- within Tax, Finance and Banking and Cannabis & Hemp topic(s)
Occupational fraud rarely remains a purely financial issue. It can quickly become a board-level governance concern, create regulatory exposure and trigger a reputational crisis. The risks are particularly acute where misconduct involves senior employees, third-party intermediaries, public-sector touchpoints or collusion that enables perpetrators to bypass standard controls.
The Association of Certified Fraud Examiners’ (“ACFE”) 2026 Report to the Nations (“Report”) analysed more than 2,400 occupational fraud cases across 143 countries and territories between January 2024 and September 2025. These cases involved aggregate losses exceeding USD 3.4 billion. The Report estimates that organisations lose approximately five per cent (5%) of their annual revenue to fraud, representing a projected annual loss of more than USD 5.5 trillion worldwide.
For organisations operating in Türkiye, the regional findings are particularly relevant. Türkiye accounted for eight of the seventy-two reported cases in Eastern Europe and Western/Central Asia, making it the second most represented jurisdiction in the regional dataset. The region recorded a median loss of USD 170,000, compared with a global median of USD 104,000. Corruption was present in fifty-seven per cent (57%) of regional cases, while fifty-three per cent (53%) involved collusion.
Although the Türkiye-specific sample is limited, these findings highlight an important practical question for legal and compliance teams: can the organisation identify and escalate concerns, preserve evidence and address control failures before misconduct develops into a wider legal or regulatory problem?
Effective compliance in practice
The Report indicates that many fraud schemes arise from weaknesses that organisations can reasonably prevent or mitigate. A lack of internal controls, management override of existing controls and inadequate management review collectively accounted for a substantial portion of the cases examined.
Many organisations maintain codes of conduct, anti-bribery policies, whistleblowing procedures and financial controls that appear comprehensive on paper. Fraud nevertheless occurs where these measures are not properly implemented, tested or supported by a culture of accountability. The effectiveness of a compliance framework therefore depends not only on its formal design, but also on how consistently it operates in practice.
Targeted anti-fraud controls are associated with lower losses and faster detection. Their legal significance, however, extends beyond prevention. Effective monitoring and documented oversight may provide important contemporaneous evidence of the steps taken by an organisation to manage compliance risks. Where misconduct later attracts regulatory scrutiny or litigation, organisations may need to demonstrate not merely that appropriate policies existed, but that they were implemented, monitored and capable of functioning effectively when concerns arose.
Detection and investigation readiness
The Report confirms that early detection materially reduces both the losses caused by fraud and the duration of fraudulent schemes. Whistleblower reports remain the leading detection method, accounting for forty-three per cent (43%) of identified cases. Internal audit, management review, proactive monitoring and data analytics also play an important role.
Organisations should therefore combine data-driven monitoring and transaction analytics with clear escalation procedures and whistleblowing mechanisms that are accessible, trusted and actively promoted. Concerns should be assessed and escalated promptly, as delays may compromise evidence, increase losses and limit the organisation’s ability to respond effectively.
Relevant warning signs may include unusual relationships with vendors or customers, unexplained accounting adjustments, irregular procurement activity and excessive manual overrides. However, a meaningful proportion of perpetrators exhibit no observable warning signs. Red flags should therefore form part of a broader detection framework rather than serve as the sole trigger for review.
Collusion presents an additional challenge. Nearly half of the cases covered by the Report involved multiple perpetrators and were associated with greater losses and longer detection periods. Organisations should therefore consider whether apparent irregularities extend across business functions, reporting lines or third-party relationships.
Effective compliance, however, does not end with the detection of potential misconduct. Once concerns arise, internal investigations are essential to establishing the facts, assessing legal and regulatory exposure, identifying control failures and determining appropriate remediation.
This, in turn, underscores the importance of investigation readiness. Organisations rarely have the luxury of designing an investigation framework after serious allegations emerge. Decisions concerning evidence preservation, interview sequencing, reporting lines, employment measures and possible regulatory notifications may need to be made quickly.
Establishing clear protocols in advance can protect the integrity of the process and facilitate timely remediation. Independent legal oversight may be particularly important where allegations involve senior management, conflicts of interest, public-sector touchpoints or significant regulatory exposure.
Considerations for companies operating in Türkiye
Corruption, management override and third-party risk remain practical concerns for organisations operating in Türkiye, particularly in sectors involving frequent interaction with public authorities, such as infrastructure, energy, healthcare, defence, transportation, telecommunications and public procurement.
Allegations in these areas may require more than an employment-law response. Depending on the circumstances, they may necessitate an internal investigation, engagement with regulatory or judicial authorities, contractual notifications or parallel review by a multinational group’s compliance function.
Although Türkiye does not have a general corporate criminal liability regime comparable to those in certain common law jurisdictions, legal entities may nevertheless face administrative sanctions, debarment risks and serious reputational consequences arising from misconduct by employees, executives or third-party representatives acting on their behalf.
Multinational organisations should also assess potential exposure under foreign legislation, including the UK Bribery Act and the U.S. Foreign Corrupt Practices Act. Conduct occurring within Türkiye may attract scrutiny from overseas authorities where there is a sufficient jurisdictional nexus, such as a foreign parent company, securities listing, international financing arrangement or cross-border transaction. Allegations that initially appear purely domestic should therefore be assessed from both Turkish-law and international-enforcement perspectives.
The Report’s central message is clear: organisations with effective controls, trusted reporting channels and established investigation protocols are better positioned to detect fraud early, limit losses and respond credibly when misconduct arises. For companies operating in Türkiye, periodically testing fraud controls, escalation mechanisms and investigation readiness is therefore not merely a compliance exercise, but an important component of legal and corporate risk management.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
