Domestic politically exposed persons represent one of the most sensitive categories within any anti-money laundering system. Their access to state power, discretion over public resources, and ability to influence administrative and regulatory decisions make them particularly vulnerable to corruption, self-dealing, and illicit enrichment. In Türkiye, where the state plays a central role in large-scale economic activity, the risks associated with politically exposed persons are heightened by structural factors such as the size of public procurement markets, the extensive role of state-owned enterprises, the concentration of authority within the executive branch, and the importance of public permits, concessions and approvals in a wide range of sectors including energy, urban development, construction, transportation, and communications.

The purpose of this study is to examine the risks and legal challenges associated with domestic Turkish politically exposed persons in relation to money laundering. The analysis draws on international standards, including the FINTRAC framework, but focuses specifically on Türkiye’s administrative structure, legal framework, and enforcement realities. Foreign politically exposed persons and individuals serving in international organizations are intentionally excluded and will be addressed separately.

Politically Exposed Person in Turkish Law

Turkish law does not provide a single, unified public list of who qualifies as a politically exposed person. Instead, obligations arise from MASAK’s regulations on customer due diligence, the Banking Law, internal compliance systems within financial institutions, and the broader requirements of the FATF. These instruments classify a politically exposed person as someone entrusted with a prominent public function, and impose heightened due diligence obligations on financial institutions whenever such a person – or a related party – initiates or maintains a business relationship.

The domestic politically exposed person category in Türkiye is broad and reflects the structure of the state. It includes senior members of the executive, such as the president, vice president, ministers, deputy ministers and the most senior administrative officials within ministries. It also encompasses the legislative branch, including members of parliament, parliamentary committee chairs, and the leaders of political parties represented in the national assembly. Members of the high judiciary, such as those serving on the Constitutional Court, the Court of Cassation, and the Council of State, similarly fall within this category. High-ranking military officials, including the chief of the general staff and commanders holding general rank, are also considered politically exposed because of the strategic and financial significance of defense procurement. Governors, metropolitan mayors and district mayors exercise considerable authority over land use, local public finances, and permitting, and therefore also form an important part of the domestic politically exposed person universe. The senior executives and board members of state-owned enterprises and state-owned banks, which control substantial economic resources, must likewise be treated with caution. Finally, the heads and senior officials of Türkiye’s regulatory and oversight bodies, including financial, telecommunications, media, and energy regulators, hold positions that influence licensing, sanctions, and market access and are therefore exposed to corruption risks.

Family Members of Domestic Politically Exposed Persons

Family members of domestic politically exposed persons require special attention because they often hold or control assets on behalf of the politically exposed person, or participate in financial arrangements designed to disguise the origin or ownership of funds. Under international best practice, which is compatible with the risk environment in Türkiye, the individuals most likely to fall within this high-risk category include spouses or former spouses, biological or adopted children, parents, parents-in-law, and siblings. These family members may appear as shareholders of companies involved in public tenders, as nominal owners of real estate or luxury assets, or as beneficiaries of offshore financial structures. They may also serve as intermediaries through whom funds are transferred or investments are made.

A key element of the politically exposed person framework is the duration of risk. International standards generally treat the family members of domestic politically exposed persons as high-risk for five years after the person leaves office. This period recognizes that the influence and networks associated with political power do not disappear immediately. In the Turkish context, where political and economic networks often persist well beyond office terms, the practical risk exposure may be longer.

Implementation Challenges

Implementation challenges remain significant. Financial institutions often struggle to identify family relationships due to the absence of a public beneficial ownership registry and limited access to reliable data. The use of extended social and business networks, rather than immediate family members, further complicates risk assessments. Complex corporate structures and multi-layered shareholding arrangements make it difficult to determine the true beneficial owner of assets. These problems are compounded when politically exposed persons or their relatives use intermediaries, informal associates or non-transparent organizational structures to conceal their involvement.

Close Associates of Politically Exposed Persons

Close associates of domestic politically exposed persons constitute another important risk category within anti-money laundering frameworks. These individuals may not hold formal public roles or familial ties, but they can exercise significant influence or may serve as trusted intermediaries through whom politically exposed persons channel funds or acquire assets. In many jurisdictions, including Türkiye, politically exposed persons frequently conduct private business activities, charitable work, or political organizing through a close circle of long-standing associates. These associates may appear as shareholders or directors of companies receiving public tenders, as signatories to financial transactions that appear unrelated to their income, or as intermediaries who acquire property or other assets on behalf of politically exposed persons. The risk associated with a close associate remains present for as long as the relationship continues, even if the politically exposed person has left office. In practice, identifying such individuals is one of the most challenging aspects of enhanced due diligence, because the nature of these relationships is often informal and deliberately obscured.

