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.

Türkiye’s gold market at a glance

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.

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.

Products and forms of gold

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

Participants across the chain

Upstream: licensed mining companies and their subcontractors, drillers, geological and environmental consultants, and assay labs serving exploration.
Midstream: refineries, independent assay and quality-control services, industrial recyclers, and secure logistics and vaulting providers.
Market/intermediation: Borsa İstanbul member institutions (banks, precious-metals companies, certain currency offices and brokerages), clearing/settlement infrastructure, and authorized importers/exporters.
Downstream: jewelry manufacturers, wholesalers, exporters, retailers and e-commerce sellers; banks and participation banks offering gold accounts and investment products.
Public institutions with operational interfaces: 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; the Turkish State Mint for coinage.

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.

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.

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.

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.

Practical implications for market participants

Maintain complete and reconcilable documentation from mine or scrap source through refinery to exchange custody or retail sale. Verify counterparties’ licensing, exchange membership and refinery accreditations before transacting. Align bank and dealer procedures with AML/CFT requirements, including enhanced due diligence for higher-risk profiles and politically exposed persons. Structure logistics with clear chain-of-custody, bonded storage where appropriate, and timely delivery to exchange vaults. Use hedging and inventory controls to manage price exposure without compromising documentation integrity.

Who’s who – actors across the value chain

Mining and upstream exploration

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

Primary processing and refining

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

Import and export gatekeepers

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

Market trading, custody and settlement

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

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; interface with exchange trading desks.
Authorized currency exchange offices with precious-metals permissions: limited intermediation and retail distribution consistent with membership status and AML obligations.
Insurers and lenders: provide cargo insurance, stock coverage, working-capital and trade-finance facilities with covenant packages tied to inventory controls and compliance.
Core responsibilities: know-your-customer and beneficial-owner checks, sanctions and trade-control screening, transaction monitoring, and reconciliation of physical flows with account movements.

Logistics, transport and storage

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

Jewelry manufacturing, wholesale and retail

Manufacturers and ateliers: transform refined inputs into finished goods; maintain working stocks and hedging practices; document scrap returns to the refinery stream.
Wholesalers and exporters: aggregate domestic output, coordinate international sales channels, 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; handle buy-backs that feed the recycling loop.
Trade bodies: sector chambers and exporters’ unions issuing guidance, training and promotion; interface with authorities on standards and policy.
Core responsibilities: supplier due diligence, hallmarking and product labelling, cash-intensive transaction controls, and documentation for buy-backs and returns.

Coins and minting

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

Integrated corporate groups

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

Professional services and oversight partners

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

Cross-cutting compliance touchpoints

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.

Core legal and regulatory framework

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

Gold import and export regime

Scope and basic rule

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.

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.

Standard vs. non-standard forms

Standard bullion: 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: 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: semi-refined metal subject to specific documentation (mine of origin, transport chain, security and insurance) and typically consigned to refineries for further processing.

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.

Customs mechanics for imports

Declaration and classification: accurate HS codes, valuation, weight and purity disclosures, and identification of the consignment as standard or non-standard.
Documentation pack: commercial invoice, packing/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: x-ray/scanner checks, sampling for assay verification, and reconciliation of bar lists with markings and serials.
Bonded handling: use of bonded areas and temporary storage until release to exchange custody or refinery intake; preservation of tamper-evident seals and chain-of-custody logs.
Delivery to custody: for standard bullion, timely delivery to exchange vaults within prescribed periods before first domestic sale; system booking by the member.

Export mechanics

Eligible exporters: exchange members and sectoral exporters (e.g., jewelry manufacturers) complying with membership and customs rules.
Product lines: refined bullion that meets destination specifications; finished jewelry; semi-finished products and granules under processing regimes.
Documentation pack: export declaration, assay/quality certificates, invoice, packing/weight list, origin documentation as required by the destination, transport and insurance, and any inward-processing clearances.
Settlement and FX: adherence to applicable FX repatriation and documentation rules; clear alignment between physical shipments and financial flows to support AML and tax audits.

Special customs procedures

Inward processing: temporary import of non-resident metal or inputs for processing and re-export, subject to permit conditions and scrap accounting.
Outward processing and repairs: temporary export for refining or finishing with return of finished product; precise reconciliation of inputs/outputs.
Temporary admission for exhibitions and fairs: controlled entry and return with strict inventory and security measures.
Free zones: storage and processing under zone rules without circumventing exchange and AML obligations when goods enter the domestic market.

