Clifford Chance

Second Circuit Affirms Bank Fraud Convictions in Sanctions Evasion Case

31 July 2020

On July 20, 2020, the United States Court of Appeals for the Second Circuit issued its opinion in United States v. Atilla, which upheld the conviction of Mehmet Hakan Atilla, for, among other things, conspiring to violate US sanctions and to commit bank fraud. The Atilla opinion is the first appellate court decision to affirm a bank fraud conviction in the context of a scheme to evade US sanctions. The case arose out of the US Department of Justice's investigation and prosecution of a multibillion-dollar scheme to evade US economic sanctions and launder Iranian oil proceeds through Halkbank, a Turkish state- owned bank. DOJ charged that Atilla—a former Deputy General Manager at Halkbank—and his co-conspirators helped to steer billions of US dollars to Iran by disguising Iranian oil proceeds as permissible payments and humanitarian assistance.

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