Türkiye’s gold sector spans the full value chain: exploration and mining, primary production and refining, import and export, exchange trading and custody, jewelry manufacturing, and retail. Public authorities coordinate and supervise different links in this chain  – MAPEG for mining rights and operations, the Ministry of Trade and Customs for cross-border movements and anti-smuggling enforcement, Borsa İstanbul for market admission, custody, and first domestic trades, MASAK for anti–money laundering (AML/CFT) obligations, and the Turkish State Mint for coinage. Private-sector participants include licensed mining companies and subcontractors, refineries and assay services, Borsa İstanbul member institutions (banks, precious-metals companies, certain currency offices and brokerages), secure logistics and vaulting providers, jewelry manufacturers and wholesalers, retailers, and integrated groups such as Ahlatcı Holding.

The legal landscape combines Mining Law No. 3213 (licensing and permits), market rules of Borsa İstanbul (admission, custody, first trade), AML/CFT Law No. 5549 with MASAK secondary measures (CDD/EDD, STR, recordkeeping), Customs Law No. 4458 and Anti-Smuggling Law No. 5607 (seizure and penal exposure), and monetary/FX rules under Law No. 1567/Decree No. 32. Enforcement attention has intensified in recent years due to refinery-focused investigations, smuggling allegations, import-policy levers that affect bullion flows, and heightened environmental and safety scrutiny in mining. Sound operation in this environment depends on rigorous licensing, market compliance, AML controls, and cross-border trade governance to manage legal, operational, and reputational risk.

1. Türkiye’s gold market at a glance

1.1. Value chain and material flows

Gold moves through a continuous chain: exploration and mining; on-site processing to ore concentrate or doré; transportation to refineries; refining into standard or non-standard bars and granules; import or export as permitted; first domestic trade and custody on the exchange; wholesale allocation to banks, precious-metals companies and jewelry manufacturers; transformation into coins, jewelry and small bars for retail and savings. A parallel recycling loop returns scrap from the jewelry and retail channel back to refineries, which is a significant source of domestic supply during periods of high consumer selling.

1.2. Market venues and custody

Borsa İstanbul’s Precious Metals and Precious Stones Market functions as the central venue for admission of standard bullion, first domestic trades and organized custody. Imported standard bars that meet acceptance criteria are typically delivered into exchange custody before first sale. Settlement and delivery occur through exchange systems via member institutions. Non-standard materials (granules, non-standard bars, doré) generally require refining or conversion before entering organized trading channels.

1.3. Products and forms of gold

Standard bars are exchange-accepted or internationally recognized bars that meet fineness and weight specifications and can be delivered into exchange custody. Non-standard bars and granules circulate between recyclers, manufacturers and refineries prior to standardization. Doré is semi-refined metal from mines requiring further refining. Scrap consists of jewelry and retail items re-melted and refined back into bullion. Minted coins, including Republican gold coins produced by the Turkish State Mint, serve a large retail and savings market distinct from exchange bullion. Small bars and investment pieces are packaged retail products sold by banks, jewelers and authorized dealers. Paper and account forms include bank gold deposit or investment accounts, participation bank products, exchange-traded positions and structured notes referencing gold.

1.4. Participants across the chain

Upstream participants include licensed mining companies and their subcontractors, drillers, geological and environmental consultants, and assay labs serving exploration. Midstream participants include refineries, independent assay and quality-control services, industrial recyclers, and secure logistics and vaulting providers. Market and intermediation participants include Borsa İstanbul member institutions (banks, precious-metals companies, certain currency offices and brokerages), clearing and settlement infrastructure, and authorized importers and exporters. Downstream participants include jewelry manufacturers, wholesalers, exporters, retailers and e-commerce sellers, as well as banks and participation banks offering gold accounts and investment products. Public institutions with operational interfaces include MAPEG for mining rights and operations, the Ministry of Trade and the customs administration for cross-border movement and border enforcement, Borsa İstanbul for market admission, custody and first trades, MASAK for AML/CFT supervision of obliged parties, and the Turkish State Mint for coinage.

1.5. Import and export mechanics

Eligible importers and exporters are typically member institutions of the exchange that meet regulatory and operational requirements. Imported standard bullion is consigned to exchange custody and first traded domestically through the organized market. Policy levers – such as import quotas, delivery-to-vault deadlines and documentation requirements – shape the timing, cost and feasibility of inbound flows. Exports follow customs formalities and exchange rules where applicable, with logistics, insurance and assay documentation forming part of the chain-of-custody package.

1.6. Price discovery and risk management

Domestic pricing references international benchmarks adjusted for costs, taxes, policy constraints and local supply-demand dynamics. Banks and manufacturers use exchange trading, inventory management and back-to-back hedging to manage price and basis risk. Participation banks and conventional banks offer gold accounts that convert retail savings into system liquidity; manufacturers manage “working stock” through leasing, consignment and recycling arrangements. Route and security risks are mitigated through vetted logistics providers, insurance cover and exchange custody.

1.7. Regulatory touchpoints along the chain

Mining and primary production are licensed and supervised under the mining regime and associated environmental and land-use permits. Cross-border movement of bullion, doré and semi-processed forms is subject to customs law, anti-smuggling provisions and specific procedural rules for eligible importers/exporters. Exchange participation rules govern who may trade, how delivery and custody occur, and what documentation accompanies standard bars. AML/CFT obligations apply to dealers, refiners, banks and other obliged parties, requiring customer due diligence, beneficial-owner verification, suspicious-transaction reporting, recordkeeping, training and internal controls.

