Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
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Agreements in place?
    Jersey
FATF Statement re AML Strategic Deficiencies:

Date:  16 February 2012

Turkey has taken steps towards improving its AML/CFT regime,
including by submitting CFT legislation to Parliament. Despite
Turkey’s high-level political commitment to work with the FATF to
address its strategic AML/CFT deficiencies, Turkey has not made
sufficient progress in implementing its action plan, and certain
strategic AML/CFT deficiencies remain. Turkey should work on
addressing these deficiencies, including by: (1) adequately
criminalising terrorist financing (Special Recommendation II); and
(2) implementing an adequate legal framework for identifying and
freezing terrorist assets (Special Recommendation III). The FATF
encourages Turkey to address its remaining deficiencies and
continue the process of implementing its action plan.

____________________________________________________

Sanctions:

None applicable

____________________________________________________

Offshore Jurisdiction Blacklists:

Information unavailable.

____________________________________________________

US State Department Money Laundering Report - 2012:

Turkey is an important regional financial center, particularly for
Central Asia and the Caucasus, as well as for the Middle East and
Eastern Europe. It continues to be a major transit route for
Southwest Asian opiates moving to Europe. However, narcotics
trafficking is only one source of the funds laundered in Turkey.
Other significant sources include invoice fraud and tax evasion,
and to a lesser extent, smuggling, counterfeit goods, and forgery.
Terrorist financing and terrorist organizations with suspected
involvement in narcotics trafficking and other illicit activities are
also present in Turkey. Money laundering takes place in banks,
non-bank financial institutions, and the underground economy.
Informed observers estimate as much as half of the economic
activity is derived from unregistered businesses. Money
laundering methods in Turkey include: the large-scale cross-
border smuggling of currency; bank transfers into and out of the
country; trade fraud; and the purchase of high-value items such
as real estate, gold, and luxury automobiles. Turkish-based
traffickers transfer money and sometimes gold via couriers, the
underground banking system, and bank transfers to pay narcotics
suppliers in Pakistan or Afghanistan. Funds are often transferred
to accounts in the United Arab Emirates, Pakistan, and other
Middle Eastern countries.

In June 2011, the Financial Action Task Force (FATF) added
Turkey to its list of “Jurisdictions with strategic AML/CFT
deficiencies that have not made sufficient progress in addressing
the deficiencies.” As such, FATF called on its members to
consider the risks arising from the deficiencies associated with
Turkey’s anti-money laundering/counter-terrorist financing
(AML/CFT) enforcement and implementation when conducting
business within the country. Turkey was included in the FATF
Public Statement for failure to adequately criminalize terrorist
financing and implement an adequate legal framework to identify
and freeze terrorist assets. The FATF action does not call for any
countermeasures against Turkey as a result of its status.

For additional information focusing on terrorist financing, please
refer to the Department of State’s Country Reports on Terrorism,
which can be found here: http://www.state.gov/j/ct/rls/crt/

Do Financial Institutions engage in currency transactions related
to international narcotics trafficking that include significant
amounts of US currency; currency derived from illegal sales in the
U.S.; or that otherwise significantly affect the U.S.: NO

Criminalization of Money Laundering:

“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes

Legal persons covered: criminally: YES civilly: YES

Know-your-customer (KYC) rules:

Enhanced due diligence procedures for PEPs: Foreign: NO
Domestic: NO

KYC covered entities: Banks, the Central Bank, post office banks,
and money exchanges; issuers of payment and credit cards;
lending, financial leasing, custody, settlement, and factoring
companies; securities brokers, investment partnerships, and fund
and asset managers; insurance, reinsurance and pension
companies, and insurance and reinsurance brokers; Islamic
financial houses; Directorate General of the Turkish Mint and
precious metals exchange intermediaries; auctioneers, and
dealers of precious metals, stones, jewelry, all types of
transportation vehicles, art and antiquities; lawyers, accountants,
auditors, and notaries; sports clubs; lottery and betting operators;
and post and cargo companies

Suspicious Transaction Reporting (STR) Requirements:

Number of STRs received and time frame: 6,500 from January -
October 2011

Number of CTRs received and time frame: Not applicable

STR covered entities: Banks, the Central Bank, post office banks,
and money exchanges; issuers of payment and credit cards;
lending, financial leasing, custody, settlement, and factoring
companies; securities brokers, investment partnerships, and fund
and asset managers; insurance, reinsurance and pension
companies, and insurance and reinsurance brokers; Islamic
financial houses; Directorate General of the Turkish Mint and
precious metals exchange intermediaries; auctioneers, and
dealers of precious metals, stones, jewelry, all types of
transportation vehicles, art and antiquities; lawyers, accountants,
auditors, and notaries; sports clubs; lottery and betting operators;
and post and cargo companies

Money Laundering Criminal Prosecutions/Convictions:

Prosecutions: 15 in 2009

Convictions: Three in 2009

MASAK no longer keeps statistics on prosecutions and
convictions (2009 was the last year it maintained these statistics).

Records exchange mechanism:

With U.S.: MLAT: YES Other mechanism: YES

With other governments/jurisdictions: YES

Turkey is a member of the Financial Action Task Force (FATF). Its
most recent mutual evaluation can be found here: http://www.fatf-
gafi.org/dataoecd/14/7/38341173.pdf

Enforcement and implementation issues and comments:

MASAK, the Financial Crimes Investigation Board, Turkey’s
financial intelligence unit, receives, analyzes, and refers STRs for
investigation. In 2010, 354 individuals were referred to the public
prosecutor’s office as a result of MASAK investigations into
terrorism finance.

For the past year, a draft terrorism finance law has been under
consideration by the Turkish Parliament and is scheduled to be
discussed by the Parliament’s Internal Affairs Commission in late
November 2011. It is not, however, clear when or if the draft would
reach the General Assembly. Concerns remain, that the draft
does not sufficiently address the above enumerated deficiencies
outlined by the FATF. Turkey should insure any new legislation
meets the FATF standards.

The non-profit sector is vulnerable to terrorist financing. Turkey’s
investigative powers, law enforcement capability, and supervisory
oversight are weak and lacking in all the necessary tools and
expertise to effectively counter this threat through a
comprehensive approach; all these areas need to be
strengthened. The nonprofit sector is not audited on a regular
basis for terrorist finance vulnerabilities and does not receive
adequate AML/CFT outreach or guidance from the authorities.
The General Director of Foundations issues licenses for
charitable foundations and oversees them. However, there are a
limited number of auditors to cover more than 70,000 institutions.

____________________________________________________

US State Dept Narcotics Report 2012 (introduction):

Turkey remains a transit country for illicit drug trafficking,
including heroin, methamphetamine, amphetamine, opium, and
cocaine. Heroin, opium, and cocaine are generally destined for
European markets, while methamphetamine is destined for the
Far East and amphetamine for the Middle East. The past year has
witnessed a significant increase in the production of
methamphetamine in Iran and West Africa, with a resultant
increase in seizures as Iranian methamphetamine transits Turkey.
Trends by illicit drug type are as follows:

Heroin - Turkey falls along three significant heroin trafficking
routes, namely: the Balkan route, the northern (Black Sea) route
and an eastern Mediterranean route. Heroin is smuggled over
land from Afghanistan, sometimes through Pakistan, to Iran and
then to Turkey. Most of the heroin trafficked via Turkey
ismarketed in Western Europe (where Turkish-based traffickers
control much of the heroin market), although small quantities of
heroin and opium are also smuggled from Turkey to the U.S.
Large drug trafficking organizations based in Turkey are
frequently involved in both heroin sales and transport, and
several have also been involved in a limited way in production
and/or smuggling of synthetic drugs. Some criminal elements in
Turkey reportedly have interests in heroin laboratories operating
in Iran near the Iranian-Turkish border. In recent years, however,
there appears to be more heroin, and less raw opium, arriving in
Turkey as a finished product from Afghanistan.

Methamphetamine and Amphetamine Tablets - There has been a
dramatic increase in the production of methamphetamine in Iran
and Western Africa (Nigeria & Benin). While the majority of this
drug is ultimately destined for consumption in the Far East, many
countries in the Middle East – such as Turkey and the UAE, are
major transit countries and significant seizures have been made
throughout the region. Turkey acts as a transit route for
methamphetamine from Iran for markets in the Far East and for
amphetamine tablets (“Captagon”) originating in Eastern Europe
en route to countries in the Middle East. The high purity level of
the Iranian-based methamphetamine seized is indicative of the
sophistication of the methamphetamine labs operating in Iran and
their access to bulk precursor chemicals. With the increased
availability of methamphetamine, it is feared that drug addicts in
Turkey will turn to this drug as it is less expensive than many
other illicit drugs. In 2011 (January to October) the Turkish
National Police reported 26 enforcement actions resulting in the
seizure of approximately 70 kg of methamphetamine that is known
to be / or reasonably suspected to be Iranian methamphetamine,
and the arrest of 43 suspects of various nationalities (22 Iranian,
16 Turkish, 1 Azerbaijan, 1 Nigerian, 1 German, 1 Belgian, and 1
unknown).

