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    GRECO Flags Executive Gaps in Türkiye as FATF Finds MASAK Strong but Enforcement Uneven

    GRECO and FATF compliance review concept with financial intelligence documents, a Turkey map and Ankara institutions
    Türkiye’s latest GRECO and FATF assessments show strong financial intelligence capacity alongside continuing gaps in oversight, verification and enforcement.Photo: Bosphorus News

    GRECO finds limited progress on top executive reforms; FATF credits MASAK and technical compliance but identifies weaker enforcement outcomes

    By Murat Yıldız

    On September 29, 2026, the Council of Europe's Group of States against Corruption (GRECO) published summaries of its latest compliance reports on Türkiye, covering parliament, the judiciary, the executive and law enforcement.

    On top executive functions, GRECO said "nearly no progress" had been achieved. Of 32 recommendations covering the executive and law enforcement, four were implemented or dealt with satisfactorily, seven partly implemented and 21 not implemented. Türkiye remains under GRECO compliance procedures and has been asked to report further progress in 2027.

    The Fourth Round, covering parliamentarians, judges and prosecutors, recorded six of 22 recommendations as implemented or dealt with satisfactorily, nine partly implemented and seven not implemented. None of the seven recommendations concerning members of parliament had been fully implemented when GRECO sent a high-level delegation to Ankara in June 2025. It also said no substantive information had been provided since 2018 on further measures concerning those recommendations.

    The Financial Action Task Force (FATF), meanwhile, records high technical compliance in Türkiye's anti-money laundering and counter-terrorist financing system. Türkiye is compliant or largely compliant with 38 of FATF's 40 recommendations. On effectiveness, eight of 11 Immediate Outcomes are rated Moderate and three Substantial. Türkiye remains in enhanced follow-up.

    GRECO and FATF do not measure the same system. GRECO examines integrity, conflicts of interest and corruption prevention in public institutions. FATF assesses money laundering, terrorist financing and proliferation financing. The comparison is therefore about implementation, not their scores.

    Parliament and the Executive

    GRECO's seven recommendations for members of parliament cover transparency in lawmaking, parliamentary ethics, conflicts of interest, secondary activities, asset declarations, immunity procedures and confidential advice and training. It has called for action on legislative transparency, a code of conduct, conflict-of-interest rules, verification of asset declarations, parliamentary immunity and integrity counselling and training.

    There has been more movement in the judiciary. GRECO has acknowledged ethics measures and training while continuing to raise issues involving the Council of Judges and Prosecutors, recruitment, security of tenure, temporary assignments, disciplinary procedures and powers held by the Ministry of Justice.

    Its Fifth Round assessment is more critical of the executive. GRECO recorded ethics and good-governance training for deputy ministers and advisers, publication of some ministerial counsellors' names and preparation of a draft national anti-corruption strategy. But only two recommendations concerning top executive functions were partly implemented.

    Outstanding issues include pre-appointment integrity checks, a dedicated code of conduct, lobbying rules, ad hoc conflict-of-interest disclosure, gift rules, post-employment restrictions and public access to asset declarations. GRECO also called for greater transparency around the State Supervisory Council and for the administrative permission requirement for prosecution to be abandoned.

    Law enforcement has made more progress. GRECO recorded integrity training, publication of donations, anti-corruption risk analysis, gender-equality measures and annual reporting by the Law Enforcement Surveillance Commission. Still open are an independent external complaints mechanism, whistleblower protection, clearer duties to report misconduct, stronger ethics rules and greater transparency in senior appointments.

    Much of the progress so far has come through training, guidance, reporting and administrative measures. Recommendations involving independent scrutiny, conflicts of interest and enforceable accountability remain open.

    MASAK Stands Out in FATF Review

    FATF credits Türkiye with generally strong, data-driven analysis of money-laundering and terrorist-financing risks and robust cooperation among competent authorities.

    MASAK is one of the strongest parts of the assessment. FATF gives Türkiye a Substantial effectiveness rating for financial intelligence and says the Financial Crimes Investigation Board has broad and direct access to more than 300 databases. Investigators and prosecutors systematically use the financial intelligence it produces.

    PEP monitoring is less effective in practice. FATF Recommendation 12 is rated Compliant, and Türkiye's framework covers domestic politically exposed persons, with enhanced measures applying when a relationship presents higher risk. FATF nevertheless found PEP identification and monitoring only partly effective, particularly among exchange offices.

    GRECO, by contrast, focuses on integrity rules, conflicts of interest and asset disclosure for parliamentarians and senior officials. FATF looks at how financial institutions identify and monitor financial risks associated with PEPs.

    Verification Remains a Weak Point

    Türkiye has built a broad beneficial-ownership framework through the Trade Registry, MERSİS and beneficial ownership reporting. FATF says the information is generally available to competent authorities.

    Its concern is accuracy and verification. Basic and beneficial ownership information still relies heavily on self-reporting, substantive checks are limited and available information sources are not used consistently. FATF calls for stronger risk-based checks of both the person reported as the beneficial owner and whether that person is in fact the true owner.

    GRECO does not assess beneficial ownership registers. For public office-holders, the comparable issue is verification of asset declarations and the handling of conflicts of interest.

    Sanctions, Prosecutions and Asset Recovery

    FATF says Türkiye's expansion of risk-based financial supervision has improved compliance. Serious structural failures, however, can initially be addressed through written warnings and time to correct them. FATF found that systemic weaknesses were not always met with sanctions proportionate to their severity or sufficiently strong to deter future breaches. The non-publication of sanctions and remedial measures further limits their deterrent effect.

    Türkiye also has the legal and investigative capacity to pursue complex money-laundering cases. FATF finds weaker results in professional laundering, sophisticated layering, misuse of legal persons and cross-border and trade-based schemes. It also says sanctions are not sufficiently dissuasive in laundering cases involving public officials, professional money launderers or organised crime.

    Asset recovery remains another weak point. Türkiye makes extensive use of provisional transaction postponements and can identify criminal assets domestically, but only a limited share of those measures ultimately results in seizure or confiscation. FATF also identifies the tracing and recovery of assets abroad as a major shortcoming.

    The Remaining Gaps

    Both reports also record strengths. FATF points to Türkiye's legal framework, financial intelligence and institutional coordination, with MASAK receiving a notably positive assessment. GRECO records progress in parts of the judiciary and law enforcement.

    GRECO's open recommendations include conflicts of interest, asset transparency, independent oversight, accountability procedures and safeguards against executive influence. FATF identifies weaknesses in ownership verification, PEP monitoring, sanctions for systemic breaches, complex prosecutions and asset recovery.

    Türkiye has much of the legal and institutional architecture in place, and MASAK shows that parts of it operate at a high level. The less consistent areas are verification, deterrent sanctions, complex-case outcomes and independent accountability.

    Read the GRECO and FATF documents here: GRECO Fourth Evaluation Round — Türkiye · GRECO Fifth Evaluation Round — Türkiye Compliance Report Summary · FATF Mutual Evaluation Report of Türkiye 2026

    Sources: Council of Europe/GRECO, Financial Action Task Force, Bosphorus News review and reporting.

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