OFAC designates Türkiye's Golden Global Bank and two subsidiaries over Iranian correspondent access
On 4 September 2026 OFAC added three Istanbul-registered entities to the SDN List under Executive Order 13902: the investment bank Golden Global Yatirim Bankasi Anonim Sirketi and its subsidiaries Golden Global Varlik Kiralama Anonim Sirketi and Golden Global Portfoy Yonetimi Anonim Sirketi. Treasury designated the bank for operating in the financial sector of the Iranian economy, stating that it had knowingly offered correspondent banking services to Iranian financial institutions and, according to OFAC, facilitated tens of millions of dollars in transactions connected to the Islamic Revolutionary Guard Corps-Qods Force. A simultaneous authorisation, Iran General License CC, permits only transactions ordinarily incident and necessary to winding down dealings with the three entities, expires at 12:01 a.m. EDT on 19 September 2026, and requires any payment owed to a blocked person to be placed in a blocked, interest-bearing U.S. account.
Treasury describes a corridor rather than a single counterparty. It states that the bank was established so Iran's rahbar network could move oil revenue from China to Türkiye, where rahbar money exchangers converted it to cash and gold, and that the accounts served included those tied to Turkish businessman Sitki Ayan, whose network OFAC sanctioned in 2022. What sets this listing apart from the campaign around it is the layer it reaches. Correspondent access — the ability to clear payments through another bank's accounts into the international system — is the capability that earlier nodes in this Iran sequence substituted for: the exchange-house fronts of Signal 014 and the digital-asset rails addressed by the E.O. 13902 sector determination in Signal 018. It is also the instrument at issue in the recent move against Banque Misr's UAE branches (Signal 020), a correspondent-account prohibition rather than a designation. Here the correspondent relationship is the designated thing itself, offered directly to Iranian institutions.
Treasury has placed the action within Operation Economic Outcast, announced on 24 August. It is the second Türkiye-based node the desk has logged in recent weeks — the 20 August Hizballah cash-smuggling action named Türkiye-based exchange houses — though two actions mark a location, not a trend. Two things the record does not settle: China, named throughout Treasury's account of the oil-revenue route, was not itself a designated party, and Türkiye's own supervisors, the BDDK and MASAK, have not publicly responded.