1.8. Current operational themes

Tighter policy management of bullion imports affects timing and availability of standard bars for domestic users. Supervisory attention to refinery practices, documentation integrity and supply-chain assurance has increased, including deeper reviews of assay results, chain-of-custody and eligibility of sources. Border enforcement focuses on undeclared or misdeclared precious metals, purity and weight discrepancies, and misuse of passenger allowances. In mining, environmental and safety expectations have intensified, with closer scrutiny of permitting, tailings management and incident response. Across the market, counterparties face higher expectations on beneficial-owner transparency, sanctions screening, transaction monitoring and rapid response to information requests from supervisors and law-enforcement agencies.

1.9. Practical implications for market participants

Market participants should maintain complete and reconcilable documentation from mine or scrap source through refinery to exchange custody or retail sale. Counterparties’ licensing, exchange membership and refinery accreditations should be verified before transacting. Bank and dealer procedures should align with AML/CFT requirements, including risk-based enhanced due diligence for higher-risk profiles and politically exposed persons. Logistics should be structured with a clear chain-of-custody, bonded storage where appropriate, and timely delivery to exchange vaults. Hedging and inventory controls should be used to manage price exposure without compromising documentation integrity.

2. Who’s Who – Actors Across the Value Chain

2.1. Mining and upstream exploration

MAPEG licenses and supervises exploration and operation rights. Rights holders are Turkish and international mining companies holding exploration (arama) and operation (işletme) licenses. Specialists include drilling contractors, geologists, environmental and social consultants, mine planners, metallurgists, and on-site assay labs supporting exploration and feasibility. Public interfaces include environment and climate authority for EIA, forestry and land administrations for access and permits, and provincial governorates for local compliance and inspections. Core responsibilities include compliance with license terms and permit conditions, reporting to MAPEG, worker safety and environmental management, and ore traceability for eventual doré shipments.

2.2. Primary processing and refining

Refineries are industrial facilities converting doré, scrap and non-standard material into standard bars and granules accepted by organized markets, maintaining accredited assay labs and quality systems. Industrial recyclers aggregate and melt jewelry and industrial scrap before refinery intake and maintain purchase records and chain-of-custody. Independent assay services provide third-party verification of fineness, weight and product conformity used by refineries, traders and customs. Core responsibilities include product conformity, emissions and waste controls, documentation of inputs and outputs, customer due diligence on suppliers, and audit readiness.

2.3. Import and export gatekeepers

Authorized importers and exporters are exchange member institutions permitted to bring standard bullion into the country and consign it to exchange custody; they manage export formalities for refined products and jewelry. Public authorities include the Ministry of Trade and customs administration for declarations, inspections, valuation, and anti-smuggling enforcement, applying risk-based controls at airports, ports and land borders. Customs brokers and bonded facilities prepare submissions, ensure tariff and documentation accuracy, and manage bonded storage and release. Core responsibilities include accurate declarations, compliance with eligibility and delivery-to-vault rules, insurance and security for shipments, and retention of chain-of-custody and assay records.

2.4. Market trading, custody and settlement

Borsa İstanbul Precious Metals and Precious Stones Market sets participation, trading, delivery and custody rules for standard bullion and oversees organized custody. Takasbank and exchange systems handle cash and metal settlement, collateral and margining where applicable. Intermediary institutions include banks, precious-metals companies, certain currency offices and brokerages executing client and proprietary trades under member obligations. Core responsibilities include adherence to market rules, timely settlement and delivery, reporting and surveillance cooperation, and maintenance of client identification and suitability files.

2.5. Finance and distribution channels

Banks and participation banks operate wholesale and retail gold flows, gold deposit and investment accounts, leasing and consignment arrangements for manufacturers, and hedging solutions, interfacing with exchange trading desks. Authorized currency exchange offices with precious-metals permissions provide limited intermediation and retail distribution consistent with membership status and AML obligations. Insurers and lenders provide cargo insurance, stock coverage, and working-capital and trade-finance facilities with covenant packages tied to inventory controls and compliance. Core responsibilities include know-your-customer and beneficial-owner checks, sanctions and trade-control screening, transaction monitoring, and reconciliation of physical flows with account movements.

2.6. Logistics, transport and storage

Secure logistics providers include armored carriers, airside handlers and global freight partners planning routes, escorts and contingencies for high-value cargo. Vaulting and storage include exchange vaults and accredited private vaults, bonded and free-zone facilities with inventory systems and access controls. Core responsibilities include sealed-bag and tamper-evident protocols, dual-control handling, inventory reconciliations, incident reporting, and timely delivery to exchange custody where required.

2.7. Jewelry manufacturing, wholesale and retail

Manufacturers and ateliers transform refined inputs into finished goods, maintain working stocks and hedging practices, and document scrap returns to the refinery stream. Wholesalers and exporters aggregate domestic output, coordinate international sales channels, and ensure hallmarking and product conformity in target markets. Retailers and e-commerce sellers serve investment, gifting and savings demand for jewelry, small bars and packaged coins and handle buy-backs that feed the recycling loop. Trade bodies issue guidance, training and promotion and interface with authorities on standards and policy. Core responsibilities include supplier due diligence, hallmarking and product labelling, cash-intensive transaction controls, and documentation for buy-backs and returns.

2.8. Coins and minting

The Turkish State Mint (Darphane) mints coinage and widely demanded Republican gold coins and operates a retail-oriented channel parallel to exchange bullion. Distributors include wholesalers and retailers authorized to sell mint products. Core responsibilities include conformity with specifications, transparent pricing practices, and AML controls on bulk sales where applicable.

2.9. Integrated corporate groups

Conglomerates operate across multiple stages, for example combining refining, wholesale, jewelry production, retail networks and financial services. Core responsibilities include group-wide governance, segregation of duties between trading and control functions, consolidated AML and sanctions policies, and independent audit of metal flows and inventory.

