Türkiye Avoids Opening US Iran Sanctions Wave as Risks Grow

    Gold bars and energy infrastructure on Istanbul’s waterfront illustrate Turkey’s exposure to new US sanctions pressure on Iran.
    US sanctions targeting Iran now reach sectors tied to Turkey’s trade, energy and financial relationship with Tehran.Photo: Bosphorus News

    Washington named no Turkish entity, but its new Iran campaign puts gas trade under scrutiny while widening sanctions risk in gold and shipping

    By Bosphorus News Economy Desk

    Türkiye was absent from the opening wave of US sanctions announced against Iran on Monday, but the new campaign widened exposure across sectors that overlap with established Turkish-Iranian trade and left Ankara's gas relationship facing a separate test.

    The US Treasury sanctioned nearly 60 companies, individuals and vessels across Iranian nuclear and missile procurement, cyber and oil-revenue networks while separately expanding the sectors that can trigger sanctions under Executive Order 13902. No Turkish entity appeared on the designation list. Washington has also told Iran's trading partners that activities it has identified as supporting Tehran must be wound down within country-specific timelines.

    Treasury Secretary Scott Bessent described the Aug. 24 package as a warning to governments and companies still doing business with Iran. He said countries were being given defined periods to close activities identified by Washington before enforcement begins, while declining to name them publicly.

    The opening list concentrated on networks operating across China, Hong Kong, the United Arab Emirates, Singapore, Switzerland and several European jurisdictions.

    The New Measures Extend Beyond the Names on the List

    The broader exposure lies in the measures issued alongside the individual designations.

    The US Treasury Department's Office of Foreign Assets Control (OFAC) identified aviation, digital assets, gold, shipping and technology as additional sectors of the Iranian economy under Executive Order 13902. Depending on the transaction and counterparty, non-US companies and individuals operating in those sectors can now face designation.

    OFAC also suspended certain general licenses under the Iranian Transactions and Sanctions Regulations and issued a separate alert on sanctions risks linked to Iranian demands concerning passage through the Strait of Hormuz.

    Türkiye's commercial relationship with Iran reaches well beyond ordinary merchandise trade, and the gold sector carries a particularly sensitive history.

    Turkish-Iranian trader Reza Zarrab pleaded guilty in 2017 to conspiring to evade US sanctions through a system involving restricted Iranian oil revenue, gold, cash and international transfers. His long-running US prosecution ended this summer when he avoided further prison time.

    The related prosecution of Halkbank was dismissed on June 17 after the bank entered a compliance agreement with the US Justice Department. The arrangement placed its sanctions and anti-money-laundering controls under outside supervision, with no financial penalty and no admission of wrongdoing.

    That history does not place Turkish companies automatically inside the new sanctions net. It does mean Washington has expanded its authorities into sectors that already sit at the center of one of the most sensitive financial disputes in US-Türkiye relations.

    Gas Is the Hardest Channel to Unwind

    Bilateral trade reached roughly $3.1 billion in the first half of 2026, about 3 percent below the same period last year, according to Turkish trade data. Iranian visitors accounted for around 5.5 percent of foreign arrivals during the first seven months, providing an important market as regional instability and inflation continue to weigh on tourism.

    The pressure was already visible before the latest sanctions campaign, with the Iran war and domestic inflation pushing down coastal hotel prices and tourism revenue.

    Energy is harder to disentangle.

    Iran supplied about 7.7 billion cubic meters of natural gas last year, equal to 13.2 percent of Türkiye's total imports, according to the Energy Market Regulatory Authority. That placed Iran fourth among suppliers behind Russia, Azerbaijan and the United States.

    The 25-year pipeline supply agreement expired at the end of July, but gas deliveries have continued.

    The legal and commercial basis has not been publicly clarified. Accounts differ over whether deliveries continue under an automatic contractual extension, force majeure provisions or compensation for volumes already paid for but not previously delivered. The expiry of the long-term Türkiye-Iran gas contract left that question unresolved.

    The new sector determinations do not themselves designate Iranian gas as one of the five newly identified sectors. Türkiye's exposure on energy instead sits inside the broader US campaign and whatever country-specific wind-down demands Washington has communicated privately.

    Gas already paid for presents a different sanctions question from a fresh payment to an Iranian counterparty, while a renewed or amended supply agreement would create another set of legal and financial issues.

    Washington has not publicly said Turkish gas imports are among the activities it expects to be wound down.

    Ankara Enters the Deadline Period With Its Own US Files Open

    Türkiye also enters the new Iran sanctions phase with two defense disputes in Washington unresolved.

    Sanctions imposed in December 2020 under the Countering America's Adversaries Through Sanctions Act (CAATSA) on the agency now officially called the Secretariat of Defence Industries (SSB) remain legally in place. OFAC continues to list the agency under its sanctioned name, Presidency of Defense Industries.

    President Donald Trump said in Ankara on July 7 that the measures would be removed, but SSB remains on the Treasury Department's current Non-SDN Menu-Based Sanctions List and no subsequent public action has removed it.

    The Treasury record continues to show restrictions imposed under Section 235 of CAATSA. Trump's political commitment has therefore not yet produced a change in the legal status of the sanctions.

    The F-35 dispute runs on a separate statutory track.

    Section 1245 of the Fiscal Year 2020 National Defense Authorization Act bars F-35 transfers to Türkiye unless the administration certifies to Congress that Türkiye no longer possesses the Russian S-400 system or associated equipment, will not reacquire it and has not obtained other Russian systems that could compromise the aircraft.

    In a July 22 response to Congress, the State Department said Türkiye had not yet met those conditions, according to reporting on the Bureau of Legislative Affairs letter. The statutory barrier remains separate from the CAATSA sanctions question.

    Removing CAATSA sanctions would therefore not, by itself, authorize an F-35 transfer.

    The Opening List Leaves the Harder Questions Unanswered

    Monday's designations left Turkish companies and state institutions untouched. The measures issued alongside them created a wider test.

    The new sector determinations directly widen exposure in areas including gold and shipping. The broader US campaign leaves Türkiye's gas relationship facing a separate question, with Washington yet to say publicly whether Turkish imports are among the activities it expects to be wound down.

    Gold carries the legacy of the Zarrab and Halkbank cases. Shipping brings the sanctions campaign into the Strait of Hormuz as Iran and Oman work on a temporary navigational corridor. Gas remains the largest direct economic exposure because of the scale of the trade and the uncertainty surrounding deliveries after the long-term contract expired.

    Bessent has also said a major sanctions announcement involving an unidentified financial institution is expected before the end of the week.

    Türkiye's absence from the Aug. 24 list settles only the first question. What matters next is which Turkish transactions Washington has identified privately, what timetable Ankara has been given and whether continuing payments connected to Iranian gas fall within it.

    Sources: Office of Foreign Assets Control, US Department of the Treasury, Energy Market Regulatory Authority, US Justice Department records, Congressional Research Service, Reuters, CNN, Bloomberg, Turkish trade and tourism data, Bosphorus News review and reporting.

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