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.

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.

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.

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.

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.

Common pitfalls and red flags

Misdeclaration of purity, weight or HS code; inconsistencies between assay paperwork and markings; origin statements that conflict with routing; repeated use of passenger channels for commercial volumes; shipments timed to evade delivery-to-vault deadlines; fragmentation of consignments to fit under internal approval thresholds; round-tripped exports and imports without economic rationale.

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.

Recent enforcement and high-profile matters

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.

Parliamentary resignations and gold-smuggling allegations

In November 2024, three deputies from the MHP resigned from the party following public allegations of involvement in gold smuggling. Subsequent coverage noted the sensitivity of the claims and the attention paid to media reporting about the case. Regardless of ultimate adjudication, the affair is a reminder that politically exposed persons (PEPs) in or around the gold trade elevate counterparty risk and due-diligence expectations for market participants. 

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.

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.

Sanctions-evasion lessons from “gas-for-gold”

Historic U.S. proceedings and public records around the 2012–2013 “gas-for-gold” pathway (Zarrab/Halkbank context) remain a reference point for banks, refiners, and traders structuring cross-border payments tied to precious metals. 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. 

Patterns emerging across cases

• Multi-statute charging: anti-smuggling, AML, fraud/forgery, public-finance and TL-protection provisions appear in combinations where facts permit.
• Custody and documentation focus: investigators test the integrity of assay reports, bar lists, serials, and warehouse receipts against customs and exchange records.
• Heightened PEP sensitivity: allegations touching elected officials amplify reputational risk and trigger enhanced due diligence duties for counterparties. 
• Environmental incidents as compliance events: licensing, criminal, and civil exposures can cascade quickly after mine-site accidents.

Practical responses for market participants

• Strengthen pre-trade controls for refinery and exporter relationships: verify subsidy/use-of-funds eligibility where relevant; align bar lists, assays, and invoices; and confirm delivery-to-vault timing against exchange rules.
• Elevate PEP protocols: apply enhanced due diligence, require declarations on beneficial ownership and official capacity, and document escalation outcomes before onboarding or executing transactions.
• Treat import-quota periods as enhanced-risk windows: pin Incoterms and delivery points (e.g., exchange vault), pre-alert customs with complete files, and monitor price bases for anomalies that could signal informal channels.
• Integrate environmental risk into counterparty ratings: for miners and processors, review EIA decisions, incident logs, and corrective-action plans; reflect findings in credit, onboarding, and trading limits.
• Re-test sanctions screening on trade structures: scrutinize third-country transshipment and barter/offset terms; require end-use/end-user attestations and bankable documentary trails for higher-risk corridors.

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.

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.

Policy considerations and reform ideas

Strengthen market integrity without constraining legitimate trade; raise transparency and traceability across the value chain; align supervisory expectations across mining, refining, import–export and organized trading; reduce compliance ambiguity and administrative friction; improve environmental and safety outcomes; protect consumers; and maintain international market access.

Conclusion

Türkiye’s gold sector is broad, fast-moving, and tightly supervised across mining, refining, import–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: bar lists and assays that match 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 (split samples, referee labs, pre-agreed protocols) is a linchpin for avoiding costly disputes and delays.

For cross-border flows, predictable compliance beats reactive fixes. Pre-alert customs, standardize documentation, and treat quota or policy-tightening periods as enhanced-risk windows with tighter controls and transparent client communications. On the market side, exchange membership brings access and also scrutiny – 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: incident readiness, tailings and water-management discipline, and verifiable remediation directly affect licensing and counterparties’ appetite.

Continuous assurance is what converts policies into resilience. Test end-to-end lot traceability, reconcile physical to book positions, validate monitoring scenarios specific to precious-metals typologies, and track KPIs that matter: delivery-to-vault timeliness, assay variance rates, customs variance closures, alert aging and STR quality, quota utilization, and remediation speed. Use third-party audits and contract-embedded rights to pressure-test high-risk suppliers, logistics providers, warehouses and labs. When incidents occur, move fast: preserve evidence, activate counsel, engage authorities with facts, and implement corrective actions that change processes—not just paperwork.

Policy evolution should aim for clarity and interoperability: coordinated guidance from supervisors, predictable import levers, accredited referee-assay capacity, machine-readable bar lists and certificates, BO 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 (1) transparent ownership and decision-making, (2) traceable origin and custody of metal, (3) clean customs and exchange delivery discipline, (4) risk-based AML/sanctions and EHS controls, and (5) 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.