2.10. Professional services and oversight partners

Legal and compliance advisors support licensing, market entry, AML/CFT frameworks, investigations and dawn-raid readiness. Auditors and independent inspectors provide stock counts, assay sampling, systems testing and accreditation reviews. Technology providers deliver KYC and sanctions screening, transaction monitoring, traceability and inventory systems tailored to precious-metals workflows. Core responsibilities include independence, defensible methodologies, and documentation aligned with regulator expectations.

2.11. Cross-cutting compliance touchpoints

Key touchpoints include beneficial-owner identification and verification for all counterparties, source-of-funds and source-of-metal checks calibrated to risk, politically exposed person screening and enhanced due diligence where indicated, sanctions and trade-control screening at onboarding and transaction level, recordkeeping and timely suspicious-transaction reporting, integrity of assay and weight documentation, cooperation with supervisory and law-enforcement requests, and clear escalation paths for anomalies in purity, weight, valuation or routing.

3. Core Legal and Regulatory Framework

3.1. Mining and primary production

Mining Law No. 3213 governs exploration and operation rights, transfers, relinquishment, and state royalties. Licenses are issued and supervised by MAPEG. Projects progress from exploration to operation through defined permits and technical reports. Environmental impact assessment (EIA) decisions, land/forest permits, workplace safety rules, and rehabilitation/closure obligations sit alongside mining rights. Holders must report production data, maintain technical records, and comply with license terms; material breaches can trigger suspension or revocation.

3.2. Market access, custody and trading rules

Borsa İstanbul’s Precious Metals and Precious Stones Market sets participation criteria for members (banks, precious-metals companies, refineries, certain currency offices and brokerages). Rules address admission of standard bullion, first domestic trades for imported bars, delivery into organized custody, settlement mechanics, member conduct, surveillance, and disclosure. Exchange directives define acceptable bar specifications, documentation (assay, weight, origin), and time limits for delivery to vault. Takasbank and exchange systems handle cash/metal settlement, collateral and default procedures.

3.3. Import and export, customs and anti-smuggling

Customs Law No. 4458 establishes declaration, valuation, tariff classification, bonded storage, and audit powers. Anti-Smuggling Law No. 5607 criminalizes undeclared or misdeclared cross-border movement, use of forged documents, and evasion schemes; it provides for seizure, confiscation, and penal sanctions. Ministry of Trade and Customs apply risk-based controls at airports, ports and land borders. Sector-specific measures may require that eligible importers/exporters be exchange members and that standard bars be consigned to exchange custody before first domestic sale. Chain-of-custody, assay certificates, insurance and transport documentation are central to clearance and post-clearance audits.

3.4. Monetary/foreign-exchange framework

Law No. 1567 and Decree No. 32 provide the backbone for transactions in foreign exchange and precious metals. Implementing communiqués set practical rules that intersect with gold imports, payments, and domestic trading. Policymakers may use levers such as import quotas, delivery deadlines to exchange vaults, or documentation requirements to manage bullion inflows. Participants should track these instruments continuously, as they can affect cost, timing and feasibility of shipments and first trades.

3.5. Anti-money laundering and counter-terrorist financing

Law No. 5549 and secondary MASAK regulations impose obligations on obliged parties, including precious-metals dealers, refineries, exchange members and financial institutions. Key duties include customer and beneficial-owner due diligence, risk-based enhanced due diligence for higher-risk profiles (e.g., politically exposed persons or opaque structures), ongoing monitoring, sanctions and trade-control screening, suspicious transaction reporting, recordkeeping, training, internal audit, and appointment of compliance officers where required. Tipping-off prohibitions apply. Failures can lead to administrative fines, criminal exposure where laundering occurs, and collateral consequences with supervisors and the exchange.

3.6. Sanctions, trade controls and international cooperation

Participants must screen transactions and parties against applicable sanctions regimes and trade restrictions, with heightened attention to complex routing, third-country transshipment, and barter/offset structures. Banks, refiners, and traders are expected to document screening, red-flag analysis, and escalation outcomes. International cooperation channels (mutual legal assistance, information-sharing MoUs, and FIU-to-FIU contacts) support investigations involving cross-border gold flows.

3.7. Product conformity, hallmarking and consumer-facing rules

Assay and specification requirements apply to standard bars admitted to organized custody. For jewelry and retail products, hallmarking, fineness marking, and product-labelling obligations protect consumers and support traceability. Retailers must provide accurate disclosures on purity and weight and maintain buy-back documentation to feed the recycling loop into formal channels.

3.8. Environmental, occupational safety and community obligations

Mining and processing activities must comply with EIA decisions, emissions and waste rules, hazardous-substance handling, tailings and water-management plans, worker safety standards, emergency response, and closure/rehabilitation commitments. Breaches can trigger administrative measures, criminal investigations after incidents, and effects on license status. Public consultation and grievance-handling mechanisms under EIA and permitting practice help manage community risks.

3.9. Competition and market-conduct constraints

Competition law prohibits collusion on prices, market allocation or coordinated capacity decisions among refiners, traders or jewelers. Abuse of dominance – such as unfair trading conditions or exclusionary conduct – may attract investigation. Exchange surveillance addresses market manipulation, insider misuse of confidential order or assay information, and disorderly trading.

3.10. Tax and accounting touchpoints

Participants must align indirect-tax treatment, withholding and corporate-income-tax reporting with the specific nature of gold transactions (physical vs. financial, retail vs. wholesale, export regimes). Accurate inventory accounting, cost of goods tracking, and reconciliation between physical flows and books are integral to audits and to AML controls.

3.11. Documentation, retention and audit readiness

Across the framework, defensible documentation is the common denominator: license files, permits and technical reports; exchange membership and trade records; customs declarations and transport/insurance papers; assay certificates and bar lists; onboarding files, beneficial-owner attestations, screening logs, monitoring alerts and STR filings; environmental and safety registers; and board-approved policies. Retention periods follow sectoral rules; electronic systems should ensure immutability and timely retrieval for supervisors, auditors and law-enforcement.

