Turkey

Hema Endustri is a Turkish engineering company that manufactures components for the automative, construction, agriculture, aviation, and defense industries. It specializes in the manufacture of hydraulic units, engine components, and power trains (Company Website). 

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Reuters reported on September 16, 2010, that Hema is planning to sign a deal worth $262 million with Iranian car manufacturer Iran Khodro. The deal calls for joint manufacturing of automative components in a free-trade zone near Iran's Turkish border. 

“The armed forces closed down the recently inaugurated Imam Khomeini International Airport (IKIA) on 8th May.  Because of security concerns, the armed forces closed the airport after a commercial airliner landed at the airport.  This was the first aircraft to land at IKIA. The armed forces announced that the decision to entrust the airport’s operation to a foreign company ‘threatens the security of the country as well as its dignity. The airport was built and was expected to be run by Turkish-Austrian consortium Tepe-Akfen-Vie (TAV). Iran’s two domestic airlines had announced that they would not transfer their operations to the airport.” (Zawya, “New Imam Khomeini Airport Closed after First Flight,” May 2004)

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The Guardian Council, comprising six Islamic clerics and six lay jurists, has in effect become an upper house of parliament. The council can vet all legislation passed by the Majlis and veto any laws that it judges do not comply with Islamic law or Irans constitution. Its influence was most apparent in 2004 and 2005 when it ratified legislation giving the Majlis retroactive veto power over two major foreign investment contracts, those of Turkcell (Turkey) and Tepe-Akfen-Vie (a joint Austrian-Turkish consortium). (Economist Intelligence Units Country Commerce Select, The operating environment: Political conditions, March 19, 2008)

“Iranian natural gas flows to Turkey were halted after an explosion and could take up to a week to resume after repairs are completed, officials at the Turkish pipeline operator Botas said on Wednesday. It was the second time in a little over a month that an explosion halted gas imports from Iran on the key link.” (Reuters, Iran-Turkey gas pipeline hit by blast, flow stopped, Aug. 25th 2010)

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“BOTAŞ was established on August 15, 1974 by The Turkish Petroleum Corporation (TPAO) under Decree No 7/7871, for the purpose of transporting Iraqi crude oil to the Ceyhan (Yumurtalık) Marine Terminal, in accordance with the Iraq-Turkey Crude Oil Pipeline Agreement signed on August 27, 1973 between the Governments of the Republic of Turkey and the Republic of Iraq. Because of Turkey’s increasing need for diversified energy sources, since 1987 BOTAŞ has expanded its original purpose of transporting crude oil through pipelines to cover natural gas transportation and trade activities, therefore becoming a trading company.” (Botas Website)

According to a February 2, 2022 US congressional report, "the [U.S.] Justice Department filed charges in October 2019 against Halkbank for an unspecified amount for allegedly helping Iran evade U.S. sanctions."

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"Turkey's Halkbank shares climbed more than 8% on Monday after a U.S. appeals court put its prosecution by the federal government, for allegedly helping Iran evade American sanctions, on hold while the bank appeals to the U.S. Supreme Court." (Reuters, "Turkey's Halkbank shares jump after U.S. prosecution put on hold," 1/17/22).

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"A U.S. judge on Thursday refused to dismiss an indictment accusing state-owned Turkish lender Halkbank HALKB.IS of helping Iran evade American sanctions. U.S. District Judge Richard Berman in Manhattan rejected Halkbank’s claim that the Foreign Sovereign Immunities Act shielded it from prosecution, saying that law did not appear to grant immunity in criminal proceedings. He also said an exception for commercial activity “would clearly apply and support the Halkbank prosecution,” citing the bank’s interactions with U.S. Treasury Department officials and its alleged laundering of more than $1 billion through the U.S. financial system." (Reuters, "Turkey's Halkbank Must Face U.S. Indictment Over Iran Sanctions, Judge Rules," 10/2/2020)

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"Halkbank will ask the U.S. judge overseeing a criminal case accusing it of helping Iran evade American sanctions to recuse himself, a lawyer for the Turkish bank said on Tuesday. The lawyer, Robert Cary, notified U.S. District Judge Richard Berman of Halkbank’s intention at a hearing, without providing a reason. Berman set a July 14 deadline for a formal request. Halkbank and its lawyers declined to comment. U.S. prosecutors have accused Halkbank and bank executives of using money servicers and front companies in Iran, Turkey and the United Arab Emirates to evade sanctions. (Reuters, "Turkey's Halkbank to seek removal of U.S. judge in Iran sanctions case," 6/30/2020).

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"Turkey’s state-owned Halkbank pleaded not guilty Tuesday to U.S. charges that the bank helped Iran evade sanctions on billions of dollars in oil funds. The plea, entered on behalf of the company by its lawyer, Robert Cary, comes after months of legal wrangling over the bank’s response to allegations of fraud, money laundering and conspiracy. The arraignment was conducted by U.S. District Judge Richard Berman in Manhattan by teleconference after many in-person hearings were halted over coronavirus fears." (Bloomberg, "Turkey’s Halkbank Pleads Not Guilty in Iran-Sanctions Case," 3/31/2020).

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"Turkey’s state-owned Halkbank has agreed to enter a formal plea of not guilty to criminal charges that it helped Iran evade U.S. sanctions, backing down from its previous refusal to answer the allegations, a lawyer for the bank said on Tuesday." (Reuters, "Turkey's Halkbank agrees to respond to U.S. criminal charges," 2/25/2020).

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"A federal appeals court granted a temporary halt in the U.S. prosecution of Turkish lender Halkbank over sanctions violation charges while it weighs other requests by the bank. Halkbank had previously sought to pursue a dismissal of the case without entering a plea on the charges. A judge denied the request, and the bank is appealing that ruling. A three-judge panel of the Second Circuit Court of Appeals will weigh the request on an expedited basis. Prosecutors have deemed the bank a fugitive from justice, asking a judge to hold it in contempt and impose fines until it begins answering the charges." (Bloomberg, "Halkbank Wins Reprieve in U.S. Prosecution Over Iran Sanctions," 2/3/2020).

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"The U.S. government said on Tuesday that Turkey’s state-owned Halkbank (HALKB.IS) should be subjected to escalating fines totaling millions of dollars until it responds in court to criminal charges it helped Iran evade U.S. economic sanctions. In a filing in Manhattan federal court, prosecutors said Halkbank should be fined an initial $1 million a day for contempt of court, and which could double each week to counter the bank’s “obstinacy” in refusing to defend itself in court." (Reuters, "U.S. seeks big contempt fines against Turkey's Halkbank," 1/21/2020).

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"A U.S. judge threatened to hold Turkish bank Halkbank in contempt and impose fines for refusing to acknowledge the sanctions evasions charges filed against it by federal prosecutors in New York. The state-owned bank was indicted in October for allegedly participating in a scheme to help Iran access $20 billion in frozen oil revenue. Since then, Halkbank and its lawyers have refused to accept service of the indictment or the legal summons to appear in court, and neither its lawyers nor executives have entered a plea on its behalf." (Bloomber, Halkbank Threatened With U.S. Contempt In Iran Sanctions Case, 12/10/2019).

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"US prosecutors on Tuesday charged Turkey’s majority state-owned Halkbank (HALKB.IS) with taking part in a multibillion-dollar scheme to evade US sanctions against Iran - an indictment that may complicate tension between NATO allies Washington and Ankara. The charges unsealed in federal court in Manhattan mirror those against one of Halkbank’s former executives, Mehmet Hakan Atilla, who was found guilty and sentenced to prison after a trial in the same court last year." (Asharq Al-Awsat, "US Accuses Turkey's Halkbank of Scheme to Evade Iran Sanctions," 10/16/2019).

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"The Justice Department on Tuesday sharply escalated economic pressure on Turkey by filing fraud and money-laundering charges against the country’s second-largest state-owned bank, [Halkbank] accusing it of helping Iran evade United States sanctions." (NY Times, "U.S. Indicts Turkish Bank on Charges of Evading Iran Sanctions," 10/15/2019).

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"Trade sources said Turkey’s Halkbank (HALKB.IS) - one of the main banks that Iran has relied on for such humanitarian trade - had not been able to process payments fast enough because of the complexity of the process and in some cases did not complete transactions with suppliers. Halkbank declined to comment." (Reuters, "Exclusive: Ships with one million tonnes of grain stuck outside Iran's ports in payment crisis," 10/2/2019). 

