The Financial Action Task Force (“FATF”) published Türkiye’s 5th Round Mutual Evaluation Report (the “Report”) on 23.09.2026, assessing Türkiye’s framework for combating money laundering, terrorist financing and proliferation financing.
The Report assesses Türkiye’s technical compliance with the FATF 40 Recommendations and the effectiveness of its framework in practice as at the on-site visit conducted between 11-28.11.2025, and sets out the areas requiring further improvement as well as the key actions Türkiye is expected to implement over the next 3 years.
According to FATF’s assessment, Türkiye is rated “Compliant” or “Largely Compliant” with 38 of the 40 Recommendations. In terms of effectiveness, Türkiye achieved a “Substantial Level of Effectiveness” in 3 of the 11 Immediate Outcomes (“IOs”) and a “Moderate Level of Effectiveness” in the remaining 8. As a result of the assessment, Türkiye has been placed under enhanced follow-up and its progress will be monitored by FATF.
The key findings of the Report and the priority actions identified for Türkiye are summarised below.
Türkiye Rated Compliant or Largely Compliant with 38 of the 40 FATF Recommendations
FATF assesses countries’ legal and institutional frameworks for combating money laundering, terrorist financing and proliferation financing against its 40 Recommendations.
Under the Report, Türkiye is rated “Compliant” with 14 Recommendations, “Largely Compliant” with 24 Recommendations and “Partially Compliant” with 2 Recommendations. None of the Recommendations are rated “Non-Compliant”. The 2 areas rated Partially Compliant are Recommendation 7, concerning Targeted Financial Sanctions (“TFS”) related to proliferation financing, and Recommendation 8, concerning non-profit organisations.
In FATF’s previous mutual evaluation of Türkiye in 2019, Türkiye was rated Compliant with 11 Recommendations, Largely Compliant with 17 Recommendations, Partially Compliant with 10 Recommendations and Non-Compliant with 2 Recommendations. The Report therefore demonstrates significant progress in Türkiye’s level of technical compliance as a result of the measures adopted during the subsequent follow-up period.
Türkiye Achieved a Substantial Level of Effectiveness in 3 of the 11 Immediate Outcomes and a Moderate Level of Effectiveness in 8
FATF’s assessment covers not only the alignment of legislation with international standards, but also the extent to which the existing legal and institutional framework operates effectively in practice.
In this context, Türkiye achieved a “Substantial Level of Effectiveness” in relation to IO.1 concerning risk assessment, coordination and policy-making, IO.2 concerning international cooperation and IO.6 concerning financial intelligence.
Türkiye achieved a “Moderate Level of Effectiveness” in relation to the supervision and preventive measures applicable to the financial sector and crypto-asset service providers; the supervision and preventive measures applicable to non-financial sectors; transparency and beneficial ownership identification; money laundering investigations and prosecutions; asset recovery; terrorist financing investigations and prosecutions; and preventive measures and financial sanctions concerning terrorist financing and proliferation financing.
MASAK’s Financial Intelligence Capabilities and Inter-Agency Cooperation Found to Be Strong
One of the positive findings of the Report concerns Türkiye’s financial intelligence infrastructure. FATF states that MASAK plays a central and effective role in receiving, analysing and disseminating financial intelligence to the relevant authorities.
MASAK has direct access to more than 300 databases, including suspicious transaction reports and cross-border declarations, and FATF considers that this infrastructure enables MASAK to produce high-quality financial intelligence supporting investigations and prosecutions relating to money laundering, associated predicate offences and terrorist financing. The Report also finds that competent authorities use intelligence produced by MASAK systematically and effectively, although delays occur in the preparation of certain reports.
FATF further notes strong cooperation between MASAK, law enforcement authorities and other competent authorities in Türkiye. In terms of international cooperation, mutual legal assistance, information sharing between law enforcement agencies and financial intelligence units, and joint investigation mechanisms are used effectively. However, FATF considers that international cooperation should be used more systematically, particularly for identifying and recovering criminal assets located abroad.