3.12. Governance expectations

Boards and senior management are expected to set risk appetite, approve policies, allocate resources, and oversee remediation. Three lines of defense – business, compliance/risk, and independent audit – should be defined. Group structures operating across mining, refining, trading and retail should harmonize policies, segregate control-sensitive functions, and implement consolidated monitoring to detect anomalies in purity, weight, valuation, ownership or routing.

3.13. Enforcement landscape

Supervisory actions range from corrective instructions and administrative fines to suspension of licenses, exchange membership consequences, and referrals for criminal investigation under anti-smuggling, forgery, fraud or laundering statutes. Cross-regulator coordination – MAPEG, Ministry of Trade/Customs, Borsa İstanbul, MASAK, environmental and safety authorities – enables parallel or sequential action where facts overlap. Early engagement, transparent remediation and verifiable controls materially influence outcomes.

4. Gold Import and Export Regime

Cross-border movement of gold in Türkiye follows a specialized regime that distinguishes standard bullion from non-standard forms, and separates commercial flows from passenger-carried items. Commercial imports and exports are routed through exchange members and customs procedures; passenger allowances are limited and cannot substitute for commercial movements.

4.1. Who may import and export

Eligible importers and exporters are typically members of Borsa İstanbul’s Precious Metals and Precious Stones Market – banks, precious-metals companies, refineries, certain currency offices and brokerage firms that meet participation and operational criteria. Non-members generally cannot bring standard bullion into the country for first sale. Jewelry manufacturers and exporters operate under sectoral rules and, where applicable, export-promotion frameworks.

4.2. Standard vs. non-standard forms

Standard bullion comprises bars meeting exchange specifications for fineness, dimensions and marking, accompanied by assay and origin documentation. Standard bars are normally consigned to exchange custody and their first domestic trade occurs on the organized market. Non-standard forms include granules, non-standard bars, semi-processed feedstock and scrap that require refining or conversion before organized trading; these may be moved under customs procedures but will not bypass the requirements for standardization and eligibility if destined for exchange delivery. Doré from mines is semi-refined metal subject to specific documentation, including mine of origin, transport chain, security and insurance, and is typically consigned to refineries for further processing.

4.3. Import policy levers

Authorities may apply quantitative or procedural levers to manage bullion inflows, such as monthly quotas on unprocessed gold, delivery-to-vault deadlines, documentary requirements, and designated entry points. These levers affect cost, timing and feasibility; importers should monitor notices and communiqués and maintain contingency plans for allocation shortfalls.

4.4. Customs mechanics for imports

Imports require accurate declaration and classification, including HS codes, valuation, weight and purity disclosures, and identification of the consignment as standard or non-standard. The documentation pack typically includes the commercial invoice, packing and weight list, assay certificate, certificate of origin or acceptable origin statement, transport and insurance documents, member authorization, and any quota allocation or regulatory clearances. Risk-based controls can include scanner checks, sampling for assay verification, and reconciliation of bar lists with markings and serials. Bonded handling and temporary storage are used until release to exchange custody or refinery intake, with preservation of tamper-evident seals and chain-of-custody logs. For standard bullion, timely delivery to exchange vaults within prescribed periods before first domestic sale and system booking by the member are central.

4.5. Export mechanics

Eligible exporters include exchange members and sectoral exporters such as jewelry manufacturers complying with membership and customs rules. Exported product lines include refined bullion that meets destination specifications, finished jewelry, and semi-finished products and granules under processing regimes. The documentation pack generally includes the export declaration, assay and quality certificates, invoice, packing and weight list, origin documentation as required by the destination, transport and insurance, and any inward-processing clearances. Settlement and FX compliance require adherence to applicable FX repatriation and documentation rules and clear alignment between physical shipments and financial flows to support AML and tax audits.

4.6. Special customs procedures

Inward processing can involve temporary import of non-resident metal or inputs for processing and re-export, subject to permit conditions and scrap accounting. Outward processing and repairs can involve temporary export for refining or finishing with return of finished product and precise reconciliation of inputs and outputs. Temporary admission for exhibitions and fairs requires controlled entry and return with strict inventory and security measures. Free zones can be used for storage and processing under zone rules, but these do not circumvent exchange and AML obligations when goods enter the domestic market.

4.7. Passenger-carried gold vs. commercial flows

Individuals may carry limited quantities for personal use subject to declaration; undeclared commercial-scale quantities risk seizure and penal action. Retail items bought abroad are not a channel for commercial import. Where doubt exists, customs can reclassify to commercial movement with full compliance requirements.

4.8. Assay, conformity and eligibility

Imports of standard bullion rely on recognized refiner lists and assay documentation; authorities and the exchange may sample to verify fineness and weight. Non-conforming or mismarked bars are redirected to refining or refused for exchange delivery. For jewelry exports, hallmarking and fineness marks must meet destination country rules.

4.9. Chain-of-custody and security

From loading to vault or refinery intake, shipments must maintain tamper-evident seals, dual-control handling and route security. Every custody transfer – carrier, bonded warehouse, exchange vault – generates dated records that feed audit trails. Losses, seal breaks or discrepancies trigger incident reports and can halt clearance or trading.

4.10. Payments, trade finance and Incoterms

Contracts should fix Incoterms, risk transfer, delivery location (e.g., exchange vault), insurance coverage, and dispute resolution. Letters of credit and documentary collections are common for bullion; banks require alignment between shipping documents, assay certificates and invoices. Premiums and discounts relative to benchmarks should be transparent and reconcilable to logistics and policy costs.