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"A US jury has found a Turkish banker of Halkbank guilty of helping Iran evade US sanctions, after a nearly four-week trial  between the United States and Turkey. Prosecutors had accused Atilla of conspiring with a gold trader, Reza Zarrab, and others to help Iran escape sanctions using fraudulent gold and food transactions. Zarrab pleaded guilty and testified for the prosecutors." (January 2018)
 

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Despite hopes of a new dawn for Iran's economy after nuclear-related sanctions were lifted, major Western banks are reluctant to do business with the Islamic republic for fear of US retribution. President Hassan Rouhani has said that to reach the target of eight-percent growth needed to modernise the industrial sector and relaunch the hobbled economy, Iran needs up to $50 billion in foreign investment every year. But without the big foreign banks, that looks impossible. "For the moment, the little European banks have agreed to work with us," said Parviz Aghili, head of the private Middle East Bank in Tehran. They include banks from Italy, Austria, Switzerland, Germany and Belgium, he said without naming them. "But not a single medium-sized or big bank has so far agreed to do it," he added... The limited number of institutions that do deal with the Islamic republic include Raiffeisen Bank and Erste Bank from Austria, Mediobanca and Banco Popolare of Italy, Germany's EIH, KfW and AKA banks, Belgium's KBC, ING of the Netherlands and Turkey's Halk, according to a banking expert in Tehran. "These banks have established working relations with the Iranian banks to open letters of credit for fairly small sums of 10, 20 or 50 million dollars." But they lack the resources to finance big projects like the deal struck between Iran and European aircraft manufacturer Airbus for 118 airplanes, or oil and gas development projects, the expert said. (AFP, "Iran banking hobbled by Western reluctance to engage," 9/13/2016).

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"Iran is seeking partnerships with Turkish companies for highway, airport and railway projects worth $10 billion over the next three to five years, Iranian Ambassador to Turkey Ali Reza Bikdeli said in an interview in Ankara. 'We have many projects,' Bikdeli said late Monday. 'We are ready to award these projects to internationally-proven Turkish companies.' ... Contracts to Turkish corporations would be awarded through work partnerships with Iranian companies and without bids, Bikdeli said. Ankara-based construction company Bergiz Insaat, in a joint venture with an Iranian state company, has already begun building a $1 billion highway project and an $800 million subway in northwestern Iran, he said. Turkey’s state-run TC Ziraat Bankasi AS should also do business with Iran, Bikdeli said. Turkish lender Turkiye Halk Bankasi AS handles payments for Iranian energy transactions." (Bloomberg, "Iran's Envoy: $10 Billion Projects Await Turkish Companies", 6/23/15)

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"Indian oil refiners will clear around 6 billion euros ($6.7 billion) of outstanding debt to Iran through Turkey's Halkbank.”  (Reuters, “Indian oil payment backlog to Iran to be cleared soon - Iranian official,” 6/1/2016)

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“Turkey's state-owned Halkbank is expected to continue processing payments for Iranian oil imports to Turkey, U.S. Treasury Undersecretary David Cohen said on Monday. ’Halkbank has for some time been involved in handling oil payments for importing oil from Iran into Turkey and we expect that to continue,’ David Cohen, Undersecretary for Terrorism and Financial Intelligence told reporters.’ We talked more broadly about sanctions ... on the banking sector so that there is good clarity on the scope of sanctions that remain in effect,’ Cohen said after his meeting with Foreign Ministry Undersecretary Feridun Sinirlioglu.” (Reuters, “Turkey's Halkbank seen continuing to handle Iran oil payments - U.S.,” 1/27/14)

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"Turkey's state-owned Halkbank, whose general manager has been detained as part of a corruption inquiry, will keep processing payments for Turkey's oil and gas imports from Iran, Turkey's Deputy Prime Minister Ali Babacan said on Wednesday. ’The state of Iran has accounts with Halkbank and we deposit the payments for the oil and gas purchased to these accounts ... Halkbank will continue to carry out this function,’ Babacan told Bloomberg HT Television. Halkbank general manager Suleyman Aslan was among dozens of prominent business people, the sons of three cabinet ministers, and state officials questioned as part of a corruption inquiry swirling around Prime Minister Tayyip Erdogan's government…Halkbank has repeatedly said its dealings with Iran are entirely lawful, but its Iranian business ties had drawn Western criticism amid U.S.-led efforts to curb Tehran's disputed nuclear programme. Turkey has bought natural gas and oil from Iran through an indirect system whereby Iranian exporters received payment in Halkbank lira accounts and used that money to buy gold. The bulk of that gold was then been shipped from Turkey to Dubai, where Iran could import it or sell it for foreign currency. Halkbank said last month that the gold sales had stopped on June 10, in line with a July ban. Since then, sources say, Iranians have bought mostly food and medicine with the funds.” (Reuters, “Halkbank to keep processing Iran energy payments for Turkey -Babacan,” 1/8/14)

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“An unfolding corruption scandal in Turkey has uncovered transactions that may have allowed Tehran to circumvent harsh U.S. and E.U. sanctions—a revelation that could destabilize Obama’s nuclear deal and threaten the government of Prime Minister Erdogan. A massive unfolding corruption scandal in Turkey—which has already forced the resignations of three government ministers and threatens to upend the Islamist government of Prime Minister Recep Tayyip Erdogan— is fast acquiring an international dimension amid accusations that Iran is enmeshed in Ankara’s political crisis…The first hint of the Iranian angle in the corruption probes launched by Turkish police in the face of government obstruction came before Christmas when a complicated oil-for-gold deal between Turkey and Iran was unmasked.  The investigators didn’t set out to uncover the sanction-busting oil deal but say they were led to it by following a trail of cash bribes. An Iranian businessman and gold dealer, Reza Sarraf (also known as Reza Zarrab), whom police have accused of bribing the Economic Minister while organizing transactions from Iran worth $120 billion, was arrested last week. So, too, the CEO of the state-owned Turkish financial institution Halkbank, who was reportedly found to have more than $4 million of cash stuffed in shoe-boxes in his home. According to Turkish investigators, both men were at the center of a complex deal in which Iran sold oil and natural gas to Turkey for cash payments that were deposited in an account held at Halkbank. In order to circumvent international money-transfer sanctions on Iran, the cash deposits were then allegedly converted into gold that Turkey exported to Tehran, often via Dubai. Police reports filed with Turkish prosecutors estimate that in the past three years alone, $8 billion in gold was transferred to Iran. American analysts say the number could be higher, to the tune of $13 billion between March 2012 and July 2013 alone. (In July 2013, the U.S. and the European Union tightened loopholes on a ban on gold exports to Iran.) In a statement to the Istanbul bourse, Halkbank stated that all its business transactions with Iran have been transparent and legal, and that it stopped exporting gold to Tehran in June 2013. The broad outlines of the oil-for-gold deal has been known for some time—in April,47 U.S. lawmakers called on Secretary of State John Kerry and Treasury Secretary Jack Lew to sanction Halkbank for its gold trade with Iran.” (The Daily Beast, “Turkey And Iran Accused Of Oil-For-Cash Sanctions Scheme,” 12/28/13)

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"Turkey's state-owned Halkbank, whose chief executive was arrested in connection with a sweeping graft investigation, said on Monday it complied with the law when doing business with sanctions-hit Iran. 'Our bank's business transactions are regularly audited by relevant authorities,' the bank said in a statement. 'The financial intermediation that our bank offers with regard to trade activities with Iran have been conducted in accordance with regulations,' it added. The statement comes after Halkbank chief executive Suleyman Aslan was charged Saturday with taking bribes, while Azerbaijani businessman Reza Zarrab was charged with forming a ring that bribed officials to help disguise illegal gold sales to Iran via Halkbank. Police had also reportedly found $4.5 million in cash stored in shoe boxes in Aslan's home. Twenty-four people have been charged so far in connection with the high-profile investigation including the sons of Interior Minister Muarrem Guler and Economy Minister Zafer Caglayan as well as several top business leaders…Halkbank has come under fire from some quarters in the United States for alleged illegal transactions to Iran. The bank said it stopped transactions to Iran as of June 10 after the United States announced further sanctions against the Islamic republic. Several pro-government media outlets claimed over the weekend that US ambassador to Turkey Francis Ricciardone told some European Union ambassadors that Washington asked the bank to cut its ties with Iran -- the allegations vehemently denied by the ambassador. The reports however infuriated the prime minister who warned he may expel some foreign ambassadors over 'provocative actions,' in remarks considered a veiled threat to Ricciardone." (AFP, "Turkey's Halkbank denies wrongdoing in Iran deals," 12/23/13)

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"Iranian Ambassador to Turkey Ali Reza Bikdeli said in an interview in Ankara yesterday that Halkbank, which handles payments for Iranian energy transactions, would maintain a key role in trade ties. Turkish exports to Iran slumped to $3.4 billion in the first nine months of this year, compared with $9.9 billion in the whole of 2012, as sanctions barred Tehran from accepting gold as payment for oil, according to data from Turkey’s statistics office last month. Precious metals accounted for 66 percent of direct exports to Iran in 2012, the data show." (Bloomberg, "Halkbank CEO, Ministers Sons Said Held in Turkey Graft Probe," 12/17/13)

