Trade, Banking and Financial Risks Awaiting Türkiye
Legislation • Secondary sanctions • Banking • TRY and barter • Third-country trade
September 2026
The United States has raised its secondary sanctions against Iran (the third-country financial embargo) to the highest level through an aggressive strategy that it has newly put into effect.
Under “Operation Economic Outcast”, announced by U.S. Treasury Secretary Scott Bessent in August 2026, banks and companies in third countries that do not sever their financial ties with Iran are threatened with complete isolation from the U.S. dollar-based global financial system. He stated that the aim is to weaken Iran’s financial connections around the world and the third-country actors that keep this system functioning.
On August 30, Treasury Secretary Scott Bessent said that new secondary sanctions were expected to be announced weekly and that banks would be targeted at the initial stage. On September 1, he stated that a new Iranian bank sanction could be announced that same week and that new steps could follow in the weeks ahead.
For Türkiye, the most important consequence is not that trade with Iran will be completely prohibited overnight, but that financing and payment channels will gradually narrow. Banks, correspondent banks, insurance companies, carriers and foreign trade partners may regard Iran-related transactions as higher risk. This may lead to delayed collections, rejected transactions, higher financing costs and increased working-capital requirements for companies.
What Financial Sanctions Are Currently in Place Against Iran?
The United States had already largely restricted Iran’s access to the international financial system; however, the latest moves have initiated “precision” penalties directly targeting Iran’s front-company financial networks.
Exclusion from the dollar system (Correspondent Account Prohibition): Foreign banks that launder money on Iran’s behalf or mediate fund transfers by circumventing sanctions are prohibited from opening accounts with U.S. banks (correspondent banking). The most concrete example has been the process of excluding the UAE branches of Egypt-based Banque Misr from the dollar system in early September 2026 on the grounds that they provided USD 1.8 billion in financing to Iran’s shadow banking network. Currency exchange offices, Hong Kong- or UAE-based front companies and regime-linked cryptocurrency wallets used by Iran to circumvent sanctions are being placed under close scrutiny and their funds are being seized.
Some limited financial exemptions (licences) that had previously been permitted, such as educational transfers or personal family remittances, have also been completely suspended.
What Does It Plan to Do Next? (New Road Map)
The U.S. administration has announced that it will increase the pressure every week until Tehran is completely isolated and brought to the table for a new nuclear/military agreement. The planned steps are as follows:
“A New Bank Every Week” Strategy: Treasury Secretary Bessent announced that, in order to close the leaks in the global financial system, they would target foreign banks that form financial partnerships with Iran and announce secondary sanctions against a new bank every week.
The sanctions have been expanded beyond banks to cover third-country companies doing business with Iran in the digital assets, technology, gold, aviation and maritime transport sectors. Foreign companies that do not sever their ties with Iran in these sectors will also be blacklisted.
All countries, particularly Iran’s largest trading partners such as China, Türkiye, India and the UAE, have been given firm deadlines (a transition/remediation period) to sever their financial and commercial ties with Iran. The United States will take unilateral steps against countries that do not cease their activities during this period.
The United States has also secured the support of the European Union for this financial blockade strategy. This increases the risk that third-country banks will be excluded from both the dollar and euro systems.
What Is the Risk for Third Countries (Türkiye, China, etc.)?
This U.S. strategy presents companies in third countries with a stark dilemma: “Either you trade with Iran or you remain within the global system that uses the U.S. dollar.” Although the laws bind only U.S. companies on paper, secondary sanctions aim to make even transactions that foreign banks carry out with Iran in their own countries “commercially impossible”. Iran is attempting to respond to this pressure by completely ending the dollar dependence of its economy and moving to a “resistance economy” model.
What Will the Sanctions Pressure Planned by the United States Change?
Washington’s new approach is not a conventional embargo aimed only at Iranian oil. Its objective is to bring Iran’s foreign-exchange revenues, banking relationships, shadow financial networks, oil and petrochemical trade, maritime transport, aviation connections and facilitators in third countries into the same chain of pressure.
On August 7, 2026, the U.S. Department of the Treasury announced that it had targeted networks operating in multiple countries and imposed sanctions on intermediaries that helped Iran move hundreds of millions of dollars.