4.11. AML/sanctions overlay on cross-border flows

Importers and exporters apply customer and beneficial-owner due diligence, sanctions and trade-control screening, and source-of-funds/metal checks. Higher-risk routes, counterparties or structures (e.g., intermediaries in sanctioned corridors, opaque beneficial ownership, unusual barter/offset) call for enhanced due diligence and formal escalation. Suspicious activity triggers internal review and, where warranted, reporting.

4.12. Governance and audit readiness

Maintain a single source of truth for customs entries, warehouse receipts, assay reports, invoices, transport/insurance documents and exchange records. Periodically test end-to-end traceability from contract to vault or buyer delivery. Use variance reports and root-cause analysis to improve controls and demonstrate a consistent compliance posture to authorities and trading partners.

5. Irregularities and Red Flags

Irregularities in Türkiye’s gold trade almost always appear where paper, metal and money stop telling the same story. The fastest way to spot trouble is to test whether a shipment file cleanly links contract, invoice and payment to assay results, serialized bar lists, transport/insurance, customs MRNs, warehouse receipts and exchange delivery timestamps. When any one of those pieces is missing, altered, or out of sequence, exposure rises sharply.

5.1. Documentation integrity

Assay reports must match bar-serial lists, weights and fineness. Red flags include recycled serial numbers, missing or out-of-range serial sequences, altered bar-list templates, or assay values that break with supplier history without explanation. For doré and scrap, incomplete melt logs and unexplained yield shifts point to provenance or accounting gaps.

5.2. Border declarations

Misclassification between granules and bars, undervaluation far from benchmark formulae, and purity/weight discrepancies at sampling are classic triggers for adjustments, seizures or post-clearance audits. Origin statements that do not fit routing, or insurance documents inconsistent with Incoterms, are additional signals.

5.3. Exchange delivery and custody

Missed delivery-to-vault windows, warehouse receipts that do not reconcile to bar lists, and delivery tickets without aligned timestamps suggest either operational breakdown or an attempt to “reset” a lot’s identity. Lots that repeatedly require re-assay on arrival should be paused pending supplier remediation.

5.4. Process regimes and free zones

Inward processing and free-zone flows must pass a mass-balance test: inputs, outputs and scrap returns line up within tolerance. Paper “round-trips” with minimal transformation, long dwell times without processing records, and third-party substitutions during processing indicate elevated risk.

5.5. Passenger channels and VIP misuse

Commercial quantities moving through passenger lanes – especially during quota periods – are a bright-line risk. Frequent travelers carrying similar packaging, invoices that do not match personal capacity, or messaging indicating onward sale convert “personal effects” into a customs case very quickly.

5.6. Granule↔bar cycling and rapid turnarounds

Repeated conversions without a manufacturing purpose can be used to blur provenance or reset assay histories. Watch for short cycle times, unstable yields, and counterparties that decline referee-assay clauses.

5.7. Sanctions and routing exposure

Third-country detours, barter/offset structures dressed as “humanitarian” trades, and opaque intermediaries with no clear value-add create long-tail liability. If the corridor intersects sanctioned regimes or state-linked traders, require end-use/end-user attestations and legal sign-off before execution.

5.8. Related-party opacity and governance

Integrated groups trading with their own affiliates need visible guardrails: disclosed related-party terms, independent pricing references, and segregation between trading desks and control functions. Undocumented offsets, unexplained price discounts/premiums, or inventory books that do not match hedge positions are warning signs.

5.9. How to test for red flags in minutes

A quick serials sweep should confirm that serial ranges and counts on the bar list match warehouse receipts and exchange delivery. Assays should be reconciled to ensure fineness and weight align with supplier history and contract specs, and variances should be explained and approved. Transport, insurance and customs entries should match Incoterms and the stated origin and destination. Timestamps should be logical across loading, border, bonded intake, vault booking and first domestic sale. Payment flows and banks should align with the commercial parties, without third-party surprises. If any link fails, movement should be paused, evidence preserved, and internal escalation triggered before the lot is listed for first domestic sale.

6. Recent Enforcement and High-Profile Matters

6.1. Istanbul Gold Refinery (IAR) investigation

In October 2025, prosecutors in Istanbul ordered arrests linked to Istanbul Gold Refinery and related firms. Public reporting indicates allegations around fraudulently obtaining state support and violations of financial rules tied to the protection of the Turkish lira’s value. Police conducted coordinated raids; multiple detentions were reported while additional suspects were sought. The matter underscores prosecutors’ willingness to combine financial-crime, public-finance, and currency-protection statutes when reviewing refinery operations and subsidy/use-of-funds questions.

6.2. İstanbul Grand Bazaar Allegations

Media reports have alleged laundering networks and sanctioned-origin flows routed through segments of the Grand Bazaar. In February 2025, authorities detained 37 people – including the bazaar’s vice president – and said they uncovered $250 million in illicit funds, which experts describe as only a fraction of the total. Compliance lesson: trades linked to Bazaar intermediaries require “single-story” files – assay tied to serialized bar lists, invoices and MRNs matched to warehouse receipts and exchange delivery – and enhanced onboarding until counterparties prove documentary discipline.

6.3. Parliamentary MP-linked smuggling claims and VIP-channel misuse

Public allegations in 2024 connected political figures and aides to irregular movements of gold, including an incident at Istanbul Airport’s VIP lounge where 60 kg of undeclared gold was reportedly intercepted. three deputies from the MHP resigned from the party following public allegations of involvement in gold smuggling. PEP (politically exposed persons) exposure elevates onboarding standards; VIP facilities do not change customs law. Rule of thumb: ban passenger channels for any commercial metal, escalate PEP/state-linked relationships for enhanced due diligence, and pre-approve only courier/secure logistics with full paperwork.