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"Turkey's state-run Halkbank can only resume processing Indian oil payments to Iran once Western sanctions are officially lifted following an interim deal in Geneva last month, a senior Halkbank official said on Wednesday. 'If the deal signed in Geneva becomes official, we could resume processing Indian oil payments to Iran,' Hakan Aydogan, head of Halkbank's foreign operations department told reporters. 'Despite the breakthrough, the positive developments, there has not been official progress in this,' he said…India started settling 55 percent of its payments for its purchases of Iranian oil in euros through Halkbank in mid-2012. The rest was settled in rupees through India's UCO Bank. But the Halkbank route was halted in February this year when new sanctions prevented Iran from repatriating cash earned from oil it has been able to sell, choking off the biggest revenue stream to its economy." (Reuters, "Halkbank unable to resume processing India payments for Iran oil," 12/11/13)

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"All Turkish banks will be able to make Iranian transactions as sanctions on Iran are eased in the wake of a deal between Tehran and six world powers to curb Tehran's nuclear programme, Turkey's economy minister said on Thursday…State-owned Halkbank, one of Turkey's biggest banks, had continued to process transactions, remaining one of the few to do so in the face of U.S. sanctions targeting financial institutions that dealt with Iran's central bank…Among transactions conducted by Halkbank are payments by Indian refiners to Iran. The refiners used this route until February and these payments could now resume." (Reuters, "Turkish banks to be able to make Iran transactions -minister," 11/28/13)

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"India could step up imports from Iran next month and start transferring billions of dollars owed it for oil as early as next week following a deal to curb Tehran's nuclear programme…Payments could potentially resume through Turkey's state-run Halkbank, a route used until February when it was blocked by sanctions…A government official also said that payments would be expedited once the payment mechanism via Turkey opens up. 'If that Halkbank route opens up ... rather than pushing this to a later date, perhaps this money will go to the Iranians sooner rather than later,' the official with direct knowledge of the matter said." (Reuters, "India ready to start Iran oil cash transfer after deal," 11/25/13)

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"Indian refiners have asked the government to clarify if they can pay Iran for crude in euros after the National Iranian Oil Company (NIOC) requested settlement of some debts through a Turkish bank, Indian officials said on Wednesday…India now owes Iran about $5.3 billion for oil imports, government and refining sources said last week. In mid-October, NIOC informed Indian refiners that Halkbank was ready to restart channelling the payments to Iran, the sources told Reuters, declining to be named due to the sensitivity of the matter. NIOC said it had been informed that Halkbank could be used again by Iran's central bank. It was unclear from the communication from NIOC what had changed that would allow the payments to restart without contravening U.S. sanctions, the sources said…Indian refiners have yet to restart payments via Halkbank and have asked the government for guidance, the sources said." (Reuters, "Indian refiners puzzle over Iran request for euro oil payment-sources," 11/13/13)

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"Several of America’s largest financial institutions are significant shareholders in Turkey’s Halkbank, a majority state-owned lender that has come under fire for enabling so-called 'gold-for-gas' exchanges with Iran that violate U.S. sanctions, according to investment documents obtained by the Washington Free Beacon. Multiple U.S. financial groups currently own shares in the bank, also known as Turkiye Halk Bankasi, which is state-owned and publicly traded. They include the Vanguard Group, Inc., Fidelity Management, J.P. Morgan, T. Rowe Price Associates, Inc., and Principal Management Group, among others... 'It is of great concern that U.S. institutions may be indirectly involved in the sale of Iranian oil for Turkish gold,' said Nathan Carleton, spokesman for United Against Nuclear Iran (UANI), a nonpartisan advocacy group that pressures international companies to cease dealings with Tehran. 'The Iranian regime is conducting these transactions specifically to evade sanctions and fund its nuclear program.' 'The American people don’t want their money going toward Iran business, and once they’re informed of these situations the companies will have to make a choice between U.S. investors or the Iranian regime,' Carleton said. 'Any U.S. entities invested in Halkbank should take immediate action to stop Iranian oil transactions, or divest.' Halkbank has quietly been exchanging large amounts of gold for Iranian crude oil according to multiple reports. These large monetary exchanges have provided Tehran with an economic lifeline while the nation’s energy sector is subjected to international sanctions... Halkbank has also processed monetary deals between Indian oil companies and Tehran, according to Bloomberg. The U.S. has never formally blacklisted Halkbank despite its sanctions-evading practices. While it is legal to own shares in the bank, its behavior directly violates U.S. and U.N. sanctions on Iran. Sanctions experts have speculated the state-controlled Halkbank may have escaped designation due to its political connections... 'The Obama administration relies heavily on Turkey—we have effectively sub-contracted our Syria policy to Ankara. A designation of Halkbank would greatly complicate that relationship,' said Jonathan Schanzer, a former terrorism finance analyst at the U.S. Treasury Department. It is difficult to determine just how much U.S. money is tied up in the Ankara-based bank, though one of the its shareholders, Vanguard, maintains the investments in Halkbank are minimal and not 'political' in nature. At least five Vanguard funds have 'relatively small investments in Turkiye Halk Bankasi as of Dec. 31, 2012,' David Hoffman, a Vanguard spokesman, told the Free Beacon. Halkbank accounted for '0.02 percent to 0.16 percent' of fund assets, according to Hoffman. Vanguard is one of Halbank’s top five Americna investors, owning nearly 2 percent of the lender as of late Friday, according to updated Bloomberg investment information obtained by the Free Beacon. This translates to more than 24 million shares in the bank. Hoffman said Vanguard’s investments in Halkbank are primarily maintained through index funds, or collective investment systems... The other U.S. financial institutions involved in Halkbank either did not respond to a request for comment or declined comment when reached by the Free Beacon last week... Halkbank is listed as one of the top investments in this particular fund... 'Halkbank is one of the worst offenders in the world of U.S. sanctions violations on multiple levels, many of which are not even public,' said a senior Senate aide involved in sanctions legislation... U.S. companies involved in Halkbank have been walking a tightrope, said the Senate source... Carleton said these types of questionable investments are not unusual. 'This sort of thing is sadly rather common, particularly since these deals often have been in place since before Iran sanctions and divestment were as popular as they are now,' he said. 'We regularly find that simply highlighting the issue will result in change.' Recently implemented economic sanctions could make it more difficult for Halkbank to support Iran’s energy sector... 'The Halkbank issue is just one of several for Turkey right now,' Schanzer said. 'Ankara has become one of the top sponsors of the Palestinian terrorist group Hamas.'" (The Washington Free Beacon, "Unsanctioned Investments: U.S. institutions hold shares of Turkish bank engaged in gold-for-oil trades," 2/19/2013)

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"Tighter U.S. sanctions are killing off Turkey's gold-for-gas trade with Iran and have stopped state-owned lender Halkbank from processing other nations' energy payments to the OPEC oil producer, bankers said on Friday. U.S. officials have sought to prevent Turkish gold exports, which indirectly pay Iran for its natural gas, from providing a financial lifeline to Tehran, largely frozen out of the global banking system by Western sanctions over its nuclear program. Turkey, Iran's biggest natural gas customer, has been paying Iran for its imports with Turkish lira, because sanctions prevent it from paying in dollars or euros. Iranians then use those lira, held in Halkbank accounts, to buy gold in Turkey, and couriers carry bullion worth millions of dollars in hand luggage to Dubai, where it can be sold for foreign currency or shipped to Iran. Halkbank had also been processing a portion of India's payments for Iranian oil. A provision of U.S. sanctions, made law last summer and implemented from February 6, effectively tightens control on sales of precious metals to Iran and prevents Halkbank from processing oil payments by other countries back to Tehran, bankers said. 'Halkbank can only accept payments for Turkish oil and gas purchases and Iran is only allowed to buy food, medicine and industrial products with that money,' one senior Turkish banker told Reuters. 'The gas for gold trade is very difficult after the second round of sanctions. Iranians cannot just withdraw the cash and buy whatever they want. They have to prove what they are buying ... so gold exports will definitely fall,' he said." (Reuters, "Exclusive: Turkey to Iran gold trade wiped out by new U.S. sanction," 2/15/13)

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"In Turkey, state-run lender Turkiye Halk Bankasi AS HALKB.IS +1.25% has been responsible for processing the payments, since the U.S. adopted a measure in January to stop dealing with financial institutions working with Iran's central bank, freezing out private Turkish banks from facilitating payments. Halkbank raised 4.5 billion liras ($2.5 billion) Monday in Turkey's biggest offering in a secondary share sale-a 20.8% stake, according to a statement to the Istanbul Stock Exchange." (The Wall Street Journal, "Turkey Swaps Gold for Iranian Gas," 11/23/2012)

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"Indian refiner Bharat Petroleum Corp (BPCL) has not received Iranian oil since February as it could not open an account with Turkey's Halkbank, which is used by other Indian refiners to pay for oil from Tehran in euros." (Reuters, "India's HMEL bought 2 million barrels of Iranian oil: sources," 10/13/2012)

