Turkey Country Summary
Sanctions
Medium Concern
FATF AML Deficient List
Lower Concern
Terrorism
Medium Concern
Corruption
Higher Concern
US State ML Assessment
Higher Concern
Criminal Markets (GI Index)
Higher Concern
EU Tax Blacklist
Medium Concern
Offshore Finance Center
Lower Concern
Please note that although the below Summary will give a general outline of the AML risks associated with the jurisdiction, if you are a Regulated entity then you may need to demonstrate that your Jurisdictional AML risk assessment has included a full assessment of the risk elements that have been identified as underpinning overall Country AML risk. To satisfy these requirements, we would recommend that you use our Subscription area.
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Anti Money Laundering
FATF Status
Turkey is no longer on the FATF List of Countries that have been identified as having strategic AML deficiencies
Latest FATF Statement - 28 June 2024
The FATF welcomes Türkiye’s significant progress in improving its AML/CFT regime. Türkiye strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan regarding the strategic deficiencies that the FATF identified in October 2021 including by (1) dedicating more resources at the FIU to supervision of AML/CFT compliance by high-risk sectors and increasing on-site inspections overall; (2) applying dissuasive sanctions for AML/CFT breaches, in particular for unregistered money transfer services and exchange offices and in relation to the requirements of adequate, accurate, and up-to-date beneficial ownership information; (3) enhancing the use of financial intelligence to support ML investigations and increasing proactive disseminations by the FIU; (4) undertaking more complex money laundering investigations and prosecutions; (5) setting out clear responsibilities and measurable performance objectives and metrics for the authorities responsible for recovering criminal assets and pursuing terrorism financing cases and using statistics to update risk assessments and inform policy; (6) conducting more financial investigations in terrorism cases, prioritising TF investigations and prosecutions related to UN-designated groups and ensuring TF investigations are extended to identify financing and support networks; (7) concerning targeted financial sanctions under UNSCRs 1373 and 1267, pursuing outgoing requests and domestic designations related to UN-designated groups, in line with Turkey’s risk profile; (8) implementing a risk-based approach to oversight of non-profit organisations to prevent their abuse for terrorist financing, conducting outreach to a broad range of NPOs in the sector and engaging with their feedback, ensuring that sanctions applied are proportionate to any violations, and taking steps to ensure that supervision does not disrupt or discourage legitimate NPO activity, such as fundraising. Türkiye is therefore no longer subject to the FATF’s increased monitoring process.
Türkiye should continue to work with the FATF to sustain its improvements in its AML/CFT system, including by continuing to ensure its oversight of the NPO sector is risk-based and in line with the FATF standards.
Compliance with FATF Recommendations
The last follow-up Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Turkey was undertaken in 2023. According to that Evaluation, Turkey was deemed Compliant for 14 and Largely Compliant for 25 of the FATF 40 Recommendations. It remains Highly Effective for 0 and Substantially Effective for 2 with regard to the 11 areas of Effectiveness of its AML/CFT Regime.
Sanctions
Turkey, as a UN member, must adhere to sanctions imposed by the UN Security Council, which are designed to maintain international peace and security. Since 1966, the Security Council has established 31 sanctions regimes, with 15 currently active, focusing on political conflict resolution, nuclear non-proliferation, and counter-terrorism. The UN emphasizes that sanctions should be part of a broader strategy, often supporting peaceful transitions rather than being purely punitive.
Turkey faces international sanctions from the EU, US, and UK due to unauthorized drilling activities in the Eastern Mediterranean and its procurement of military systems from Russia. The EU and UK sanctions include asset freezes and travel bans, while the US has imposed sanctions on Turkey's defense industry. Recent alerts indicate that Turkey may be involved in circumventing sanctions, raising concerns about compliance and illicit activities.
Criminality
Rating |
0 (bad) - 100 (good) |
---|---|
Transparency International Corruption Index | 34 |
World Bank: Control of Corruption Percentile Rank | 35 |
Corruption remains a significant issue in Türkiye, as evidenced by its low ranking in Transparency International's Corruption Perceptions Index and inadequate government mechanisms for investigating and punishing corruption. Despite reforms aimed at increasing transparency in public procurement, critics argue that favoritism persists in awarding contracts to companies aligned with the ruling party. While Turkish law prohibits bribery and aligns with international standards, enforcement is inconsistent, and Türkiye has been placed under increased monitoring by the Financial Action Task Force due to deficiencies in its anti-money laundering and counter-terrorist financing measures.
Economy
Turkey experienced significant economic growth from 2002 to 2007 and managed the 2008-2009 global economic crisis relatively well, establishing itself as a stable emerging market. However, recent years have seen stalled economic and democratic reforms, with the Turkish lira losing substantial value and inflation rates soaring, leading to vulnerabilities in the economy. Despite a strong banking system and a favorable investment climate, challenges such as unorthodox monetary policies and external economic shocks remain significant concerns.
Turkey's investment climate is characterized by a liberal foreign direct investment (FDI) regime that treats foreign investors equally to domestic ones, although opaque rulemaking and legislative processes pose risks. In 2022, Turkey attracted $6.48 billion in FDI equity capital inflows, slightly down from $7.1 billion in 2021, while also promoting green and renewable investments through various incentives. Despite challenges such as macroeconomic instability and high inflation, Turkey's large domestic market, skilled workforce, and strategic location continue to positively influence its investment environment.

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- Risk Analysis
- Corruption
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- Executive Summaries
- Investment Climates
- FATF Status
- Compliance
- Key Findings