September enforcement catch-up: four actions and where each stands in October

Four enforcement actions taken in the first week of September reached banks and manufacturers in the UAE, Türkiye and the UK. Six weeks on, one is final, one has moved to its next stage, and two are waiting on a decision that has not yet come. This catch-up sets out what each action did and where it stood on 17 October, with the document behind each.

Two Iran cases: one proposal pending, one listing in force

A proposal by the US Financial Crimes Enforcement Network (FinCEN), published in the Federal Register on 1 September, would bar US financial institutions from opening or keeping correspondent accounts for Banque Misr UAE, the Emirati arm of Egypt's state-owned Banque Misr, under Section 311 of the USA PATRIOT Act. FinCEN identified 103 potential Iranian shadow banking front companies that moved about $1.8 billion through accounts at the bank between January 2024 and June 2026, including about $520 million in the latest 12 months, the proposed rule says. It describes a bank with about $6 billion in assets and three direct US correspondent relationships. Comments closed on 1 October. A search of the Federal Register on 17 October returned the proposal and no final rule, so the special measure is not yet in force. The Treasury had announced it on 28 August.

On 4 September the Office of Foreign Assets Control (OFAC) added Istanbul's Golden Global Yatirim Bankasi and two affiliates, Golden Global Varlik Kiralama and Golden Global Portfoy Yonetimi, to its Specially Designated Nationals list under Executive Order 13902, its action notice shows. General License CC, issued the same day, allowed the wind-down of dealings with the three companies, and with any entity they own 50 per cent or more of, until 12:01 a.m. eastern daylight time on 19 September, according to its text as published in the Federal Register. That window has closed. The bank said it met all local and international compliance rules and would take legal action, Al Jazeera reported on 5 September.

OFAC has since put both cases in one frame. Its 5 October alert to foreign financial institutions lists them, with the designation of Russia's VTB Bank on 14 September, as steps in what Treasury calls Operation Economic Outcast, and warns that institutions still transacting with sanctioned Iranian banks "could be targeted at any time without advance notification". In London, HM Treasury published guidance on 23 September on its approach to licence applications from certain designated Iranian banks operating in the UK, under the title "Presumption of Denial".

Citibank London: final, and the latest UK penalty

The penalty of £4,732,830.58 that the Office of Financial Sanctions Implementation (OFSI) imposed on the London branch of Citibank, N.A. is settled: the penalty notice records that it was imposed on 11 August after settlement was agreed. It covers 970 payments worth £19,720,127.43 in breach of the Russia regulations and the Global Anti-Corruption regulations. OFSI rated the case Level 4, the highest in its seriousness framework, set a baseline of £7,888,050.97 against a statutory maximum of £9,860,063.72, and cut it by 40 per cent: 20 per cent for voluntary disclosure and co-operation and 20 per cent for settling. The notice says breaches worth about £6.9 million were not voluntarily disclosed and surfaced only after OFSI wrote to the bank. It remained the most recent monetary penalty on OFSI's enforcement page on 17 October.

Turkish auto suppliers: the investigation clock

Türkiye's Competition Board decided on 13 August (No. 26-29/831-M) to investigate 37 automotive suppliers and two associations, the TOSB Automotive Supply Specialized Organized Industrial Zone and the Automotive Suppliers Association, over suspected agreements not to hire one another's staff and exchanges of pay information, the Competition Authority announced on 7 September. The announcement records a suspicion, not a finding.

Under Article 43 of Act No. 4054, an investigation must end within six months, with one extension of up to six months, which on our count puts the ordinary deadline in mid-February 2027. The same article bars commitments for "naked and hard-core infringements", and the Authority's labour-market guidelines treat no-poach agreements as market allocation and as cartels (paragraphs 20 and 21), which leaves the companies with little room to close the case early by offering remedies. Fines for an Article 4 breach can reach 10 per cent of annual gross revenue, the Act provides.

Next steps to watch:

• A FinCEN final rule on Banque Misr UAE, which would set the date US banks must close the accounts.
• Any court filing by Golden Global against its designation.
• The next OFSI penalty notice, and whether it again turns on Russian correspondent banking.
• The Turkish Board's decision on the auto-supplier case, or a request to extend the investigation.