6..4. Libya – Türkiye interdiction (Misrata route)

A 2024 interdiction in Misrata involved a planned movement of gold and cash reportedly bound for Türkiye. Route-based risk rises when origin airports and onward handling are opaque. Control set: end-use/end-user attestations, screening snapshots for every party (buyer, seller, carrier, warehouse, insurer, assayer), and pre-alerts to customs when corridors are sensitive.

6.5. Environmental and safety enforcement at the Çöpler mine (Erzincan/İliç)

A large landslide at the Çöpler gold mine in February 2024 triggered an extensive emergency response and a criminal inquiry. Authorities later detained company officials and revoked environmental permits and licenses, citing contamination risks associated with cyanide-bearing material. The case illustrates how environmental incidents can rapidly migrate into criminal exposure, licensing consequences, and reputational damage across the domestic and cross-border supply chain.

6.6. İpek – Koza / Koza Altın governance history

Since 2015, Koza entities have operated under state-appointed control, with international arbitration and later media reports on ownership and naming developments. Complex control histories are not a bar to trade, but they demand verified, current signatory and ownership records and a contract architecture with audit rights and termination triggers if governance changes.

6.7. Reza Zarrab / Halkbank (“gold-for-gas”) sanctions case

U.S. proceedings stemming from 2012–2013 described conversion of restricted Iranian funds into gold via sham paperwork and third-country detours; Zarrab pled guilty in 2017, and the case against Halkbank continues after immunity challenges failed in U.S. courts. The core takeaway is unchanged: complex barter or offset structures layered through intermediaries, especially on sensitive corridors, require rigorous end-user, end-use, and sanctions diligence before execution. 

6.8. Import-policy shocks and knock-on risks

Since December 2023, authorities have managed bullion inflows with a 12-ton/month quota on unprocessed gold (subject to stated exemptions). Trade and sector press have linked quota-driven scarcity to secondary risks such as pricing dislocations and incentives for informal channels. Compliance teams should anticipate tighter documentary reviews, delivery-to-vault timetables, and scrutiny of routing when quota constraints bind.

6.9. Patterns emerging across cases

Several patterns recur across these matters. Investigators frequently use multi-statute charging, combining anti-smuggling, AML, fraud and forgery, public-finance and Turkish-lira protection provisions when facts permit. Across cases, custody and documentation integrity is a central focus, with assay reports, serialized bar lists and warehouse receipts tested against customs and exchange records. Heightened sensitivity around politically exposed persons is another recurring theme, as allegations touching elected officials amplify reputational risk and trigger enhanced due diligence expectations. Finally, environmental incidents increasingly function as compliance events, because licensing, criminal and civil exposures can cascade quickly after mine-site accidents.

6.10. Practical responses for market participants

A defensible response begins with strengthening pre-trade controls for refinery and exporter relationships, including verifying eligibility and the integrity of subsidy and use-of-funds positions where relevant, aligning bar lists, assays and invoices, and confirming delivery-to-vault timing against exchange rules. PEP protocols should be elevated through enhanced due diligence, declarations on beneficial ownership and official capacity, and documented escalation outcomes before onboarding or executing transactions. Quota months should be treated as enhanced-risk windows, with Incoterms and delivery points pinned to exchange vaults, customs pre-alerted with complete files, and price bases monitored for anomalies that could signal informal channels. Environmental risk should be integrated into counterparty ratings by reviewing EIA decisions, incident logs and corrective-action plans for miners and processors and reflecting findings in onboarding and trading limits. Sanctions screening should be re-tested on trade structures by scrutinizing third-country transshipment and barter or offset terms and requiring end-use and end-user attestations and bankable documentary trails for higher-risk corridors.

6.11. Forward look

With prosecutors and supervisors coordinating across financial-crime, customs, market-conduct and environmental statutes, gold-sector enforcement is likely to remain active. Firms that can evidence real-time traceability from origin to custody, disciplined counterparty governance, and rapid response to information requests will be better positioned to manage enforcement exposure while sustaining market access.

7. Venezuelan Gold Flows to Türkiye: Sanctions Exposure and Supply-Chain Risk Analysis

Venezuelan gold flows since 2018 present a distinct and instructive risk category for the Turkish gold market, particularly in the context of sanctions compliance and supply-chain integrity. Although gold imports are, in principle, permitted under Turkish customs and trade regulations, transactions involving gold originating from jurisdictions subject to extensive sanctions and governance concerns may give rise to heightened legal, regulatory and reputational exposure. Venezuela has been widely characterised by international organisations and investigative bodies as a high-risk gold-producing jurisdiction due to extensive state involvement in gold acquisition and exports, widespread illegal and informal mining activity, and the strategic use of gold as a liquidity instrument under international sanctions pressure.

Investigative reporting has indicated that substantial quantities of gold sold by the Venezuelan Central Bank during 2018 were exported to a limited number of foreign counterparties, including a Turkish precious-metals company, with shipments reportedly transported by air and refined outside Venezuela. These findings, which rely on leaked documents, customs records and transport-route analysis, do not constitute judicial determinations of illegality. Nevertheless, they are legally significant from a compliance perspective because they demonstrate that Türkiye has functioned as a destination and processing jurisdiction for gold originating from a sanctions-exposed state. This places Turkish refiners, traders, logistics providers and financial institutions involved in such transactions within the scope of heightened international scrutiny, irrespective of whether domestic legal requirements were formally satisfied at the point of import.

The sanctions framework applicable to Venezuelan gold explains why such transactions attract particular regulatory attention. Unlike ordinary commodities, gold occupies a structurally distinct position in sanctions law because it can transfer value without reliance on the international banking system, can be physically transported with limited financial traceability, and becomes largely fungible once refined. As a result, sanctions targeting Venezuela’s gold sector have been designed not only to prohibit direct dealings by designated persons, but also to raise compliance expectations for third-country actors whose activities may facilitate the monetisation of gold reserves or the circumvention of financial restrictions. In this context, sanctions risk may arise even where a transaction is lawful under Turkish law, particularly if it materially enables value generation for a sanctioned state or involves intermediaries subject to designation or investigation.