Sectoral Realities

The risk of bribery, corruption and money laundering within the domestic politically exposed person environment in Türkiye must be understood in light of sectoral realities. Public procurement constitutes one of the largest channels of public spending, and therefore one of the most significant potential sources of illicit enrichment. Large-scale construction and infrastructure projects, urban transformation programs, energy supply contracts, and public – private partnerships often involve substantial financial flows and complex contracting structures. Discretionary authority in the approval of zoning changes, land allocations, environmental permits or investment incentives creates avenues for undue influence or preferential treatment. State-owned enterprises control major segments of the economy, including energy transmission, oil and gas operations, railways, airports and public utilities, making them especially vulnerable to internal and external manipulation. Local governments, particularly metropolitan municipalities, manage significant budgets and have authority over many forms of licensing and contracting, further amplifying risk.

Common Patterns

International studies on corruption and domestic reports from audit authorities and judicial proceedings illustrate common patterns in the behavior of politically exposed persons who engage in illicit financial activities. These patterns often include unexplained increases in wealth or lifestyle inconsistent with declared income, the rapid accumulation of real estate by the politically exposed person or by close relatives, repeated transactions with the same private contractors or consultants, and the use of intermediaries who have no discernible business rationale for involvement in major financial transfers. Risk indicators also include the establishment of multiple companies with overlapping ownership structures, the frequent use of cash-intensive operations such as construction subcontracting, and the appearance of politically exposed persons or their relatives as beneficial owners of companies that recently gained access to lucrative state contracts.

Money laundering methods used by domestic politically exposed persons in Türkiye often mirror those observed in comparative jurisdictions, though certain patterns reflect the specific dynamics of the Turkish economy. Offshore structures remain a common technique, particularly through jurisdictions that offer corporate secrecy or lenient reporting obligations. These structures can be used to hold assets or receive payments disguised as consultancy or intermediary fees. Real estate is frequently used both as a storage mechanism and as a vehicle for layering transactions. Family members, especially spouses and adult children, may acquire high-value residential or commercial property without a legitimate source of wealth. Charitable associations and foundations can also serve as vehicles for moving funds, often through donations or project-based spending that lacks adequate documentation. Cash-intensive businesses and subcontracting firms provide another avenue for disguising illicit proceeds, as invoices, wages, and material costs can be manipulated to integrate funds into the formal economy. In recent years, cryptocurrency has emerged as an additional method for transferring or concealing funds, facilitated by the ability to move value across borders with limited transparency.

Obligations Imposed on Reporting Entities

The obligations imposed on reporting entities under Turkish law are substantial and form a central part of the anti – money laundering architecture. Financial institutions are required to identify customers, verify beneficial ownership, and apply enhanced due diligence when dealing with politically exposed persons. Enhanced due diligence generally includes obtaining senior management approval before establishing or maintaining business relationships with politically exposed persons, understanding the source of funds and the nature of financial activities, and conducting ongoing monitoring to detect unusual transactions. Suspicious transaction reporting to MASAK remains a cornerstone of the system, and financial institutions must file a report whenever they suspect that the proceeds of crime may be involved or that a customer is attempting to obscure the origin of funds. These obligations extend not only to banks but also to certain non-financial businesses, including real estate agents, notaries, sports clubs, jewelers, and dealers in precious metals and stones. Practical challenges persist, however, particularly in identifying politically exposed persons accurately, verifying familial and associative ties, and tracing beneficial ownership across multi-layered corporate structures.

Criminal Liability

Criminal liability for politically exposed persons under Turkish law arises primarily from the Turkish Penal Code, which criminalizes bribery, abuse of office, embezzlement, fraudulent procurement practices, influence trafficking, and the laundering of proceeds of crime. Article 282 of the Penal Code sets out the offence of laundering criminal proceeds and imposes significant penalties on individuals who engage in acts designed to conceal the origin, nature, location or ownership of illicit assets. Politically exposed persons who misuse public authority may also face charges under provisions addressing unlawful enrichment, misappropriation of public property, and misconduct in public office. When corruption is involved, the proceeds generated through bribery or the misuse of state authority may later be laundered through financial institutions or real assets, making the politically exposed person liable for both the predicate offence and the laundering activity. Investigations involving high-ranking public officials are subject to special procedural rules under the Criminal Procedure Code, often requiring authorization from administrative or political authorities, which may delay or impede effective enforcement.

Enforcement Challenges

Despite these legal provisions, enforcement challenges remain significant. Complex patronage networks, the use of intermediaries and nominees, and the limited transparency of beneficial ownership structures contribute to difficulties in detecting and prosecuting laundering activities. Additionally, the volume of public procurement and the broad discretion available to public officials make it challenging to distinguish legitimate contracting decisions from those influenced by improper motives. The lack of a comprehensive asset declaration verification system, combined with limited institutional capacity to cross-check financial information, further weakens the effectiveness of anti-corruption controls.

Enforcement patterns related to politically exposed persons in Türkiye reveal recurring difficulties that mirror global challenges but also reflect features of the national governance environment. Cases involving senior political figures or high-ranking bureaucrats often require approval from administrative bodies or elected officials before investigations may proceed. This creates structural delays that can reduce the effectiveness of early-stage evidence collection. In some situations, political sensitivity may discourage proactive investigative steps, resulting in missed opportunities to uncover financial connections or identify beneficial ownership structures. Another challenge concerns the fragmentation of institutional responsibilities: while MASAK analyzes suspicious transaction reports and disseminates intelligence, the initiation of criminal proceedings depends on prosecutors, who may not always have the specialized capacity or resources necessary to pursue complex financial crime cases involving sophisticated laundering schemes.