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"India currently uses Turkey's Halkbank to route dollar payments to Iran. The new set of sanctions being contemplated would close that route." (The Times of India, "US barbs may block India's pay path for Iran oil," 10/7/2012)  

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"Turkey's importance as a trade conduit to Iran has widened to include supplying most of its steel as Turkish banks are among the very few still willing to arrange financing for the sanctions-hit country . . . Banks in traditional steel suppliers such as Turkey, Russia, Ukraine and Europe have withdrawn most financing facilities for deals with Iran, making it extremely difficult for producers and traders to do business with the Gulf country. Yet traders said Turkey's banks, among them state-owned Halkbank, are accepting letters of credit from Iranian buyers. 'There is a facility in place which allows Turkish bank Halkbank, to receive funds from Iran,but only for material that is supplied from Turkey,' said one UK-based steel trader. 'Consequently Turkey almost has a monopoly. 'Halkbank general manager Suleyman Aslan, declined to comment on the issue." (Reuters, "Steell is Turkey's latest helping hand to Iran," 8/16/12)

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"State-run Hindustan Petroleum (HPCL) has made its first payment for Iranian oil in rupees to partially settle its bill for a cargo imported in May, company officials said on Friday, a move that will help New Delhi fix its trade imbalance with Tehran . . . India is Iran's second-largest oil buyer, but has struggled to find ways to pay for the oil as Western sanctions curb international financial payments destined for Tehran. The two countries agreed in January to settle 45 percent of the oil trade in rupees. The balance of HPCL's payment, made on Friday, was through Turkey's Halkbank and India's UCO Bank. 'This is the first payment we have made since the gate was opened...we have paid 45 percent in rupees and 55 percent through Halkbank,' B. Mukherjee, head of finance at HPCL, told Reuters. Since July 2011, refiners in India have been using Halkbank to pay their annual oil import bill of more than $10 billion, after a previous payment channel was blocked in December 2010 . . . HPCL has paid 2.75 billion Indian rupees ($49.25 million) to Iran through UCO Bank and $60 million through Halkbank, a company source privy to the matter said." (Reuters, "India HPCL begins rupee payment for Iran oil," 3/8/12)

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"Secretary of State Hillary Clinton said on Monday the U.S. would exempt India, South Korea, Turkey and four other countries from financial sanctions because they have significantly cut purchases of Iranian oil. That means Turkey's Halkbank will be able to make payments to the Iranian Central Bank for oil shipments to Tupras without fear of being blacklisted by the United States." (Reuters, "U.S. presses Turkey to cut more Iranian oil imports," 6/12/12)

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"Turkish lender Halkbank , little known outside Turkey, has gained a reputation in the oil market over the past 18 months for handling transactions that other banks fear to touch - trade deals with Iran... Halkbank's stance toward Iran largely has reflected the attitude of the Turkish government, which owns 75 percent of the bank, towards international sanctions against Tehran over its nuclear programme... Halkbank handles payments to Iran by Tupras, which is owned by the Turkey's largest conglomerate Koc Holding, according to industry sources with knowledge of the transactions. Indian refiners, unable to pay Iran for imported oil through their own banking system for fear of U.S. retribution, turned to Halkbank in mid-2011 to make payments. In December, Halkbank refused to open an account for an additional Indian refiner, BPCL, for that purpose. No reason was given, though there was speculation that Turkey wanted to avoid further antagonising Washington. Halkbank was contacted over the status of the bank's dealings with Iran, but senior officials were unavailable for immediate comment." (Reuters, "Iran dealings put Turkey's Halkbank in spotlight," 1/4/2012)

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"Halkbank, as the bank is popularly called, was revealed to have facilitated payments of $100 million between Indian oil refiners and the National Iranian Oil Company. This fund transfer was a multi-step process coordinated with Union Bank of India, and designed specifically to evade international sanctions." (Bloomberg, "Iran Receives $100 Million in Oil Payments From India, PTI Says," 8/2/2011)

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Conducts business with U.S. banks and Iranian banks. ("Iran's Dirty Banking", Avi Jorisch)

In January 2021, the State of New Jersey Department of the Treasury listed Som Petrol as a company engaged in prohibited activities in Iran pursuant to P.L. 2012, c. 25 ("Chapter 25"). 

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On October 14, 2020, Som Petrol remained on the Tennesse Department of General Services list of persons it determines engage in investment activities in Iran, as described in 12-12-105.

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As of July 1, 2020, Som Petrol is listed as an entity “determined, based on credible information available to the public, to be engaged in prohibited activities in Iran pursuant to New Jersey P.L. 2012, c.25 (“Chapter 25”). 

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As of April 15, 2020, Som Petrol is included as an entity determined to be non-responsive bidders/offerers pursuant to The New York State Iran Divestment Act of 2012.  

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As of April 15, 2020, Som Petrol is included on the Tennessee list of persons it determines engage in investment activities in Iran, as described in § 12-12-105. 

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On June 30, 2019, New Jersey listed Som Petrol on its state list of entities determined, based on credible information, to be engaged in prohibited activities in Iran.

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In 2018 and 2019 Tennessee used the New York list of “Entities determined to be non-responsive bidders/offerers pursuant to the New York State Iran Divestment Act of 2012.” Som Petrol was included on this list in 2018 and 2019. Tennessee states "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

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"Iran’s Oil Ministry said the country had signed a €1 billion ($1.3 billion) pipeline deal to take gas to Turkey and a Turkish firm called Som Petrol said it was the partner in 
the project.

“The one billion euro deal to build 660km gas pipeline was signed on Thursday during the Iranian Oil Minister’s trip to Turkey,” the Iranian ministry said in a statement on Friday...

“The pipeline will enable Iran to export 50 to 60 million metres of gas per day ... It will be constructed within three years,” Javad Oji, head of the National Iranian Gas Export Co. (NIGC), told the Iranian Oil Ministry’s official website (sic) SHANA.

Oji was quoted by the Mehr news agency as also saying that 23 per cent of the project would be handled by the Iranian side and 77 per cent by the Turkish side. One of the world’s biggest oil and gas producers, Iran has been hit by US and UN sanctions that have hindered access to foreign investment and slowed its development as a major exporter.

The website identified NIGC’s Turkish partner as ASB Co., but Som Petrol said it had signed the deal.

“We signed the agreement on the Iran-Turkey pipeline yesterday,” Som Petrol’s Chairman Sitki Ayan told Reuters.

This agreement can be seen as continuation of a project that began in 2008.

Iran and Turkey first agreed on a pipeline project in 2008 with the aim of carrying Iranian gas to Europe.

Ayan said the pipeline would carry 110 million cubic metres of gas per day and is planned to be completed in 2014...

Som Petrol already has operations in Turkmenistan and has been looking to expand business with Iran. A unit of Som Petrol had applied to the energy regulator EPDK for permission to purchase electricity from Iran, according to officials from the regulator.

Turkey’s Energy Minister Taner Yildiz said neither the Turkish government nor state pipeline concern Botas were involved in the deal with Iran, though several private firms had  hown (sic) interest.

On June 30, 2020, the Mississippi Department of Finance & Administration identified Tupras as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.” 

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Turkish oil importer TÜPRAŞ, which has imported some 100,000 tons of crude oil from Iran according to the provisional data for April, will cut its oil imports from the country completely. It is said that its new crude oil route may be from countries such as Iraq, Russia and partly Saudi Arabia. (5/8/2019)

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"Turkey's Tupras reduces Iranian crude purchases as U.S. sanctions loom." (7/20/18)

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In 2017 the U.S. state of Mississippi listed Tupras on its Iran scrutinized list rendering Tupras ineligible for investment and/or state contracting.

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In 2016 and 2017 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran. Aban Offshore was included on this list in 2016. "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

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In 2015 Tupras was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because the company's "involvement in purchases of crude oil falls uner the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."
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Tupras is a subsidiary of Koc Holding.

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"In November 2013, the US State Department extended six-month Iran sanctions waivers to Turkey, among other countries, in exchange for their reduced purchases of Iranian crude oil earlier this year. Under the Geneva accord signed that month, the U.S. and five other countries agreed to suspend efforts to further reduce Iran's crude oil sales, allowing consuming countries to continue buying their 'current average amounts of crude oil'. In 9M13, Iraq became Tupras's principal crude oil source by supplying nearly 28% of its crude oil, while Iran supplied 25% of Tupras's total crude, down from 45% in 2011. Tupras's favourable location and coastal refineries give it access to a variety of crude sources.” (Reuters, “RPT-Fitch affirms Tupras at 'BBB-'; outlook stable,” 1/15/14) 

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In 2014, Tupras was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.