Within this regulatory environment, gold refineries and traders are increasingly treated as compliance gatekeepers rather than neutral commercial actors. International due-diligence standards applicable to precious metals require enhanced scrutiny where gold originates from high-risk or sanctions-affected jurisdictions. This includes assessing the legality of extraction and export at origin, the involvement of state entities or politically exposed persons, the ownership and control structure of counterparties, and the overall economic rationale of the transaction. Refining or onward trading of gold does not, in itself, neutralise risks linked to origin or sanctions exposure, and reliance solely on contractual representations or counterpart assurances is generally insufficient in high-risk cases.

The Venezuelan example illustrates broader implications for the Turkish gold market. Formal customs clearance and compliance with domestic trade rules may not be sufficient to eliminate international legal exposure where gold originates from a sanctions-exposed jurisdiction. Enhanced due diligence, internal escalation mechanisms, and robust documentation of origin verification and decision-making are essential to mitigate the risk of regulatory enforcement, sanctions designation, civil liability or reputational harm. From a risk-management perspective, gold originating from Venezuela and similarly situated jurisdictions should therefore be treated as inherently high-risk, requiring a cautious and structured compliance approach to preserve the integrity and international credibility of the Turkish gold market.

8. Civil and Administrative Exposure Beyond Criminal

Even where conduct does not meet criminal thresholds – or runs in parallel with a criminal inquiry- gold-sector participants can face a wide spectrum of civil and administrative outcomes: confiscation and forfeiture of goods, administrative fines, license suspensions or revocations, exchange membership sanctions, export-support clawbacks, tax and customs assessments with penalties and interest, competition and consumer-protection measures, environmental and workplace safety orders, and contractual claims from counterparties and customers. These actions often move faster than criminal proceedings and can disrupt operations immediately.

9. High-Risk Corridors and Counterparty Governance

9.1. Sanction-sensitive routes

Some corridors carry structural risk because counterparties, insurers or intermediaries may be exposed to sanctions or trade controls. Before committing price or capacity, participants should require end-use and end-user attestations, identify the actual consignee and shipper rather than only agents, and screen every party involved, including buyer, seller, carrier, warehouse, assayer, insurer and financier, with dated evidence saved to the shipment file. If a third-country detour, barter or offset arrangement, or humanitarian cover is proposed, the economic rationale should be documented and legal sign-off obtained. Where attestation is absent, purpose is unclear, or trade logic is not defensible, the transaction should not proceed.

9.2. Bazaar-linked and quota-period protocols

Where trades touch Grand Bazaar intermediaries or occur during quota months, elevate controls: enhanced onboarding (beneficial ownership to natural persons, PEP/adverse-media review), sample reconciliation of serials and assays against historical supplier patterns, and pre-alerts to customs for atypical routes or forms. Operate a delivery-to-vault countdown visible to trading, logistics and compliance. Communicate partial fills and delays to clients in writing; do not shift to passenger/VIP channels. Treat any documentation anomaly (serial gaps, assay outliers, inconsistent invoices) as a stop signal until resolved.

9.3. Doré and upstream (EHS-integrated diligence)

For miners and processors, environmental and safety performance should form part of onboarding and ongoing review, including EIA status, water and tailings management, hazardous-substance permits, incident logs and remediation plans. EHS grades should be tied to trading and credit limits and revisited after any incident. For doré, mine-of-origin papers, secure transport and insurance, and blending and yield rules at the refinery should be verified. Where upstream transparency is weak or incidents recur without verified remediation, exposure should be capped or relationships exited.

9.4. Integrated groups and related-party discipline

Large actors may combine refining, wholesale, retail and finance under one umbrella. Map all entities, board/signatory powers and intra-group routes. Set related-party trading limits, require independent price references, and segregate trading from control functions (compliance, risk, internal audit, assay QA). Reconcile inventory to hedge positions at month-end and around big shipments; unexplained offsets or timing differences are escalation triggers. Build audit rights and termination clauses into contracts to address loss of eligibility, sanctions hits, or governance change.

9.5. Vendors and outsourced links

Secure logistics, bonded warehouses, assay labs, customs brokers and KYC providers are extensions of your control environment. Risk-score them, require SLAs and incident-notification windows, and test performance with periodic spot checks (seal integrity, time-to-vault, assay variance rates, customs variance closures). Keep alternative providers on standby for corridor disruptions or vendor failures.

9.6. Documentation governance and retention

Adopt a “single source of truth” for every lot: contract, assay, serialized bar list, transport / insurance, customs MRN, bonded intake, warehouse receipt, exchange delivery, payment. Lock templates (bar lists, invoices, customs drafts) to prevent tampering; control access and log edits. Retain screening snapshots, end-use/end-user attestations, and variance committee decisions for the statutory period. If you cannot retrieve a document in minutes, assume a regulator cannot either.

9.7. Decision rules and escalation

Define red/yellow lines in policy. Red: passenger channels for commercial metal, unsigned bar lists, unexplained serial gaps, sanctioned counterparties or vessels, absence of end-use/end-user evidence on sensitive corridors – trade blocked. Yellow: assay outliers, small valuation differences, form/HS uncertainty – variance committee decides within a fixed SLA with root-cause notes and corrective actions. Escalations travel to a cross-functional committee (trading, logistics, legal, compliance) with power to pause flows.

9.8. Metrics that keep governance real

Track and review monthly: percentage of lots with complete “single-story” files at day zero; on-time delivery to vault; assay variance rate and closure time; customs variance count and PCA findings per 100 shipments; share of counterparties with BO verified to natural persons; sanctions/PEP alert aging; vendor incident rate; EHS-linked counterparty downgrades. When any metric deteriorates, tighten limits, increase sampling, and retrain the closest process owners.

