Most payment problems start not when funds are blocked but earlier — when a transaction goes ahead without checking who it is with and through whom it runs. Checking the counterparty and the route of the money is not a formality for the bank; it is a condition without which the deal should not even be planned.
An example that shows the scale of the risk
On 4 September 2026 the US Treasury’s Office of Foreign Assets Control added the Istanbul-based Golden Global Yatırım Bankası and two related companies to its sanctions list. According to the US side, Iranian oil revenue passed through the bank; the bank rejects the allegations. It is not a large institution — according to press reports, 35th in Türkiye by assets.
For the clients and counterparties of such a bank the consequences are immediate: transactions with it stop, and a wind-down licence with a limited term has been issued to complete those already under way. But the main point lies elsewhere. A company with no connection to Iran whatsoever could find itself in this situation simply because its partner held an account at the wrong bank.
Why the check must come before the transaction
Banks are obliged to check their clients and transactions — this is their direct duty under anti-money-laundering legislation. But a bank checks its own side. Nobody will check the counterparty, its bank and the route the money will take on your behalf. And if a problem surfaces after the transfer, the choice will no longer be between “go ahead or not” but between different ways of getting the money back — slowly and with no guarantees.
What is checked before the deal
- The counterparty — against the US, EU and UN sanctions lists and the Turkish asset-freeze decisions published in the Resmî Gazete. Not only the company but also its owners and managers are checked.
- The counterparty’s bank and the payment route — which banks the money will pass through and whether any of them are under restrictions or heightened regulatory scrutiny.
- The source of funds — documents for each source, proof of tax paid, statements with no gaps in the chain.
- Consistency of documents — the contract, the invoice and the payment reference must match word for word.
- The subject of the deal and the jurisdictions — whether there are restrictions on the goods or services themselves and on the countries the transaction passes through.
Sanctions change faster than contracts
A counterparty that is clean on the day the contract is signed may be on a list a month later. That is why a check is not a one-off step when parties first meet but a procedure repeated before every significant transaction — especially when the chain includes banks from jurisdictions that regulators are currently watching closely.
What follows from this
Check first, then negotiate the payment. It costs less than any dispute over blocked money and requires only time and the right order of steps. If the deal is international and a Turkish party is involved, the check should start before the terms are agreed, not after signing.