Areas for Improvement Identified in the Compliance Processes of Financial Institutions and Crypto-Asset Service Providers
FATF notes that Türkiye has a comprehensive framework for the licensing of financial institutions and that financial institutions and crypto-asset service providers are supervised on a risk-sensitive basis and in particular, on-site and off-site supervision of higher-risk entities has increased significantly.
However, the Report finds that, while financial institutions and crypto-asset service providers generally have a strong understanding of money laundering risks, awareness of terrorist financing risks is more limited in sectors outside the banking sector. FATF also notes that the identification and monitoring of Politically Exposed Persons (“PEP”) is only partially effective and that deficiencies remain in the implementation of suspicious transaction reporting requirements. Low levels of terrorist financing-related suspicious transaction reporting in certain higher-risk sectors are also identified as an area requiring improvement.
Accordingly, FATF’s 3-year Roadmap calls for financial institutions and crypto-asset service providers to develop a better understanding of terrorist financing risks and mitigating measures; strengthen compliance with AML/CFT obligations, including suspicious transaction reporting, PEP requirements and customer due diligence; and ensure that sanctions for serious or systemic breaches are proportionate and dissuasive.
Stronger Supervision Expected for Lawyers, Notaries and Other Non-Financial Professions
The Report also identifies areas for improvement in the supervision of Designated Non-Financial Businesses and Professions (“DNFBP”).
According to FATF, while risk-based supervision is applied to higher-risk sectors such as dealers in precious metals and stones, real estate businesses and accountants, supervision of lawyers and notaries remains limited and is not sufficiently commensurate with the risks faced by certain entities operating in these sectors. Improving the understanding of money laundering and terrorist financing risks in non-financial sectors and addressing deficiencies in suspicious transaction reporting and internal control processes are also among the areas highlighted in the Report.
FATF calls on Türkiye to strengthen the understanding of risks and compliance with AML/CFT obligations across non-financial sectors, increase supervisory capacity and, in particular, conduct a more comprehensive assessment of the money laundering and terrorist financing risks faced by lawyers. Regular supervision of higher-risk entities in the legal and accounting sectors is also among the key actions included in the 3-year Roadmap.
Accuracy and Currency of Beneficial Ownership Information Need to Be Strengthened
FATF notes that Türkiye has adopted significant measures to prevent the misuse of legal persons for money laundering and terrorist financing purposes. The multi-layered framework comprising the Trade Registry, the Central Registry System (MERSİS) and beneficial ownership reporting requirements is identified as one of the positive aspects in this area.
Nevertheless, FATF considers that significant improvements are required to ensure that beneficial ownership information is consistently accurate and up to date. In particular, FATF calls for stronger risk-based and systematic verification of the identity of beneficial owners and of whether the person reported is in fact the ultimate beneficial owner. More effective consideration of discrepancies reported by obliged entities and broader use of data contained in the beneficial ownership register by competent authorities are also included in the Roadmap.
Prioritisation of Money Laundering Investigations Relating to High-Risk Predicate Offences Requested
The Report states that Türkiye has the capacity to conduct complex money laundering investigations and uncover criminal networks and that there are significant numbers of money laundering and predicate offence investigations, prosecutions and convictions.
However, given the size of Türkiye’s financial system, its position as a transit country, the prevalence of cash usage and the size of the informal economy, FATF considers that further operational work is required in high-risk areas other than fraud. Professional money laundering activities, the misuse of legal persons and cross-border movements of money and assets are particularly highlighted in this respect. FATF also points to the need to reduce the caseload relating to 7,248 ongoing prosecutions and 6,085 conviction cases.
The 3-year Roadmap calls for the prioritisation of complex money laundering investigations and prosecutions linked to high-risk predicate offences such as drug trafficking, smuggling and illegal betting; the development of prosecution prioritisation criteria aligned with Türkiye’s risk profile; and the effective and dissuasive application of sanctions, particularly in relation to professional money launderers and organised crime.
