The bank had argued it is immune from prosecution under the federal Foreign Sovereign Immunities Act because it was "synonymous" with Turkey, which has immunity under that law. The court said Halkbank was conflating its purpose - to act as a repository for the Turkish government's Iranian oil and gas proceeds - with its action, which was a scheme to participate in money laundering. The appeals court said that even if the law "confers sovereign immunity in criminal cases, the offense conduct with which Halkbank is charged falls within FSIA's commercial activities exception to sovereign immunity."