Patterns Visible in Publicly Known Cases

Patterns visible in publicly known cases also illustrate the frequent reliance on family members and close associates as intermediaries. Real estate purchases in the names of spouses or adult children, transfers of company shares to siblings or cousins, and the establishment of offshore accounts or shell companies with the assistance of long-standing associates are all commonly observed structures. Procurement-related illicit schemes tend to involve subcontractors who inflate invoices or supply false documentation, with funds subsequently transferred to entities linked to politically exposed persons. The use of charitable foundations, educational associations, or cultural organizations as vehicles for money movement also appears in several cases, as these institutions often have reduced scrutiny compared to commercial entities. In some investigations, large amounts of cash were recovered, suggesting the ongoing importance of physical currency in attempts to avoid detection.

A particularly notable risk in Türkiye involves the use of state-owned enterprises, municipal subsidiaries, and public–private partnerships. These entities may operate with less transparency than central government agencies, and they may award contracts, hire consultants or engage in financial transactions without sufficient independent oversight. Politically exposed persons with influence over these institutions can, in some cases, direct funds toward companies controlled by associates or family members, thereby facilitating both the generation and laundering of criminal proceeds. Construction and infrastructure projects are especially vulnerable due to their scale, complexity, and the opportunities they provide for manipulating costs and inflating invoices.

Digital Financial Channels

Another area requiring particular attention concerns digital financial channels. Cryptocurrencies enable the rapid movement of value across borders without the use of traditional financial institutions, and anonymous or semi-anonymous wallets complicate efforts to trace ownership. Politically exposed persons or their associates may acquire digital assets using cash or through intermediaries to conceal the origin of funds. As the regulatory framework governing digital assets continues to evolve in Türkiye, the potential for misuse remains significant.

Policy Recommendations

Given these challenges, several policy recommendations emerge from the analysis of risks associated with domestic politically exposed persons. The creation of a centralized, regularly updated domestic PEP registry would improve the ability of financial institutions to identify high-risk customers. Such a registry could include information on the roles, dates of service, and relevant identifiers of public officials, as well as a clear definition of the scope of family members and close associates. Enhanced transparency concerning beneficial ownership would also significantly strengthen the overall effectiveness of the anti-money laundering framework. Requiring companies, including those involved in public procurement, to submit accurate and verifiable beneficial ownership information would make it more difficult for politically exposed persons to conceal their involvement through multiple layers of corporate structure.

Asset Declarations

Another important reform relates to asset declarations. Although some categories of public officials in Türkiye are required to file asset declarations, there is limited systematic verification of the information provided. Establishing an independent verification mechanism, supported by access to financial records and property databases, would contribute to early detection of illicit enrichment. Enhancing the audit and oversight capacity of public procurement authorities and state-owned enterprises is equally important, particularly by increasing transparency in contracting, publishing project budgets and expenditures, and conducting independent performance reviews.

Strengthening Cooperation

MASAK and other regulatory authorities would benefit from additional resources and technical capacity to analyze complex financial structures, particularly those involving international components. Strengthening cooperation with foreign financial intelligence units and law enforcement agencies would help address cross-border elements of laundering schemes. Moreover, providing specialized training to prosecutors and judges on financial crime, asset tracing and digital evidence would improve the effectiveness of legal proceedings involving politically exposed persons.

Clearer Guidance for Financial Institutions

Reforms should also include clearer guidance for financial institutions on how to identify family members and close associates of politically exposed persons. Many institutions struggle to implement enhanced due diligence due to uncertainty regarding the scope of relevant relationships. Comprehensive guidelines, combined with improved information sharing mechanisms, would support more accurate risk assessments.

Fostering a Culture of Accountability and Integrity

Finally, fostering a culture of accountability and integrity within public institutions remains essential. Internal compliance units, whistleblower protections, and mechanisms for reporting misconduct can contribute to early detection of irregularities. Civil society organizations, investigative journalists, and academic researchers also play an important role in monitoring public administration and identifying patterns of misconduct.

Conclusion

In conclusion, the risks posed by domestic politically exposed persons in Türkiye reflect structural features of public governance, economic organization and market regulation. The concentration of state authority, the scale of public procurement, and the influence wielded by key officials create environments in which illicit enrichment and money laundering can occur. The methods used to conceal criminal proceeds, whether through family members, associates, corporate structures, real estate or digital assets, are diverse and increasingly sophisticated. While Turkish law contains robust provisions addressing bribery, corruption, abuse of office and money laundering, practical enforcement remains challenging due to institutional capacity constraints, procedural requirements and limited transparency. Strengthening the anti-money laundering framework through improved information systems, enhanced beneficial ownership transparency, greater oversight of public procurement, and more effective inter-agency cooperation would significantly reduce opportunities for politically exposed persons to misuse public office for personal gain. Addressing these vulnerabilities is essential not only for the integrity of the financial system but also for public trust, democratic governance and the rule of law.