside a sequence of separate decisions, which should not be merged. On 4 September OFAC designated Istanbul-based Golden Global Yatirim Bankasi under E.O. 13902 (we reported it in Signal 021). On 16 September BDDK decision no. 11569 — reported as taken under Article 18(5) of the Banking Law — gave the Savings Deposit Insurance Fund (TMSF) the shareholder rights, other than dividends, attached to 99.98% of Golden Global’s shares; on 17 September the TMSF Fund Board appointed board members it has not named. Golden Global kept its licence, and its shareholders kept ownership of their shares. Two banks, three Turkish decisions, three different legal effects: the authorities did not link them, and neither do we.

What happens next comes from a separate source. In a statement carried by Bloomberg HT and posted on the branch’s own website, TMSF said management and supervision of the branch had passed to the Fund and that liquidation under Law 5411 had begun — consequences that follow from the Law, not from the Gazette text, which states neither. TMSF says it will first pay insured deposits and only then apply to court for the branch’s direct bankruptcy; it has not yet applied. If the court declines, TMSF says it will run the liquidation itself. What remains open: the grounds are in letter E-32521522-101.02.02[61]-203345, which has not been published; the letter, the Board meeting and the decision all bear the same date, 18 September; the members TMSF appointed to Golden Global’s board are unnamed; and whether MASAK, Türkiye’s financial intelligence unit, has taken any action concerning the branch is not established.