Identification and Recovery of Criminal Assets Abroad Identified as a Priority Area
FATF notes that Türkiye has prioritised the recovery of criminal assets at both national and operational levels and has established mechanisms for the rapid identification and tracing of such assets.
However, cases involving criminal assets located abroad are identified as a significant weakness in the system. FATF notes that the amount of assets seized and confiscated remains limited in light of Türkiye’s risk profile and that the number of detections and seizures of cross-border cash and other valuables should also be increased.
FATF therefore calls on Türkiye to strengthen its capacity to identify, trace and recover criminal assets located abroad, particularly in complex and cross-border cases, and to make more systematic and timely use of international cooperation mechanisms, including mutual legal assistance.
Expansion of the Risk-Based Approach to Combating Terrorist Financing Expected
FATF considers that Türkiye is exposed to a high degree of terrorist financing risk due to its geographical location and has developed strong policy and operational mechanisms to address these risks. Türkiye is considered to have a strong and institutionalised capacity to detect and investigate terrorist financing activities relating to threats identified in its national risk assessment.
However, FATF considers that further improvements are required in identifying financing activities connected with other terrorist organisations and networks identified through international sources and cooperation mechanisms as relevant to Türkiye’s risk profile. Trade-based terrorist financing, large-scale procurement networks, layered cross-border financial structures and complex transactions involving legal persons are also identified as areas requiring further development.
FATF’s Roadmap includes actions aimed at identifying terrorist financing risks more comprehensively in line with the current risk profile, developing capacity to investigate and prosecute complex terrorist financing cases, and increasing awareness and compliance among non-financial sectors regarding targeted financial sanctions obligations.
Türkiye Placed Under Enhanced Follow-Up Pursuant to a 3-Year Roadmap
As a result of the 5th Round evaluation, FATF has established a 3-year Roadmap setting out priority actions for Türkiye. The Roadmap calls for concrete improvements across a range of areas, including financial institutions and crypto-asset service providers, non-financial professions, beneficial ownership identification, money laundering investigations and prosecutions, recovery of criminal assets, terrorist financing and targeted financial sanctions.
Türkiye has been placed under enhanced follow-up based on the effectiveness and technical compliance results. Accordingly, Türkiye will report to FATF on its progress in implementing the actions set out in the Roadmap.
Assessment and Conclusion
FATF’s 2026 assessment demonstrates that Türkiye has made significant progress in its legal and institutional framework for combating money laundering, terrorist financing and proliferation financing compared with the previous evaluation period. Türkiye’s achievement of a Compliant or Largely Compliant rating for 38 of the 40 Recommendations, with none of the Recommendations rated Non-Compliant, demonstrates the level of technical compliance reached. However, the fact that 8 of the 11 effectiveness outcomes were assessed as having a Moderate Level of Effectiveness indicates that the focus in the coming period will shift from technical compliance with the rules towards improving their effectiveness in practice.
Against this background, supervisory and practical compliance expectations applicable to financial institutions, crypto-asset service providers and non-financial obliged entities can be expected to increase over the next 3 years. In particular, PEP controls, suspicious transaction reporting, assessment of terrorist financing risks, verification of beneficial ownership information and targeted financial sanctions are among the areas that FATF has expressly identified for further improvement.
Accordingly, entities subject to FATF-related obligations should assess not only whether their existing policies and procedures formally comply with applicable legislation, but also whether those policies and procedures are implemented effectively and on a risk-sensitive basis. In particular, customer and beneficial ownership identification, PEP controls, suspicious transaction monitoring and reporting processes, terrorist financing and proliferation financing risk assessments, sanctions-list screening and internal control mechanisms should be reviewed in light of the findings set out in FATF’s Report and 3-year Roadmap. Such a review will be important in preparing for potential new regulatory and supervisory expectations in the coming period.
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