OFAC blocks the Golden Global companies under its Iran sectors order
OFAC's Iran General License CC, published on 11 September 2026, allows wind-down of transactions with three blocked Golden Global companies, including an investment bank, until 12.01 a.m. eastern daylight time on 19 September. Payments to them must go into blocked accounts.
On Friday we wrote about OFAC's suspension of several Iran aviation and shipping licenses. The same Federal Register document that carried that rule's wind-down license (91 FR 57795, published 11 September 2026) also carried a second one, Iran General License CC. It's the one more likely to matter to a bank, because it concerns a bank.
What GL CC says
OFAC issued GL CC on its website on 4 September 2026, under Executive Order 13902 of 10 January 2020, "Imposing Sanctions With Respect to Additional Sectors of Iran." It names three blocked persons:
- Golden Global Yatirim Bankasi Anonim Sirketi
- Golden Global Varlik Kiralama Anonim Sirketi
- Golden Global Portfoy Yonetimi Anonim Sirketi
It also covers any entity in which one or more of them own a 50 percent or greater interest, directly or indirectly, individually or in the aggregate. Yatirim bankasi is Turkish for investment bank.
The license authorizes "all transactions prohibited by Executive Order (E.O.) 13902" that are ordinarily incident and necessary to wind down transactions involving those persons. It runs until 12.01 a.m. eastern daylight time on 19 September 2026. Any payment to a blocked person "must be made into a blocked, interest-bearing account located in the United States."
Paragraph (b) is the usual limit: the license doesn't authorize any other transaction under E.O. 13902, including with other blocked persons, unless separately authorized.
What it doesn't do
GL CC is a wind-down license. It treats the three companies as blocked persons throughout, and it covers only transactions needed to close out existing dealings, with anything owed to them paid into a blocked account. It doesn't authorize new business.
Who it may reach
Most community banks and credit unions will never have touched a Turkish investment bank or its asset management and leasing affiliates. Exposure, if any, would come indirectly: a wire from a customer's trading partner routed through one of these companies, a correspondent relationship somewhere up the chain, or a customer holding an instrument tied to them.
The 50 percent rule widens that a little. A subsidiary owned 50 percent or more by one of the three is covered too, even if its own name never appears in the license.
What it could mean
We think the useful work here takes about an hour and has two parts.
First, check that your screening caught it. OFAC issued GL CC on 4 September, so the three names should already be in your sanctions data. Search your wire and correspondent history for "Golden Global" anyway. The names are long Turkish company forms, and a shortened or English version of a name in a free-text field may not match cleanly. If your vendor's fuzzy logic struggles with transliterated Turkish characters, this is a cheap test of it.
Second, if anything does turn up, the clock is short. The license ends at 12.01 a.m. eastern daylight time on 19 September. Anything you're holding that relates to these companies needs a decision before then, made with your BSA officer and counsel: does it fit the wind-down, and if a payment is owed to a blocked person, is the blocked account ready?
For the large majority of small institutions the honest answer will be "no exposure." We'd still write that down, with the date you checked. Sanctions questions at exams are often about how a bank keeps up, and a dated note is easy evidence.