FATF Mutual Evaluation Report of Türkiye 2026

• Türkiye identifies, assesses and understands its money laundering and terrorist financing risks to a large extent including through its national risk assessment (NRA) process and related Threat and Vulnerability Working Groups.
• Türkiye needs to deepen its understanding of cross-border money laundering and terrorist financing risks, including those involving trade and smuggling, and track outcomes of policies to further ensure effectiveness of its AML/CFT strategy.
• Domestic co-operation is strong in Türkiye with frequent and positive interaction between Türkiye’s Financial Intelligence Unit (FIU), MASAK, law enforcement agencies and other competent authorities.

• Türkiye has a sound legal and institutional framework for international co-operation and generally seeks and provides mutual legal assistance, extradition and other forms of co-operation broadly in line with its risk profile. 
• Authorities provide generally good quality assistance and make effective use of formal and informal co-operation channels, including strong police-to-police co-operation, FIU exchanges, liaison officers and joint investigations, which support foreign and domestic investigations, prosecutions and asset recovery, particularly in higher-risk areas such as money laundering (ML), terrorism and terrorist financing (TF). 
• Türkiye also actively seeks international co-operation and makes broad use of co-operation mechanisms, including for beneficial ownership information and operational support. Improvements are needed in timeliness, follow-up and the more consistent pursuit of cross-border asset recovery.

• Türkiye has established a comprehensive framework for the licensing of all financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs). A solid regulatory framework was still being implemented at the time of the onsite visit for Virtual Asset Service Providers (VASPs). 
• Türkiye supervises FIs and VASPs following a risk-based approach with a significant increase in the number of AML/CFT compliance supervisions, including both off‑site and on‑site supervisory actions, particularly on high-risk entities. 
• Overall supervisors have a good understanding of ML/TF risks, although sectoral supervisors have a less developed understanding of underlying risks, which may affect effective AML/CFT supervision.
• FIs and VASPs have a generally strong understanding of the ML risks they are exposed to, while understanding of TF risks is more limited across sectors outside the banking sector. Overall, FIs and VASPs have a thorough knowledge of their AML/CFT obligations; however, important deficiencies remain in their effective implementation. In particular, Politically Exposed Person identification and monitoring is only partially effective, and shortcomings continue to be identified in suspicious transaction reporting. 
• Low levels of TF related Suspicious Transaction Reports (STRs) across several higher risk sectors suggest constraints in the detection and reporting of TF related activity relative to risk exposure.
• Türkiye has a licensing framework in place for all DNFBPs and follows a risk-based approach for the supervision of DNFBPs. All high-risk entities in the highest risk sectors (Dealers in precious metals and stones (DPMS), real estate agencies and accountants) are supervised yearly and medium risk ones have been supervised at least once over a three-year period. Supervision of the other sectors (lawyers and notaries) is scarce and not in line with the risks posed by some entities in those sectors. 

• Türkiye has a generally good and evolving understanding of ML/TF risks associated with domestic legal persons, although this understanding is less developed regarding foreign-created legal persons with sufficient links to Türkiye and foreign legal arrangements, and is uneven across competent authorities and obliged entities. 
• Türkiye has established important mitigating measures to reduce misuse of legal persons, including transparency controls through a multi-pronged framework for beneficial ownership information, controls over bearer shares and robust monitoring arrangements for associations and foundations. However, major improvements are needed to ensure basic and beneficial ownership information is consistently accurate and up to date, particularly through more systematic and risk-based verification. 
• While competent authorities generally have timely access to ownership information, use of the full range of information sources appears uneven in practice, with concentrated reliance on core registries. 

• MASAK plays a central and effective role in the receipt, analysis, and dissemination of financial intelligence. MASAK’s broad and direct access to more than 300 databases, provides a robust information base for producing high quality financial intelligence to support ML, associated predicate offences, and TF investigations and prosecutions. 
• MASAK generates balanced proactive and reactive disseminations and can identify and trace complex ML/TF schemes, including criminal networks and their financiers.
• Competent authorities make systematic and effective use of MASAK’s intelligence, which is consistently assessed as relevant, timely, and of clear added value at an operational level. However, some delays in the production of these reports were identified. 

• Türkiye’s competent authorities identify ML activities utilising a wide range of information and investigative tools. Specialised public prosecutors lead ML investigations with the support of LEAs and other relevant competent authorities (i.e., MASAK). 
• Türkiye has demonstrated its ability to conduct complex ML investigations leading the disruption of ML criminal networks by prioritising interagency and international co-operation through formal and informal channels. 
• Türkiye has investigated, prosecuted and convicted a substantial number of ML and predicate offences, with over 10 000 prosecutions, the country’s contextual and material factors increase exposure to ML risks and require further operational efforts in high-risk areas other than fraud (i.e. professional ML, misuse of legal persons, and cross-border movements).
• Despite efforts and specialised courts established in 2023, Türkiye has a backlog in the number of pending prosecutions (7 248 cases) and convictions (6 085) that needs to be addressed along with the dissuasiveness of sanctions for legal persons.

• Türkiye prioritises asset recovery as a national and operational policy objective at the highest level and has mechanisms in place to help authorities with rapid identification and tracing of criminal property and property of corresponding value. 
• Challenges when assets are located abroad represent a major shortcoming in the overall asset identification and tracing mechanism. Although Türkiye has substantially applied asset freezing as a preventive measure, the number of assets seized and confiscated remains modest.

• In response to elevated terrorist financing risks, Türkiye’s authorities have developed and implemented robust CFT policies and operational mechanisms.
• Türkiye presents strong and institutionalised capabilities to identify and investigate TF in relation to those terrorist organisations identified as TF threats in its national risk assessment, but challenges remain in identifying TF activity involving other terrorist organisations and networks identified through international sources and co-operation channels as relevant to its TF risk exposure. 
• Türkiye implements TF related targeted financial sanctions (TFS) without delay to some extent yet not systematically. Türkiye has made use of its TF TFS framework to a large extent to mitigate its TF risks, demonstrating its ability to target assets of individuals and entities related to terrorist organisations, including UN designated terrorist organisations. 
• FIs and VASPs are generally aware of their TF TFS obligations and complying to a certain extent while DNFBPs have a lesser understanding and compliance with those obligations. Supervisory activities on TF TFS are conducted following a risk-based approach.
• Türkiye has an overall good understanding of PF risks yet risks related to potential sanctions evasions via the misuse of legal persons, including foreign ones, are understood to a lesser extent and could hinder Türkiye’s ability to deter PF risks to some extent. 

Following the assessment, Türkiye received a roadmap of Key Recommended Actions to complete within three years. These include enhancing understanding of TF risks and related mitigating measures by reporting entities, prioritising money laundering investigations and prosecutions related to certain high-risk predicate offences such as drug trafficking, smuggling and illegal betting,  and  improving the identification, investigation and, where appropriate, the pursuit of prosecutions and convictions linked to the full range of TF threats aligned with its up-to-date risk profile.

Based on Effectiveness and Technical Compliance Ratings, Türkiye is placed in enhanced follow-up. Türkiye will report back to the FATF on its progress.