Operation Economic Outcast, announced on August 24, turned this approach into a broader state policy. The fundamental objective in the Treasury’s announcement is to cut the global economic connections that sustain the Iranian regime.
For this reason, the expected picture in autumn 2026 is not a one-off sanctions package, but periodic and expanding sanctions decisions. In addition to banks, Bessent’s statements have also raised entities linked to the Islamic Revolutionary Guard Corps (IRGC), airline leasing companies, the maritime sector and digital assets.
In this financial blockade strategy, the United States having also secured the support of the European Union does not mean a sanctions risk for other third countries, but for countries trading with Iran it means becoming subject to sanctions. This increases the risk that third-country banks, financial institutions and companies will be excluded from both the dollar and euro systems.
What Does the U.S. Embargo Mean Legally?
Although it is publicly referred to as “the U.S. embargo on Iran”, the more legally accurate expression is the expansion of the U.S. sanctions regime against Iran and, in particular, the increased risk of secondary sanctions for persons and organisations outside the United States.
Not every transaction conducted by a Turkish company with Iran is automatically prohibited under U.S. law. The risk varies according to factors such as whether the parties to the transaction appear on sanctions lists, the sector and product involved, the amount of the transaction, the payment channel, the U.S. nexus and the applicable secondary-sanctions provisions.
Nevertheless, Türkiye’s Ministry of Trade points out that persons and organisations trading with Iran may encounter problems even if they have no direct commercial transaction with the United States. The Ministry also states that U.S. sanctions may target third-country nationals and financial institutions.
Why Might Türkiye Be Affected More?
- Türkiye has a land border and long-standing commercial relations with Iran.
- Iran is an important neighbour for Türkiye in terms of energy, transit, logistics and regional supply.
- Turkish companies depend on international banking, insurance and transport systems.
- Third-country banks, trading companies and logistics centres may be used in Iran-related transactions.
- U.S. sanctions have started to target financial and commercial facilitators in third countries as well.
On August 28, 2026, the U.S. Department of the Treasury raised the process of restricting the UAE branches of Egypt-based Banque Misr from access to the U.S. financial system due to financial activities linked to Iran’s shadow banking networks. This development is significant because it demonstrates that Washington may also target third-country financial institutions connected with Iran.
Does Using TRY, Euros or Barter Eliminate Sanctions Risk?
No. Changing the currency of payment does not change the sanctioned party or goods in a transaction. Using TRY may reduce direct exposure to the dollar system; however, it does not automatically make a transaction with a sanctions-risk party, sector or activity safe.
Barter, set-off or payment in goods likewise does not create an automatic exemption. The economic reality of the transaction, the parties’ beneficial owners, the nature of the product, the end user and the transport chain must be assessed together.
Therefore, companies should not proceed on the assumption that “we do not use dollars, so sanctions do not apply”.
Does Trade Through Georgia, Kazakhstan or the UAE Resolve the Risk?
Sending goods from Iran to a third country and then to Türkiye, or making payment through a bank in a third country, does not automatically place the transaction outside sanctions. There is a legal distinction between genuine, independent third-country trade and a sham transaction designed to conceal an Iranian connection.
The targeting of facilitators in third countries in U.S. enforcement actions in 2026 has made this issue more important. Companies should therefore treat the use of a third country not as a “method of evading sanctions”, but as a compliance matter requiring an assessment of whether the genuine commercial structure is lawful.
In particular, origin, final destination, actual buyer, beneficial owner and the payment chain must be consistent with the documents. False declarations, sham invoices or structures intended to conceal the Iranian connection may also create customs, tax, money-laundering and criminal-law risks.
Checklist for Companies Importing from Iran into Türkiye
- The Iranian seller, partners and beneficial owners should be screened against sanctions lists.
- The goods’ GTIP/HS code and intended use should be examined.
- Export controls should also be assessed for dual-use goods, technology, electronics, machinery and strategic products.
- The end user and end use should be documented as far as possible.
- The sanctions compliance of the bank, carrier, insurance company and other intermediaries should be checked.
- Invoices, origin, transport and customs documents should fully reflect the commercial reality.
- Specialist legal advice should be obtained before high-value or high-risk transactions.