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“Tupras Turkiye Petrol Rafinerileri AS (TUPRS), Turkey’s only oil refiner, will cut imports of crude oil from Iran this year 22 percent to 5.6 million tons, or 105,000 barrels a day, to comply with sanctions. The U.S. extended exemptions to sanctions against Iran’s nuclear program to countries dependent on Iranian crude for another six months from June, Tupras Chief Executive Officer Yavuz Erkut said yesterday. Iran is Turkey’s largest supplier.  ‘We have diversified crude oil sources and the decrease in Iran supplies is being compensated for by purchases from Saudi Arabia and Iraq,’ he said. Iraq supplied 3.8 million tons in 2012 while Saudi Arabia 2.8 million tons, he said.” (Bloomberg, “Turkey Will Cut Imports of Iranian Crude 22% to Meet Sanctions,” 6/28/13) 

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"Tupras, Turkey's sole oil refiner, will extend purchases of crude oil from Iran when the company's contract expires in August but won't increase imports, Energy Minister Taner Yildiz said... Yildiz said Tupras, which is controlled by Turkey's biggest company Koc Holding, will continue to buy the same amount it has been under the exemption." (Reuters, "Turkey's Tupras to extend Iran oil purchase contract," 1/7/2013)

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"Around 200,000 barrels per day (bpd) of Iranian crude oil were discharged at the import terminals Aliaga and Tutunciflik for Turkey's sole refiner Tupras, data from a shipping source and AIS Live ship tracking on Reuters showed. Tupras used two Iranian tankers to bring Iranian crude from storage at the Egyptian port of Sidi Kerir. The port is the end-point of the Sumed pipeline, an alternative route to the Suez Canal for oil shipments coming into the Mediterranean from the Red Sea... Tupras is wholly reliant on Iranian-owned tankers as they are still unable to insure their own vessels. 'Right now they cannot carry any Iranian oil with their own tankers, that problem is still not solved,' said a Turkey based shipping source close to Tupras." (Reuters, "Turkey's Iranian oil buying jumps in August," 9/4/2012)

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"Tupras Petrol Rafinerileri AS (TUPRS), Turkey’s sole refiner, said net income plunged 47 percent in the second quarter, missing estimates, as Iran oil sanctions shrank its refining margins... Tupras cut oil purchases from Iran in the second quarter as the U.S. and Europe planned sanctions against the Persian Gulf country... 'Refineries’ production costs have increased because of Iranian sanctions,' Tupras said in an e-mailed statement. Inventories lost value as oil and product prices fell, while rising natural gas boosted production costs, which also contributed to narrower refining margins, the company said... Tupras said Aug. 14 that its net refining margin fell to $3.65 a barrel compared with a second-quarter Mediterranean regional benchmark of $5.73 a barrel and from $4.34 in the same period last year. Production fell 0.6 percent in the first half of this year, the company said at the time... Tupras aims to make products with a low sulfur content such as diesel and gasoline from higher-content products such as fuel-oil through a so-called residuum upgrade project. Tupras spent $584.5 million on the project in the first half of this year, carrying out about a quarter of the $2.4 billion project, which is scheduled for completion by 2014, it said. Tupras is cutting oil purchases 20 percent from Iran, after signing a contract in August 2011 to buy 9 million metric tons, or 180,000 barrels a day, of crude for a year. Iran’s share of Turkish crude oil imports dropped to 37 percent in June from 50 percent in May and 66 percent in April, according to data from Turkey’s energy market regulator. Turkey imported 1.87 million tons of crude from all nations in June, it said." (BusinessWeek, "Tupras Quarterly Profit Drops 47% on Iran, Missing Estimates," 8/28/12) 

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"Turkey's sole refiner, Tupras, has been forced to lift even less Iranian oil than it had itself promised to the West as EU measures have stopped European firms, which dominate the marine insurance sector, from offering cover on Iranian crude... Tupras has been compensating for the lower Iranian volumes with Russian and Iraqi medium sour grades as well as Nigerian and Libyan light sweets." (Reuters, "Turkey's Iranian oil buys hit new low in July," 8/13/12"

"Turkey is struggling to import Iranian oil in July because of Western sanctions on ship insurance, trading and shipping sources told Reuters, leaving Tehran battling to sell oil now stuck in storage tanks in Egypt.

Turkey, which relies on Iran for half its crude needs, has already cut imports of Iranian oil by a fifth from average levels of 2011 to win waivers from U.S. sanctions.

But volumes will now likely fall much steeper as Turkish main refiner Tupras cannot import Iranian oil on Turkish tankers after European Union sanctions against Tehran stopped the region's firms, which dominate the marine insurance sector, from offering cover on Iranian crude.

'Tupras was lifting Iranian crude with its own tankers up until July... This is no longer possible... They are now focusing more on lifting from Libya, Saudi Arabia and Iraq with its tankers,' said a Turkey-based shipping source." (Reuters, "Iranian oil stuck in Egypt as Turkey cuts imports," 7/13/12)

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"Turkey's crude oil imports from Irandropped by more than 35 percent in May from April as it steps up efforts to ensure the United States waives sanctions on its imports of Iranian oil for the remainder of this year…Turkey's only crude buyer, refiner Tupras, has a term contract with Iran that expires in August, which allows it to lift 180,000 bpd.

Tupras said in early June that it would lift around 140,000 bpd as of May and planned the same amount for June and July.

In the first five months of this year, Iran accounted for nearly 57 percent of Turkey's total crude imports." (Reuters, "Turkey slashes Iranian oil imports in May," 6/29/12)

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"Turkey's sole refiner Tupras has cut imports of Iranian crude by 20 percent, Turkish Energy Minister Tamer Yildiz said.

Yildiz said Turkey would continue to source 'a certain amount' of crude from its neighbour Iran but would compensate for the reduction by taking more from Saudi Arabia and Libya.

Speaking to reporters at the St Petersburg Economic Forum he said Turkey was settling oil payments to Iran in Turkish lira."  (Reuters, "Turkey says cuts Iran oil imports by 20 pct," 6/22/12)

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"Washington granted Turkey a 180-day exception from financial sanctions as a result of the initial cut made by Tupras, Turkey's sole refiner and a unit of Koc Holding. 'So Turkey now has 180 days, Tupras has 180 days to take a look at its oil situation to decide - can it reduce further, can it get to zero? - what it needs to do,' [a] diplomat said . . . Halkbank will be able to make payments to the Iranian Central Bank for oil shipments to Tupras without fear of being blacklisted by the United States. After the 180 days, the U.S. diplomat said, Washington will be looking for Tupras to make a further significant cut, without specifying how much . . . The diplomat told reporters the grace period, starting on June 11, should give Tupras time to find other suppliers and make the technical adjustments needed to handle a different mix of crude, noting that Tupras's contract with Iran ends in August." (Reuters, "U.S. presses Turkey to cut more Iranian oil imports," 6/12/12)

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"Iran's trading partners are looking for ways to avoid being hit by U.S. sanctions on Iranian oil transactions that take effect mid-year, with Turkey looking for other suppliers, India exploring options and smaller Asian countries arguing their imports from Tehran are tiny. Turkey, the fifth-largest buyer of Iranian oil, has committed to reduce its crude from Tehran by 10 percent and the country's only refiner, Tupras, a unit of Koc Holding , has pledged to cut imports by 20 percent... Twelve other countries could eventually be subject to U.S. sanctions by the end of June. A number of Asian countries, including South Korea, Singapore and Taiwan, are on Washington's watch list." (Reuters, "Iran's trade partners act toavoid U.S sanctions," 4/22/12)

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"The United States Sunday welcomed Turkey's decision to reduce its purchases of oil from neighbouring Iran by 20 percent.  "I was encouraged to hear Turkey's announcement that it will significantly reduce crude oil imports from Iran," US Secretary of State Hillary Clinton told a press conference in Istanbul where she attended a "Friends of Syria" conference.  "We certainly welcome that announcement," she added.  Turkey's national oil company Tupras Friday said it had cut its purchases of oil from Iran by 20 percent as western nations tighten sanctions against Tehran over its nuclear programme" (AFP, "US welcomes Turkey cutting Iran oil imports," 4/1/12)

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"Turkey will reduce the amount of oil it buys from Iran by around 10 percent, Energy Minister Taner Yildiz said on Friday, a week after Washington warned Iran's customers they could be subject to U.S. sanctions unless they significantly cut purchases. Turkey will partly replace the oil with 1 million metric tonnes it expects to buy from Libya, Yildiz told reporters... Turkey imports around 200,000 barrels per day of oil from Iran, representing 30 percent of its total imports and more than 7 percent of Iran's oil exports... Turkey's sole refiner Tupras, a unit of Koc Holding, said in a statement to the Istanbul stock exchange that it would cut its purchases of Iranian crude by 20 percent. Tupras is the main Turkish customer, currently buying some 30 percent of its crude oil from Iran, and it has an 9 million tonnes annual purchase contract." (Reuters, "Turkey to cut Iran oil imports, bows to U.S. pressure," 3/30/12)