Cannabis - Cannabis (primarily in the form of hashish) enters
Turkey through Afghanistan, Lebanon, and Albania. There is no
appreciable cultivation of illicit marijuana in Turkey where only a
modest amount is grown primarily for local consumption.

Opium - Turkey acts as a transit route for opium originating from
Afghanistan en route to Western Europe. Opium is smuggled to
Turkey overland from Afghanistan via Turkmenistan, Azerbaijan,
and Georgia. While the Balkan Route on to Western Europe
remains heavily used, intelligence and investigations suggest that
traffickers also use a more northerly route through Azerbaijan,
Georgia, Russia, and Ukraine. The total amount of opium seized
in Turkey remains relatively small when compared to heroin
seizures.

Turkey and India are the only two traditional licit poppy-growing
countries recognized by the USG and the International Narcotics
Control Board (INCB). The Turkish Grain Board strictly and
successfully controls Turkey’s licit opium poppy cultivation and
pharmaceutical morphine production program, in accordance with
international treaty obligations, with no apparent diversion into the
illicit market.

Cocaine - An emerging trend in Turkey is the smuggling of
cocaine either directly from South America or via transshipment
locations in Western Africa. West African drug trafficking
organizations control much of the distribution with the consumer
markets of Europe being the final destination. Intelligence
provided by the Turkish National Police indicates the preferred
method for transporting cocaine to Turkey is couriers onboard
commercial aircraft. Seizures also indicate cocaine is
predominantly hidden inside passenger luggage and/or hidden on
the courier’s person. Many West African drug trafficking
organization representatives in Turkey have assimilated within the
population, marrying Turkish nationals and obtaining citizenship.

Many major drug traffickers based in Turkey are ethnic Kurds or
Iranians, and many of the same individuals and families have
been involved in smuggling contraband, especially heroin, for
years. Ethnic Kurds generally live in the areas where opiates and
cannabis enter Turkey from the east. However, in recent years,
large numbers of ethnic Kurds (including smugglers) have moved
to larger cities in Turkey and even to other countries in Europe.
Some have continued drug smuggling in their new locations. Drug
abuse remains modest in scale in Turkey compared to other
countries.

Turkey is a party to the 1988 UN Drug Convention, the 1971 UN
Convention on Psychotropic Substances, and the 1961 UN Single
convention, as amended by the 1972 protocol. Turkey is also a
party to the UN Convention against Corruption and the UN
Convention against Transnational Organized Crime and its
protocols.

For Full report, click here

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 2)

Turkey is a source, destination, and transit country for women,
men, and children subjected to sex trafficking and forced labor.
Women and child sex trafficking victims found in Turkey originate
predominately from the former Soviet Union and Eastern Europe.
Turkish women are also subjected to forced prostitution within the
country. According to regional experts, men and women from
Turkmenistan, Tajikistan, and Mongolia are subjected to forced
labor in Turkey. A recent report claimed that children involved in
the drug trade, prostitution, and pick pocketing in Turkey are
vulnerable to exploitation by criminal groups. According to a
recent report by ECPAT, some Turkish children may be subjected
to human trafficking through forced marriage.

