We first started noticing major 'odd' exports of gold from Turkey to Iran in May 2012. Turkey’s trade balance fluctuated wildly as gold stocks flowed out of the country in bursts.

“Turkey’s going to continue it,” the Turkish economy minister said. “If those casting aspersions on the gold trade are searching for immorality, they should take a look in the mirror.”

Then, in 2014, we discussed Turkey's "200 tons of secret gold" trade with Iran detailing how a complex network that spanned Turkey, China, Dubai and Iran was used to skirt US sanctions on energy exports from Iran.

The operation featured an Iranian-born businessman who liked fast horses, faster cars and the fastest planes. His unique skill: Getting gold into sanctions-encircled Iran. Enough gold that for a time he became the government’s key instrument in improving Turkey’s irksome economic imbalance.

At the time, the plot revealed what one observer called, "one of the most complex illicit finance schemes [prosecutors] have seen."

In 2017, the man at the center of the scheme, Reza Zarrab, was arrested (and briefly disappeared) and was tied to Turkey's president.

“Zarrab is thought to have been close to the Erdogan family and, indeed, he was given Turkish citizenship, alongside Iranian. This is a real stress point."

Zarrab pleaded guilty in October 2017 and turned against Mehmet Hakan Atila - a director at Turkey’s Halkbank - who was convicted on Jan. 3, 2018, and after serving a total 32 months behind bars was returned to Turkey and has since become the head of the Istanbul stock exchange.

And since then "one of the biggest money-laundering schemes ever" has disappeared from the headlines... until now.

Thanks to a massive leak of more than a million documents from a British offshore shell company provider, think Panama Papers 2.0, we now learn exactly how Iran’s national oil company and its subsidiaries hopscotch the globe, with the help of intermediaries, in search of tax havens that help it try to wriggle free from the grip of crippling U.S.-led sanctions.

As McClatchy reports, the massive data set of communications, incorporation certificates and other documents was leaked to journalists, and after months of collaboration, news organizations across the globe are collectively publishing stories starting this week under the title #29Leaks.

Included in the voluminous Formations House documents is a register of shareholders in an offshore company called Naftiran Intertrade Company Ltd, or NICO. This list of shareholders was attached to an email from December 2014, declaring the state-owned National Iranian Oil Company as the overarching shareholder and having complete control over NICO.

Also attached was a register of NICO directors listing five Iranian nationals.

NICO, the gasoline import arm of the state oil company, came to renewed international attention in March 2016 after the arrest at Miami International Airport of Reza Zarrab.

He flew to Florida to visit Disney World and on that trip was charged with conspiring to evade U.S. sanctions through an elaborate gold-for-gas scheme between Turkey and Iran, and using global banks to process transactions on behalf of Iran.

Prosecutors contend that Zarrab and a co-defendant, Mehmet Hakan Atila, who was a director at Turkey’s Halkbank, schemed to help Iran skirt U.S. sanctions by trading Turkish gold for oil and natural gas. Using companies across the globe, they facilitated $20 billion worth of transactions.

“High-ranking government officials in Iran and Turkey participated in and protected this scheme,” the Justice Department in Oct. 15, 2019. statement announcing charges against Halkbank, which incriminated Zarrab. “Some officials received bribes worth tens of millions of dollars paid from the proceeds of the scheme ... and to help shield the scheme from the scrutiny of U.S. regulators.”

Shortly after his arrest, Zarrab, who is married to a Turkish pop star and has citizenship in Iran as well as Turkey, implicated Turkish President Recep Erdogan as having approved the operation.

Zarrab was represented briefly by Rudolph Giuliani, who has since become President Trump’s personal attorney. Zarrab was also a focus of Special Counsel Robert Mueller III’s prosecution of Trump adviser Lt. Gen. Michael Flynn for lying under oath the FBI. Mueller looked at Flynn’s lobbying for Turkey.

Additionally, the leaked documents tie the mid-October, six-count indictment against Halkbank for fraud, money laundering and sanctions-evasion was tied to NICO and the state oil company.

Prosecutors said that bank has been the “sole repository of proceeds from the sale of Iranian oil” to Turkey and also cited Zarrab transactions involving NICO.

The leaked new documents expose this chain of communications between a Dutch offshore services provider, Dennis Vermeulen of INCO Business Group, Formations House employees Oliver Hartmann (aka Syed Rizwan Ahmed) and Charlotte Pawar, and Farhad Dizadji, owner and senior partner of London-based accounting firm Roberts & Partners.

“Just like we’ve seen in the Halkbank scandal, entities are eager to exploit the secrecy afforded by anonymous shell companies to evade U.S. sanctions on Iran, undermining our national security,” the top Democrat on the Senate Finance Committee, Oregon’s Ron Wyden, said in a statement on the Formations House leak. “Ending anonymous shell companies would make it easier for law enforcement to ‘follow the money’ when investigating complex financial crimes like sanctions evasion.”

By constantly switching domiciles, NICO may have sought to ease political pressures, according to a former senior official at the U.S. Treasury Department. The official previously worked on Iran sanctions and international money-laundering investigations and requested anonymity in order to discuss non-public matters.

So, in conclusion, we now have two facts confirmed - trust no one and nothing; and gold is money. Given the level of grift here, we wonder just how long before more incriminating evidence is leaked about how Democrats have benefited greatly from Ukraine deals.