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"Turkey will seek a waiver from the United States to exempt its biggest refiner Tupras from new U.S. sanctions on institutions that deal with Iran's central bank, a Turkish energy ministry official told Reuters on Wednesday... U.S. ally Turkey gets about 30 percent of its oil from neighbour Iran, and Tupras - Turkey's biggest crude oil importer, owned by its largest conglomerate, Koc Holding - is a big buyer of Iranian crude... Turkey's Energy Minister Taner Yildiz said Tupras will continue to buy oil from Iran 'until there is a new development'. 'Iran is one of the countries Tupras imports oil from. We have not received information on the new sanctions. Tupras continues to buy oil today,' Yildiz told reporters." (Reuters, "Turkey to seek US waiver on Iran oil -energy official," 1/4/2012)

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"Turkey's biggest crude oil importer Tupras has renewed its annual deal to buy crude oil from Iran for 2012, at almost the same volumes as this year, industry sources familiar with the matter said. They said Tupras had no plans for now to purchase extra amounts from the Islamic Republic... But industry sources said Tupras had no such plans, at least for now. 'I don't think there is such an intention right now,' one trading source said. 'Tupras has become much more commercial since its privatisation. If Iranian crude makes economical sense, they might take on more, if not they wouldn't, as simple as that,' he added... Tupras purchased 7.41 million tonnes of crude oil from Iran in 2010, according to a presentation on its website, which makes up for almost 38 percent of the 19.6 million tonnes of crude it refined in 2010... Another industry source said the amount that Tupras agreed to buy for 2012 was 'more or less the same' with that of this year's, which falls in line with the analysts' expectations. Tupras is Turkey's sole refiner with a total capacity of 28.1 million tonnes in four refineries. Since its privatisation bid in 2005, it is owned by Turkey's largest conglomerate Koc Holding." (Reuters, "Turkey's Tupras renews annual Iran crude oil deal," 12/21/2011)

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"Open sources reported that Tupras sold gasoline to Iran in 2010.... [It] notified GAO that it stopped selling gasoline to Iran in July 2010, following the announcement of U.S. sanctions against Iran on July 1, 2010." (U.S. Government Accountability Office, Report: "Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products between January 1, 2009 and June," September 3, 2010)

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"Tupras, Turkey's sole refiner, purchases about a third of its crude from neighbouring Iran. In June, Turkey provided about half of Iran's gasoline needs, but sales last month dropped 73 percent to $25.6 million, equivalent to about one cargo, as sanctions against Iran took effect... 'In the current situation, sales of petroleum products to Iran are not being made. Therefore, there is no possibility that our company will face any kind of sanctions,' Tupras said." (Reuters, “UPDATE 2-Tupras Q2 net misses forecast, no Iran sales,” 08/23/10)

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“Operating four oil refineries, with a total of 28.1 million tons annual crude oil processing capacity, Tüpraş is Turkey’s largest industrial enterprise. In addition, a 50,000 ton capacity petrochemical production facility, a majority stake (79,98 %) in shipping company DİTAŞ and 40% share ownership of petrol retailer Opet, creates synergies and adds value to the operations. The roots of Tüpraş, an integrated petroleum company with a large market share, corporate reliability, production complexes and affiliates, dates back to İPRAŞ (İstanbul Petrol Rafinerisi A.Ş.) founded by the U.S. Caltex Company. In 1983, İPRAŞ and three other publicly owned refineries were brought under the Tüpraş umbrella by arrangements made for a more effective operation of State Economic Enterprises” (Company website, "About Tupras")

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An article on recent further impacts of the sanctions on Iran reports, "Only three cargoes of gasoline have so far reached Iran in July, according to a shipping document seen by Reuters, much less than the seasonal norm, as new sanctions cause ships carrying fuel to be diverted."  "The document seen by Reuters showed only three cargoes of gasoline had arrived this month and were supplied by Turkish refiner Tupras and Unipec, the trading arm of China's Sinpoec." ("Iran Fuel Imports Nosedive as Sanctions Bite," Reuters, July 26, 2010).

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Following new U.S. sanctions against Iran in July 2010, Tupras is supplying Iran with about half of its gasoline imports: "Iran is depending more on friendly powers in the international arena for fuel supplies after the U.S. passed far-reaching sanctions a week ago that aim to hinder Tehran's fuel imports and deepen its international isolation.  The Islamic Republic is buying around half of its July gasoline imports from Turkey and the rest from Chinese sellers, oil traders said on Thursday, as most other suppliers have stopped selling due to the U.S. sanctions.  Turkish refiner Tupras began supplying gasoline to Iran in June after a hiatus of at least 18 months, trade sources said, just days after Turkey and Brazil brokered a nuclear fuel swap plant with Tehran designed to quell international fears over the Islamic Republic's atomic ambitions."  "Iran would import around 90,000 barrels per day (bpd) of gasoline in July, steady from June, oil traders said. It would take around nine cargoes, four or five of them from Turkey and the rest from Chinese sellers, they said."  "The limited pool of suppliers was driving up the cost of gasoline for Iran and making it harder for the Islamic Republic to buy the quantities it needs, traders said.  "These restrictive measures mean it is getting very serious for Iran," said Mehdi Varzi, a London-based energy consultant. "The oil market is a big market, and they will always find suppliers, but it is getting more difficult and it is costing more."  "Two of the gasoline cargoes coming from Turkey were scheduled to load from Turkish refiner Tupras' Izmit refinery, while two or three were scheduled to load from Tupras' Izmir refinery, sources said. The cargoes would be loaded load onto ships owned by the state energy giant National Iranian Oil Company (NIOC), they added.  A Tupras spokeswoman was not immediately available for comment on Thursday" (Webb, Simon, "Iran relies on friendly powers for fuel supplies," Reuters, July, 8 2010).

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"Turkey buys 10 billion cubic metres of gas annually from Iran, which meets about 30 percent of Turkey's domestic needs. Iran is set to receive its first shipment of gasoline from Turkey in at least 18 months in June, industry sources have said.  "Iran supplied Tupras with 3.2 million tonnes of crude in 2009, down from 7.5 in 2008 and 8.86 in 2007, according to a Tupras investor presentation. That makes Iran Turkey's second-biggest supplier after Russia (5.48m T in 2009, 6.57m T in 2008, 9.06m T in 2007)" (“Turkey's economic relations with the Middle East,” Reuters, June 24 2010).

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As of April 2010, Tupras imports 63 thousand barrels of crude oil per day from Iran. ("Iran’s Crude Oil Buyers in Europe, Asia," Reuters, April 18 2010.)
 

"Iran has offered to allocate two new natural gas fields in the country’s South Pars region to the Turkish Petroleum Corporation (TPAO) as part of efforts to strengthen ties with Turkey amid threatened UN and US sanctions over nuclear work, the Anatolia news agency quoted a TPAO official as saying Monday.Noting that technical negotiations are ongoing on joint projects in Pars, the official reiterated Turkey would not renege on a joint project with its energy ally. Iran is Turkey’s second-biggest supplier of natural gas after Russia. During Prime Minister Recep Tayyip Erdoğan’s visit to Tehran with Energy Minister Taner Yıldız last October, the two neighbors signed a number of deals to facilitate the efficient flow of gas through Turkey to Europe, including accords on allocating three of Iran’s South Pars gas fields to TPAO, allowing Iranian gas to be transported via Turkey and allowing Turkmenistan’s natural gas to be pumped to Turkey via Iran, a $3.5 billion joint development project. Turkey expects Iranian gas can help the planned Nabucco pipeline supply Europe and lessen the continent’s dependence on Russian resources. During the October visit Yıldız and his Iranian counterpart also discussed the establishment of a joint working group to study the possibilities of substituting the three less-productive fields in the South Pars region with the new ones" (Today's Zaman, "Iran Offers to Improve Energy ties with Turkey in Pars," 4/27/2010)

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Firm/country: Turkish Petroleum Company (TPAO)/Turkey;

Firm activity: Development of natural gas field in South Pars phases 22-24. Total production is projected to be 35 billion cubic meters per year;

Status: Preliminary agreement to be finalized by February 2010;

Commercial activity: Memorandum of Understanding agreement signed in 2007;

Firm comment: Contacted on February 9, 2010; no response as of March 22, 2010.

(GAO Report 2010, "Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors")

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"TPAO is already drilling deep in the Black Sea and now it plans to conquer the Middle East’s oil fields... According to the MOU signed on July 14, 2007, South Pars Field Development and Production Project, 22-23-24 Phases were reserved to TPAO with direct negotiations. Evaluations of the sites are ongoing.” (Next Generation Oil and Gas, "Eastern Promise")

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Turkey will fund its $3.5 billion investment in Iran's giant South Pars development entirely from state-run TPAO's coffers as US opposition to business links with Tehran has deterred foreign investors, Energy Ministry officials said today. (Upstream, "TPAO goes solo with $3.5bn Pars spend," 10/3/07)

"Turkish Airlines temporarily suspended flights to Iran due to the spread of coronavirus, Trend reports referring to Turkish media on Feb. 24. According to the Turkish media, flights were suspended until February 27, 2020." (Azer News, "Turkey suspends flights to Iran due to spread of coronavirus," 2/4/2020).