The Government of Turkey does not fully comply with the
minimum standards for the elimination of trafficking, but it is
making significant efforts to do so. The government improved its
recognition of forced labor and domestic trafficking during the
reporting period and provided funding to the IOM-run anti-
trafficking hotline. The government did not follow through on
correcting its long-standing deficiency of inconsistent protection of
victims in Turkey, resulting in significant gaps in protection and
assistance for victims. Further, the number of victims the police
identified dropped by almost half compared to the previous year.
While it prosecuted and convicted trafficking offenders in 2010,
the government did not provide sentencing information to
demonstrate that they received adequate jail sentences.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Overview: Domestic and transnational terrorist groups have
targeted Turkish nationals and foreigners in Turkey, including on
occasion U.S. government personnel, for more than 40 years.
Terrorist groups that have operated in Turkey in the past have
included Kurdish nationalist, Marxist-Leninist, pro-Chechen, as
well as al-Qa’ida and its affiliates. Most prominent among terrorist
groups in Turkey is the Kurdistan Workers’ Party (PKK).
Composed primarily of ethnic Kurds with a nationalist agenda, the
PKK operated from bases in northern Iraq and directed its forces
to target mainly Turkish security forces. PKK activity was lower in
2009 but increased again in 2010 during a May through October
wave of violence. Other prominent terrorist groups in Turkey
included the Revolutionary People’s Liberation Party/Front (DHKP-
C), a militant Marxist-Leninist group with anti-U.S. and anti-NATO
views that seeks the violent overthrow of the Turkish state. The
Turkish Workers’ and Peasants’ Liberation Army, though largely
inactive, were still considered potential threats by the Turkish
government.

Turkish terrorism law defines terrorism as attacks against Turkish
citizens and the Turkish state. This definition hampers Turkey’s
ability to interdict, arrest, and prosecute those who plan and
facilitate terrorist acts to be committed outside of Turkey, or acts
to be committed against non-Turkish citizens within Turkey.
Nonetheless, Turkish counterterrorism cooperation with the
United States continued to develop and improve.

2010 Terrorist Incidents: PKK attacks in 2010 once again
demonstrated the nation-wide reach of the group. Typical tactics,
techniques, and procedures included ambushes on military
patrols in the countryside, improvised explosive devices (IEDs)
along known military or police routes, and bombings of both
security and civilian targets in urban areas. Three attacks
received particular attention and condemnation:

* A June bombing of a bus stop in Istanbul that killed five,
including a 17-year-old girl, and wounded 13.
* A September attack on a mini-van in Hakkari killed 10 civilians.
* A November suicide-bomb attack in Istanbul's Taksim Square,
which killed only the bomber due to an IED malfunction, injured 15
police officers and 17 civilians

Legislation and Law Enforcement: The narrow legal definition of
terrorism as an act against the Turkish state in existing Turkish
counterterrorism law poses concerns for joint and legal
cooperation. In July, the government amended the Anti-Terror
Law to prohibit prosecution of minors under the age of 15 under
the law. Minors are now tried in juvenile courts rather than in
criminal court as adults. Similarly, the Government of Turkey
amended the Law on Demonstrations, allowing first time juvenile
offenders – those not convicted of an offense involving weapons
or arson – to be subject to administrative sanctions rather than
sent to prison. These amendments resulted in more than 200
children being released from detention, a development that was
welcomed by many human rights groups and ethnic Kurds.
Human rights groups continued to allege, however, that overly-
broad application of the Anti-Terror Law was still used by the
government as a means to stifle legitimate political protest and
expression of Kurdish identity or minority viewpoints.

Countering Terrorist Finance: Pursuant to its obligations under
UNSCR 1267 and subsequent resolutions, Turkish officials
continued to circulate UN-designated names of terrorists to all law
enforcement and intelligence agencies and to financial
institutions. Turkish officials also distributed U.S.-designated
names to the security services for their awareness, although only
UN-listed names were subjected to asset freezes enforced
through a Council of Ministers decree.

In February, the Financial Action Task Force (FATF) identified
Turkey as a jurisdiction with significant anti-money laundering and
counterterrorist financing (AML/CTF) vulnerabilities, chief among
them was Turkey’s incomplete criminalization of terrorist financing
and weak national asset freezing mechanisms. In coordination
with the FATF’s International Cooperation Review Group, the
Government of Turkey made a high-level commitment to work with
the FATF and adopted an “Action Plan” which committed Ankara
to a timeline for implementing new legislation addressing the
shortcomings. On June 1, Turkey submitted a report to the FATF
plenary along with a draft law on the “Prevention of Terrorism
Financing,” which was intended to address all CTF deficiencies
identified by the FATF with respect to its criminalization of terrorist
financing and national asset freezing mechanisms. The draft law
was in the Prime Ministry at year’s end, where experts within and
outside the Prime Minister’s office were reviewing it.

