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This analysis uncovers divergent legal outcomes of sanctions violations in Türkiye and Iran, suggesting legal frameworks and political will affect enforcement.
The paper analyzes violations of US and UN sanctions against Iran by two businessmen - one based in Türkiye (Roni Zuccuchi) and one in Iran (Barak Zenith). While both were central to the sanctions-evasion network, this study focuses primarily on the Turkish-based businessman and his interactions with Turkish state institutions. The Iranian counterpart is examined as a comparative case to demonstrate how the same illicit activity resulted in divergent legal outcomes under different governance regimes: prosecution and imprisonment in Iran versus non-prosecution in Türkiye and eventual cooperation with US authorities. The paper provides a comparative legal analysis of these divergent judicial outcomes across the three jurisdictions. The analysis centers on the indictments and trials in the US Southern District of New York, specifically United States v. Zaccuchi (15-CR-867) and United States v. Asunta (15-CR-867), examining how US courts interpreted and applied the International Emergency Economic Powers Act (IEEPA) and sanctions regulations. The paper argues that the divergent outcomes - non-prosecution in Türkiye versus conviction in the US and Iran - reveal how enforcement of transnational financial crimes is contingent not only on legal frameworks but also on the political will and institutional independence of the enforcing jurisdiction.
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Cenap Ilter (2026) studied this question.
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