9.9. Practical outcome

When corridors are risky and counterparties complex, disciplined governance – not optimism -keeps shipments moving. If a file proves who owns what, where metal came from, how it traveled, when it reached custody, and why the route made economic sense, banks, insurers and authorities usually stay onside. If any of those answers are missing, pause and repair before price and legal risk compound.

10. Conclusion

Türkiye’s gold sector is broad, fast-moving and tightly supervised across mining, refining, import and export, organized trading, retail and recycling. The operating reality is a mesh of licensing, exchange rules, customs formalities, FX measures, AML/CFT expectations, sanctions screening, consumer and product standards, and EHS obligations. Enforcement has grown more coordinated, with cases cutting across financial crime, market conduct, customs and environmental law. In this environment, durable success depends less on transactional opportunism and more on verifiable control systems, disciplined documentation and credible governance.

A defensible operating posture starts with clear role design, a board-approved risk map, and a compact policy stack that front-line teams actually use. Across the value chain, counterparties must be onboarded with verified beneficial ownership, sanctions and adverse-media screening, and, where relevant, source-of-metal evidence that stands up to audit. Shipment files should tell a single, reconcilable story from contract to custody or export, with bar lists and assays matching packaging and warehouse receipts, customs entries aligned with invoices and payments, delivery-to-vault on time, and variances closed with root-cause notes. Assay governance, including split samples, referee labs and pre-agreed protocols, is a linchpin for avoiding costly disputes and delays.

For cross-border flows, predictable compliance beats reactive fixes. Customs should be pre-alerted, documentation standardized and quota or policy-tightening periods treated as enhanced-risk windows with tighter controls and transparent client communications. On the market side, exchange membership brings access and scrutiny, and surveillance cooperation, timely settlement and clean custody records are non-negotiable. In retail, hallmarking, price transparency, cash controls and buy-back documentation keep consumer and AML risks in check. For miners and processors, EHS performance is now core business risk, with incident readiness, tailings and water-management discipline and verifiable remediation directly affecting licensing and counterparties’ appetite.

Continuous assurance converts policies into resilience. End-to-end lot traceability should be tested, physical positions reconciled to books, monitoring scenarios validated for precious-metals typologies, and KPIs tracked, including delivery-to-vault timeliness, assay variance rates, customs variance closures, alert aging and STR quality, quota utilization and remediation speed. Third-party audits and contract-embedded rights should be used to pressure-test high-risk suppliers, logistics providers, warehouses and labs. When incidents occur, response should be rapid, evidence should be preserved, counsel engaged, authorities approached with facts, and corrective actions implemented that change processes, not just paperwork.

Policy evolution should aim for clarity and interoperability through coordinated guidance from supervisors, predictable import levers, accredited referee-assay capacity, machine-readable bar lists and certificates, beneficial ownership verification for sector actors, and targeted risk indicators for doré, scrap and free-zone processing. These steps reduce ambiguity for responsible firms while making it harder for high-risk behavior to hide.

The practical takeaway is straightforward. Participants that can demonstrate transparent ownership and decision-making, traceable origin and custody of metal, clean customs and exchange delivery discipline, risk-based AML, sanctions and EHS controls, and rapid evidence-backed remediation will not only withstand scrutiny but also earn better access to banks, insurers, counterparties and markets. In a sector where trust rides on grams, serials and timestamps, robust controls are not overhead; they are the competitive edge.

If you operate anywhere in Türkiye’s gold value chain and need a practical, defensible compliance posture, or immediate assistance with an audit, variance or investigation, Bıçak Law Firm stands ready to assist.

We help gold-sector clients prove the single story that keeps shipments moving and investigations narrow. Our team designs customs and exchange-delivery workflows, builds audit-ready shipment files from contract to assay to serialized bar list to transport and insurance to customs MRN to bonded intake to warehouse receipt to exchange delivery to payment, and negotiates referee-assay clauses with pre-agreed labs and tight timelines. We conduct end-to-end sanctions and routing reviews for sensitive corridors, archive screening snapshots for every party, and obtain defensible end-use and end-user attestations where needed.

On the AML/CFT side, we implement risk-based onboarding with beneficial ownership verified to natural persons, PEP and adverse-media checks, tune transaction-monitoring scenarios for precious-metals typologies, and write playbooks for variance committees, quota-period trading and bazaar-linked counterparties. For miners and processors, we integrate EHS diligence into trading and credit limits.

When problems hit, we respond fast. In seizures, dawn raids or post-clearance audits, we preserve evidence, rebuild chain-of-custody, prepare petition and objection files, commission referee assays, and negotiate releases or settlements while corrective controls go live. In documentation disputes, we reconcile serials, assays and warehouse receipts; where misclassification or valuation is at issue, we prepare technical memoranda and seek binding rulings.

If you face a stuck shipment, delivery-to-vault delay, assay variance, sanctions inquiry, subsidy audit or an EHS-triggered review, contact us.

© 2025 Prof. Dr. Vahit Bıçak / Bıçak Law Firm – All rights reserved. This article was written by Prof. Dr. Vahit Bıçak for publication on the website www.bicakhukuk.com. Even if cited as a source, the full text of the article may not be used without prior permission. However, a portion of the article may be quoted, provided that an active link is included. Publishing the article in whole or in part without indicating the author and the source constitutes a violation of personal and intellectual property rights.

Reference: Bıçak Vahit (2025) “Gold Market Operations in Türkiye: Legal Framework, Risks & Recent Enforcement”, Bıçak Law Firm Blog, https://www.bicakhukuk.com/en/turkish-gold-market-risks-and-remedies/, Prgf. __., Access Date: ….