Regional and International Cooperation: Turkey has played a
critical role as a friendly, neutral, arbiter in Afghanistan and
Pakistan, as a regional facilitator, International Security
Assistance Force contributor, and bilateral donor. On the
development front, Turkey has provided assistance on health,
education, and agriculture projects in Afghanistan. Turkey also
conceived and continued to support an annual meeting of the
Ministers of Interior of the Neighbors of Iraq, which focused on
supporting regional stability and security, including
counterterrorism and border security issues. Turkey ratified the
2005 Protocol on the Suppression of Unlawful Acts against the
Safety of Maritime Navigation.

Countering Radicalization and Violent Extremism: The
Government of Turkey has two significant programs in place to
counter radicalization and violent extremism. The first,
administered by the National Police, is a broad-based outreach
program to affected communities, similar to anti-gang activities in
the United States. Police worked to reach vulnerable populations
before terrorists do, alter the prevailing group dynamics and
prevent recruitment. Police also undertook social projects,
activities with parents, in-service training for officers and teachers,
and utilized social science research. Programs prepared trainers,
psychologists, coaches, and religious leaders to intervene to
undermine radical messages and prevent recruitment.

The second program, administered by the Religious Affairs Office
(Diyanet) of the Government of Turkey, promoted a Hanafi Sunni
Islam1 and worked to undercut the message of radical or violent
Islam. In Turkey, all Hanafi Sunni imams are employees of the
state's Religious Affairs office (the Diyanet). In support of its
message of traditional religious values, Diyanet's over 66,000
imams throughout Turkey conducted individualized outreach to
their congregations. Diyanet similarly worked with religious
associations among the Turkish diaspora, assisting them to
establish umbrella organizations and providing them access to
mainstream Hanafi Sunni Islamic instruction. Diyanet supported in-
service training for religious leaders and lay-workers through a
network of 19 centers throughout Turkey, and has sister-city
relationships established with religious authorities abroad.

The Government of Turkey took steps to follow up on its 2009
Democratic Initiative, also known as the National Unity Project,
designed to address the social and economic inequalities that are
seen as fueling Kurdish dissent and PKK recruitment. Turkey
devised concrete steps within the scope of the initiative to drain
the PKK’s support, by, for example, liberalizing laws governing the
use of the Kurdish language in broadcasting, education, and state
buildings; reducing the application of counterterrorism laws to non-
violent crimes; and, providing legal incentives to bring members of
the PKK who have not engaged in violence back into civil society

____________________________________________________

Links:

Financial Crimes Investigation Board

Worldwide AML Legislation (International Bar Association)
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
Y
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
White
?
Is it on EU 'white' list of equivalent jurisdictions?
N
?
Offshore Finance Center (Original IMF List)?
N
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
PC
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
N
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
N
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Terrorist Assets w/o Delay?
N
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
61 (out of
183)
56 (out of
178)
?
Ease of doing business (World Bank)
71 (out of
183)
65 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2007
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
3
12
22
11
1
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
L
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
L
 
16. DNFBP – R.13-15 & 21
N
4. Secrecy laws consistent with the
Recommendations
L
 
17. Sanctions
P
5. Customer due diligence
N
 
18. Shell banks
P
6. Politically exposed persons
N
 
19. Other forms of reporting
C
7. Correspondent banking
N
 
20. Other NFBP & secure
transaction techniques
C
8. New technologies & non
face-to-face business
P
 
21. Special attention for
higher risk countries
N
9. Third parties and introducers
N
 
22. Foreign branches &
subsidiaries
N
10. Record keeping
C
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
N
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
P
13. Suspicious transaction reporting
P
     
Institutional and other
measures
 
26. The FIU
L
 
31. National co-operation
L
27. Law enforcement authorities
P
 
32. Statistics
P
28. Powers of competent authorities
L
 
33. Legal persons –
beneficial owners
P
29. Supervisors
P
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
P
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
P
36. Mutual legal assistance (MLA)
L
 
39. Extradition
L
37. Dual criminality
L
 
40. Other forms of
co-operation
L
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
P
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
N
SR.III Freeze and confiscate
terrorist assets
P
 
SR.VIII Non profit
organisations
P
SR.IV Suspicious transaction
reporting
P
 
SR.IX Cross Border
Declaration & Disclosure
L
SR.V International co-operation
P
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if
any of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated
either Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
TURKEY
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
Y
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012