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"Turkish and Pegasus airlines will resume flights to Iran and Iraq on Thursday night, company sources told Reuters, after they halted flights for some 24 hours due to tensions between Iran and the United States." (Reuters, "Turkish, Pegasus airlines to resume flights to Iran, Iraq: sources," 1/9/2020).
 

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"Turkey’s flag carrier Turkish Airlines has signed a memorandum of understanding (MoU) with Kish Free Zone Organization, the free trade organization reported. In a move to attract foreign tourists to Kish Island, the Iranian resort island eyes to be promoted at an international level by a global brand." (October 18, 2017).

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Turkish Airlines runs flights from Tehran's Imam Khomeini Airport(IKA) and Tabriz (TBZ) in Iran to multiple cities in Europe. (Company Website)

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"Among the first signs that business is ready to resume is the surge in demand for flights. Austrian Airlines last week announced it will resume five weekly flights to Tehran, and its parent company Lufthansa said it’s thinking about adding more seats to its daily flights. Turkish Airlines, which serves six Iranian destinations, is seeking permission to increase frequencies." (AP, “European businesses rushing to find Iran bonanza,” 1/22/14)

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"Meanwhile, Yazıcı also highlighted how Turkish Cargo, an affiliate of Turkish Airlines (THY), had announced plans to launch cargo flights to Tehran. The THY press agency said Tehran flights were scheduled at least once per week, starting tomorrow. Turkish Cargo’s freight network now reaches 46 international destinations with the addition of Tehran, it has said." (Hurriyet Daily News, "Iran, Turkey Trade Should Reach $30 billion: Minister," 7/29/13)

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"Turkish Airlines (THY) is struggling to collect 50 million euros from Iran, a sum of money that is said to be blocked on account of difficulties in transferring money, a problem seemingly exacerbated by a shortage of foreign currency in sanctions-hit Iran Today`s Zaman reported... Payments for tickets which THY agencies sell in Iran are deposited into a bank in Iran and some time is needed to transfer this money to Turkey through the Central Bank of Iran... Talking about the sum of money that THY was due to receive from Iran, Topçu earlier said, 'There was some difficulty in transferring this sum of money to the Turkish Central Bank but we overcome that problem, but some problems still persist.' Noting that the problem in transferring money was not only peculiar to THY, and that other Turkish companies doing business with Iran are also experiencing the same problem, Güntay Şimşek, who hosts the TV program 'Airport,' commented to Today's Zaman that 'Iran has financial problems due to sanctions and you can't work with Iran without taking certain risks.'... THY is therefore a major airline for the Iranian market, with quite a few Iranians flying not only to Turkey but also to destinations in the US, Canada, Europe and even in some Asian countries, via THY... 'Iranian passengers have considerably contributed to the growth that THY has achieved in past years,' Hamid Kian, the chairman of the İstanbul-based Association of Iranian Industrialists and Businessmen (İSİAD), told Today's Zaman. A second reason that may have contributed to the figure increasing to as high as 50 million euros may be sales that THY conducted with Iran in the past few years... In addition, the value of Iran's rial has plummeted in the past year and it could be that one of the problems that the THY chairman was referring to is a demand by Iranians to use the former value of the rial instead of the current devalued one for the payment of THY's money. 'Iran wants to pay based on the former value of the rial,' Şimşek, who is also a columnist at the Habertürk daily, maintained, while Oran from the CHP had also asked, 'Is it true that the money THY is supposed to receive from Iran fell by 40 percent in value due to the exchange difference?' THY will not write off the money it is due to receive from Iran but it may just take a long time. As Şimşek, who believes that Iran is an important market which THY should not give up on, noted: 'Iran would never solve any problem at just one go. Doing business there is quite laborious.' The successful performance of THY, which has the largest destination network in the world with flights to 87 cities, has also drawn worldwide attention.German Chancellor Angela Merkel proposed to Prime Minister Recep Tayyip Erdoğan during his visit to Germany last week that Lufthansa and THY establish joint management, to which Erdoğan agreed. THY shares on the İstanbul Stock Exchange (İMKB) rose by as much as 5 percent on Monday following talks of a possible merger with German giant rival Lufthansa." (Trend, "THY struggles to free blocked 50 mln euros from Iran," 11/6/2012)

According to its form 20-F filed with the SEC for the fiscal year 2021, "During the year ended December 31, 2021, Turkcell had international roaming relationships with the following companies in Iran: Mobile Telecommunication Company of Iran, Irancell Telecommunications Services Company (“MTN Irancell”), Gostaresh Ertebatat Taliya PJS (“Taliya”) and Rightel Communication Services Company PJS (“Rightel”). Turkcell had gross revenues of approximately TRY 3.066 million and net profits of approximately TRY 1.9 million attributable to these agreements during the year ended December 31, 2021...

Turkcell has developed several digital services such as BiP, Dergilik, fizy, lifebox, TV+ etc. which are available for download free of charge and have been downloaded from within Iran. "

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According to its Annual Report filed with the SEC for fiscal year 2019: 

"During the year ended December 31, 2019, Turkcell had international roaming relationships with the following companies in Iran and Syria: TCI Mobile Company of Iran, MTN Irancell, Taliya Iran, 

Telecommunication Kish Co., Rightel, Syriatel and MTN Syria. Turkcell had gross revenues of approximately EUR 0.8 million and net profits of approximately EUR 0.5 million attributable to these agreements during the year ended December 31, 2019.

During the year ended December 31, 2019, lifecell had international roaming relationships with the following companies in Iran and Syria: MTN Irancell, Rightel, Syriatel and MTN Syria. lifecell had gross revenues of approximately EUR 0.9 thousand and no net profits attributable to these agreements during the year ended December 31, 2019.

Turkcell has developed several digital services like BiP, Dergilik, fizy, lifebox, TV+ etc. which are available for download online free of charge and have been downloaded from within Iran. The Company believes that these downloads from within Iran have generated no revenue or profits. For details regarding the risks we face with regard to our business in Iran, please refer to “Item 3.D—Risk Factors— Any instability in the political environment and/or downturn in the economy, as well as volatile international markets , in particular as a result of the ongoing COVID-19 global outbreak, in Turkey and/or internationally may have an adverse effect on our business and financial condition.”

Turkcell has voice interconnection agreements with Tadbir Ertebatat-E-Sigma (Sigma llc) of Iran. During the year ended December 31, 2019, gross revenues attributable to these agreements were approximately EUR 5.8 million, and net losses were approximately EUR 0.9 million.

Turkcell Superonline provided transit IP and leased line services through network interface agreements with Telecom Infrastructure Company of Iran (“TIC”). During the year ended December 31, 2019, gross revenues attributable to these agreements were approximately EUR 4.7 million, and net profits were approximately EUR 1.4 million. Furthermore, Turkcell Superonline has a business relationship with Teleka Maedeh Co. (Telecom Idea) based in Iran, which acts as its solution partner and agent. 

Although it is difficult to do with a reasonable degree of certainty, we have concluded that our Iranian business partners described in this section may be owned or controlled indirectly by the Government of Iran. However, to our knowledge, none of the services provided by Turkcell and our affiliates in Iran described in this section have been used by the Government of Iran to commit serious human rights abuses against the people of Iran. Furthermore, we understand that the U.S. Department of the Treasury’s Office of Foreign Assets Control has issued a general license authorizing U.S. persons to engage in certain of the activities described in this section. We and our affiliates intend to continue the activities described in this section in 2020."

