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AML regulations in Turkey Law Firm 0555

AML regulations in Turkey




Whilst AML regulations in Turkey is not a member of the EU, as a candidate country, it has adapted its money laundering legislation in line with developments in EU Directives. Turkish laws have not been officially harmonised with the Fourth EU Money Laundering Directive. However provisions from the Fourth Directive have been adopted such as:




How many suspicious transactions have been reported to the central authority by lawyers in the last 12 months? DFCIB publishes an annual activity report. The Anti money laundering regulations in Turkey annual report for 2018 has not been published yet. However, according to the 2017 report, there were a total of 27,209 suspicious transactions reported to the DFCIB. However the report does not refer specifically to the number of reports submitted by lawyers. We note from the FATF report of October 2014 that it records only one suspicious transaction report filed by Lawyers in 2014. Therefore (extrapolating from this) we believe since then the number of suspicious transactions reported by Lawyers will be relatively low and the vast bulk of reporting derives from financial institutions.




The other important element of KYC requirements in Turkey anti-money laundering measures is suspicious transaction reports. ("STR") The suspicious transaction occurs if there is any suspicion on the assets subject to the transaction that they have been obtained illegally or used for illegal purposes. Besides, transactions, where obliged parties cannot identify the customers or receive sufficient information about the purpose of the business relationship can be considered suspicious transactions. As per the anti-money laundering legislation, the obliged parties shall report all suspicious transactions, regardless of their amount, to MASAK.




As explained above, money laundering operations usually takes place in numerous countries. For this reason, it became necessary to take precautions internationally. The first written international document regarding money laundering is the UN Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (“Vienna Convention”) dated 19 December 1988. As the name suggests its sole aim was to fight drug smuggling. However, its successors have adopted the same principles in Personal Data Protection in Turkey terms of preventing money laundering.




Are CDD requirements for different entity types specified by legislation (or is a true risk-based approach applied). If yes, please describe Yes, CDD Requirements for different entity types are specified by legislation as follows: natural persons, legal entities registered with the trade registry, associations and foundations, trade unions and confederations, political parties, non-resident legal persons, unincorporated organizations and public/governmental institutions.




The United Nations Convention Against Corruption was ratified by Turkey on 18 May 2006. Having adopted similar principles, it emphasized communication and collaboration between contracting states’ judicial and financial authorities, and law enforcement agencies.




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