The Ministry of Trade’s official Iran page explains that the objectives of U.S. sanctions include restricting Iran’s oil revenues and access to foreign currency, preventing financial intermediation for sanctioned trade and reducing investment flows into Iran. The Ministry also states that significant flexibilities exist for certain food, medicine, medical-device and hygiene products classified as humanitarian trade, but that the specific transaction must be assessed separately.
What Would Be the Right Approach for Turkish Companies?
Check the customer, beneficial owner, bank, carrier, vessel/aircraft and other intermediaries.
Before making payment, confirm whether the bank will accept the Iran-related transaction.
Examine the product and determine the GTIP, intended use and dual-use product risk. Contracts, invoices, origin and transport documents should support one another. Document the end user, especially for industrial, technology and machinery products.
By making an alternative plan, reduce dependence on a single payment channel or a single bank and verify that the alternative channel is also lawful. Retain screening results, bank correspondence and commercial documents regularly.
Possible Steps the United States May Take in the Coming Period
The policy announced as of September 2026 indicates that sanctions pressure will continue. The following headings are risk scenarios based on statements by U.S. authorities; they do not mean that every future measure has been finalised.
- New secondary sanctions against third-country banks conducting transactions with Iran.
- New sanctions against trade networks carrying Iranian oil and petrochemical revenues.
- More intensive targeting of shipowners, brokers, vessels, logistics and maritime companies.
- Targeting Iran-linked digital assets and financial intermediaries.
- Sanctions against third-country companies linked to the IRGC.
- Deterring third-country banks by cutting off or restricting access to the U.S. financial system.
- Increasing political and financial pressure on G20 and other countries to reduce economic ties with Iran.
Possible Effects on Türkiye’s Economy
- Longer collection periods and increased working-capital needs for companies working with Iran.
- Higher compliance costs and transaction times for banks.
- Higher insurance and logistics costs.
- Longer supply times for some Iran-related products.
- Stronger inflationary pressure in Türkiye if energy and regional transport costs rise.
- The emergence of certain regional supply and transit opportunities for companies active in the Iranian market; however, these opportunities must be assessed together with sanctions risk.
The Main Risk for Türkiye Will Be the Freezing of Finance, Not Trade.
The United States’ 2026 strategy against Iran targets not only Iran’s oil sales but also the financial and logistical infrastructure that makes this trade possible. Operation Economic Outcast and the weekly secondary-sanctions plan subsequently announced indicate that the pressure may expand further in the coming period.
The critical point for Türkiye is not that all trade with Iran is automatically prohibited. The greater risk is that banks, insurers, carriers and foreign trade partners increasingly regard Iran-related transactions as high risk.
Therefore, the right strategy for Turkish companies is not to seek methods of circumventing sanctions, but to establish a strong transaction-by-transaction compliance system. The use of TRY, euros, barter or a third country is meaningful only when the other elements of the transaction are also legally compliant.
In autumn 2026, the fundamental question companies should ask themselves is not “Can I trade with Iran?” but “Who is the buyer in this transaction, who is the seller, who is the beneficial owner, what is the product, who is the end user, where will the payment pass through, what is the transport chain and what sanctions risk arises?”
Bibliography and Official Sources
- U.S. Department of the Treasury — Treasury Launches Unprecedented Campaign Against Iranian Regime on Economic D-Day / Operation Economic Outcast, August 24, 2026.
- Reuters — Bessent expects new US secondary sanctions weekly, aiming to increase pressure on Iran, August 30, 2026.
- Reuters — Bessent says U.S. likely to announce Iran bank sanctions this week, September 1, 2026.
- Republic of Türkiye Ministry of Trade — UN and U.S. Sanctions, Iran country page.
- Republic of Türkiye Ministry of Trade — Guide to U.S. Sanctions Against Iran in 15 Questions.
- U.S. Treasury / OFAC — Iran Sanctions Program, current sanctions lists, FAQs and licences.
Legal Notice
This study has been prepared for general information purposes. The application of sanctions, customs, export-control, MASAK, tax and foreign-exchange rules to a specific transaction may vary according to the transaction date, parties, product, amount, payment method and transport route. Current sanctions lists and specialist legal advice should also be checked for high-risk transactions.