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During the year ended December 31, 2017, Turkcell, Belarusian Telecom and lifecell had international roaming relationships with the following companies in Iran and Syria: MTN Irancell, Taliya Iran, KIFZO and Rightel and Syriatel and MTN Syria. (SEC Disclosure 2018)

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"Turkish mobile phone company Turkcell has taken to a South African court with its $4.2 billion lawsuit against rival MTN Group, alleging it was the victim of corruption and bribery that caused it to lose a contract in Iran. Turkcell originally pursued the case against Johannesburg-based MTN in the United States but dropped it in May after a U.S. Supreme Court ruling in a separate case made clear that U.S. courts would not have jurisdiction in a claim involving two foreign firms in an overseas dispute. In papers filed on Tuesday with the South Gauteng High Court in Johannesburg and seen by Reuters, Turkcell says that MTN, former CEO and current Chairman Phuthuma Nhleko and former executive Irene Charnley 'acted wrongfully' and interfered with Turkcell's relationship with the Iranian government over the granting of a mobile licence in 2005. Turkcell accuses Africa's largest mobile operator of 'corrupt acts' - including promises of bribes and the giving of gifts to Iranian and South African government officials - to secure the licence. It also alleges that MTN promised to influence the South African government's vote at the International Atomic Energy Agency (IAEA) on Iran's nuclear programme in 2005 and 2006. MTN said in a statement: 'Although we don't have details of the case, MTN continues to believe that there is no legal merit to Turkcell's claim and will accordingly oppose it.'" (Reuters, "Turkcell sues MTN in South Africa for $4.2 bln in Iran damages," 11/27/13)

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"The year-long internal investigation led by UK judge Lord Leonard Hoffmann dismissed allegations brought by rival Turkcell that MTN had got its Iranian licence through corrupt means. Turkcell has since dropped its US$4,2bn law suit but the sudden departure of MTN finance chief Nazir Patel has brought the matter to the fore again. According to the Sunday Times, his resignation relates to attempts to get money out of the country. But despite the cloud hanging over it , the Iranian operation has been a great investment for the mobile operator. It contributes 10% of MTN's total revenue and the company holds 47% of the Persian market . . . Those worried that the Iranian operationwill drag down MTN's valuation need not fret. 'Most valuations I've seen exclude Iran,' says Frost & Sullivan research analyst Masego Mbaakanyi. This does not mean there's no chance of exiting Iran. 'There is a possibility, if the status quo does not improve,' says Chireka. She says the decision to leave would likely be driven by its inability to bring cash back to SA. 'The problem is that's beyond its control. If it were an operational issue, it could still do something about it' . . . [If MTN chooses to sell] Chireka speculates that other contenders could be some operators in the Middle East; even Turkcell could make an offer. If Turkcell does make an offer (unlikely), don't be surprised if MTN charges it an extra R300m to recoup the costs of defending itself against Turkcell's corruption allegations ." (FM, "MTN in Iran: should they stay or go?" 8/8/13)

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"Turkcell Iletisim Hizmetleri AS (TCELL) withdrew a lawsuit against MTN Group Ltd. (MTN) over bribes MTN allegedly paid to get an Iranian mobile-phone license, citing a Supreme Court decision that bars such cases in the U.S. Turkcell, based in Istanbul, told U.S. District Judge Reggie Walton in a court filing today in Washington that it would drop the case because of the Supreme Court's ruling last month on the Alien Tort Statute. The case had been on hold while the Supreme Court decision was pending. Turkcell, Turkey's biggest mobile-phone company, sued its Johannesburg-based rival in March 2012 for $4.2 billion in damages over the loss of the Iranian license it was initially awarded. Turkcell claimed MTN, Africa's largest mobile-phone operator, bribed officials, arranged meetings between Iranian and South African leaders, and promised Iran weapons and United Nations votes in exchange for a license to provide wireless service in the Islamic Republic." (Bloomberg, "Turkcell Dismisses Suit Against MTN over Iran License," 5/1/13)

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"The government has confirmed that SA's ambassador to Iran, Yusuf Saloojee, has been suspended and recalled to SA while he is being investigated for allegedly taking bribes from cellphone company MTN to help it win an operating licence in Iran. International Relations and Co-operation Minister Maite Nkoana-Mashabane told Parliament in July that Saloojee was being investigated on the charges that arose from allegations by the Turkish cellphone company Turkcell in a US court . . . [Nkoana-Mashabane] also repeated a previous statement that another ambassador had not been suspended and wasn’t being investigated for accepting a bribe. Though this other ambassador was not named in the parliamentary questions, Maynier had identified him as Abdul Minty, SA’s ambassador to the UN in Geneva, who was SA’s representative on the International Atomic Energy Agency (IAEA) in Vienna in 2006. Turkcell, which had been awarded an operating licence in Iran before it was switched to MTN, has claimed in the US court that Minty opposed sanctions against Iran at the IAEA in 2006 because MTN had bribed the SA government to do so. Nkoana-Mashabane said earlier that Minty had been instructed by the SA government to oppose sanctions against Iran and that this instruction had nothing to do with MTN." (IOL News, "Envoy recalled over alleged MTN bribe," 10/19/12)

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"A U.S. court has delayed ruling on a $4.2 billion suit by Turkish mobile operator Turkcell against South African rival MTN Group , pending a Supreme Court decision on a separate case, the two companies said... The court has put the suit on hold, the two companies said in separate statements late on Friday, to await a Supreme Court decision on a different case using the Alien Tort Statute - the human rights law on which Turkcell's suit is based...Turkcell said in a statement it welcomed the decision, adding it believed U.S. courts had clear jurisdiction over the case. MTN said it expected Turkcell's claim to be disposed of after the Supreme Court issues its decision in Kiobel. It was not immediately clear for how long the suit would be put on hold. Turkcell said the suit would be pushed back by several months, while MTN said a decision in Kiobel was likely to happen by the end of June 2013. Several U.S. legal experts have told Reuters that Turkcell may not get much further with the suit because the case has only tenuous links to the United States. Turkcell was originally awarded a mobile licence in Iran in 2004 before a disagreement over the terms of the deal prompted an about-face by Tehran, which awarded MTN the licence in 2005. Turkcell says MTN lobbied the South African government to support Iran's nuclear programme in exchange for winning the contract, and bribed officials from both governments." (Reuters, "U.S. Court delays ruling on MTN $4.2 bln Iran suit," 10/13/2012)  

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"MTN Group Ltd. (MTN), Africa’s largest wireless operator, asked a federal judge to dismiss a lawsuit brought by Turkcell Iletisim Hizmetleri AS over a mobile-phone service deal in Iran, saying the core of the case has 'no conceivable' connection to the U.S. MTN, in a filing today in Washington, said Turkcell is improperly trying to use the Alien Tort Statute to bring a commercial dispute between a Turkish company and a South African company before a U.S. court. The 1789 law, usually cited in human rights and torture cases, gives U.S. courts jurisdiction in some instances to consider claims by foreigners for illegal conduct that occurred in another country. 'This is not a case about grave issues of universal international concern that the ATS addresses -- such as piracy and genocide,' according to MTN’s court filing. 'This case is about one thing: Turkcell trying to get paid by a nonstate actor for an Iranian cellular telephone license that it claims it lost unfairly. We respectfully submit that a U.S. district court has no business deciding this dispute.' Turkcell, which initially was awarded the Iranian mobile- phone license, sued its Johannesburg-based rival on March 28 for $4.2 billion in damages. The suit alleges MTN bribed officials, arranged meetings between Iranian and South African leaders, and promised Iran weapons and United Nations votes in exchange for a license to provide mobile-phone service in the Islamic Republic . . . 'This is far from a routine business dispute,' David Farber, a lawyer for Turkcell, said in an e-mail. 'Contemporaneous documents and recent testimony clearly demonstrate MTN’s efforts to assist Iran’s nuclear program, and its attempt to facilitate Iranian arms sales in spite of the international embargo' . . . The case is Turkcell Iletisim Hizmetleri AS (TCELL) v. MTN Group Ltd, 12-cv-479, U.S. District Court, District of Columbia (Washington)." (Bloomberg, "MTN Asks Judge To Dismiss Turkcell Lawsuit Over Iran Deal," 7/3/12)

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"Turkey's largest mobile phone operator, Turkcell Iletisim Hizmetlera AS (TKC), Thursday said it has filed a suit against South Africa's MTN Group Ltd. in the U.S., seeking damages related to the award of a license in Iran.  Turkcell alleges the South African company encouraged Pretoria to support Iran's nuclear power development program in 2005, and it claims MTN made improper payments to an Iranian and to a South African government official between 2004 and 2005 to enable the company to secure a license to operate in Iran... The allegations come as MTN's Iranian operation is the target of a U.S. lobby group, which is seeking to persuade foreign businesses to leave Iran. United Against Nuclear Iran in January sent a letter to MTN Chief Executive Sifiso Dabengwa calling for the company to pull out of the country, alleging MTN's technology is being used by Iran's government to locate and track mobile phone users." (Nasdaq, "Turkcell Files Suit Against MTN In US Courts," 3/28/12)

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The Guardian Council, comprising six Islamic clerics and six lay jurists, has in effect become an upper house of parliament. The council can vet all legislation passed by the Majlis and veto any laws that it judges do not comply with Islamic law or Irans constitution. Its influence was most apparent in 2004 and 2005 when it ratified legislation giving the Majlis retroactive veto power over two major foreign investment contracts, those of Turkcell (Turkey) and Tepe-Akfen-Vie (a joint Austrian-Turkish consortium). (Economist Intelligence Units Country Commerce Select, The operating environment: Political conditions, March 19, 2008)

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, "List of Companies Doing Business With State Sponsors Of Terror", Removed from the internet in July of 2007)

Company website lists project in Iran and list an Iran government ministry as client. (Company website)