Türkiye’s 2026–2030 AML/CFT Roadmap: What the New Strategy Means for Obliged Entities

The Circular and the Legal Nature of the Strategy Document

Presidential Circular No. 2026/7, published in Official Gazette No. 33300 dated 4 July 2026, announced the “Strategy Document for Enhancing Effectiveness in Combating Money Laundering and Terrorist Financing and in Confiscation Practices in Türkiye (2026–2030)” to the public. Published in full on MASAK’s website, the Strategy Document does not, by itself, create new obligations for obliged entities; it is principally a national policy and implementation roadmap addressed to public authorities. It is nevertheless highly relevant to obliged entities because it signals the legislative, guidance and supervisory priorities for the coming period.

I. Why It Matters

Depriving criminals of illicit proceeds is one of the core tools in fighting crime. The Strategy rests on that premise. For Türkiye, a FATF member since 1991, the approach is not new. However, following the expiry of the previous 2021–2025 Strategy Document announced by Circular No. 2021/16, the new document sets out an updated roadmap framed around FATF’s 40 Recommendations and 11 Immediate Outcomes. It stands out for moving beyond “compliance on paper” and placing greater emphasis on concrete, measurable and outcome-focused implementation.

II.  Seven Strategic Objectives

Unlike its predecessor, the new Strategy Document sets out its goals under seven strategic objectives, each paired in a comprehensive annexed table with concrete activities, responsible institutions, and timing/frequency:

• Effective conduct of judicial and administrative processes in combating money laundering, aligned with the National Risk Assessment (NRA) — systematizing parallel financial investigations for high and medium-high risk threats identified in the NRA, pursuant to the Ministry of Justice’s Circular No. 155/1.
• Strengthening structures specific to terrorist financing — Enhancing the national risk assessment, information sharing, financial investigations and prosecutions relating to terrorist financing.
• Keeping the National Risk Assessment (NRA) current — Developing statistical infrastructure for risk-based, measurable and data-driven policy, and preparing typology guides on prominent trends and methods.
• Effectiveness of seizure and confiscation practices — prioritization based on national risks, system integration, and strengthening customs controls over cross-border movements of cash and bearer-negotiable instruments.
• Effective use of targeted financial sanctions — monitoring and supervising asset-freezing decisions under Law No. 6415.
• Strengthening obliged sectors — This objective is the focus of this article and is the one that most directly concerns private-sector obliged entities.
• Strengthening compliance with international standards and cooperation — reviewing legislation for alignment with FATF standards and making effective use of information-exchange channels.

III. Key Points and Practical Steps for Obliged Entities

Although the Document is principally addressed to public authorities, its most visible implications for private-sector obliged entities arise under Strategic Objective 6. The main areas that obliged entities can review now are as follows:

• Risk-based supervision is being institutionalised. Sectoral risk classifications will be updated and supervisory plans will focus on higher-risk areas. Align your enterprise-wide risk assessment with current NRA findings and review your sector’s risk classification.
• Beneficial ownership and shareholding transparency are being strengthened. The scope of the Electronic Commercial Ledger System is expected to expand, and beneficial ownership declarations will be compared with registry records. Test the consistency of beneficial ownership declarations against trade registry and shareholding records, confirm whether the current electronic-ledger requirements apply to you, and prepare for their future expansion.
• Compliance programmes will be aligned with the NRA. Entities required to establish a compliance programme should update their institutional policies, risk management, monitoring and control, training and internal audit components in line with NRA results, together with financial-group arrangements where applicable. Make explicit references to NRA findings in policies, procedures and controls, and document changes through management approval and supporting records.
• The quality of suspicious transaction reports is gaining importance. Existing reports, particularly those indicating possible beneficial ownership inconsistencies, will be prioritised for analysis. Incorporate beneficial ownership inconsistencies into customer and transaction risk analysis and, where the statutory suspicion threshold is met, submit a timely, well-reasoned and sufficiently detailed STR.
• Sanctions and supervisory capacity will be strengthened. The deterrence, effectiveness and proportionality of supervisory sanctions will be reviewed, while the number of staff available for assignments by MASAK and sectoral supervisory bodies will increase.  In anticipation of more intensive risk-based supervision, test your documentation and record-keeping, the rationale for decisions and your ability to produce records promptly.

IV. Activity Timetable: Timeframes and Responsible Institutions

The document’s most concrete innovation is that its annexed activity table ties each item to a responsible institution and a timeframe/frequency. The key intervals:

• Continuous: Most operational activities, such as parallel financial investigations, seizure/confiscation prioritization, beneficial ownership checks, and priority STR analysis.
• At least quarterly: Regular meetings of the main working groups (Threat, Vulnerability, Sanctions Monitoring).
• Every six months: Inter-agency technical meetings on targeted financial sanctions, and cross-checks between the beneficial ownership registry and the trade registry.
• Annually: Assessment of supervision results and violation trends, and guidance activities.
• Every two years: Preparing typology guides on prominent money laundering and terrorist financing trends and methods; developing core statistical datasets and the institutional and technical infrastructure for statistics.

Responsible institutions include the Ministry of Justice, MASAK, the Revenue Administration, the Capital Markets Board, the Banking Regulation and Supervision Agency, the Central Bank of the Republic of Türkiye (CBRT), the Insurance and Private Pension Regulation and Supervision Agency, the Ministry of Trade and numerous other public authorities. MASAK is designated as the institution responsible for monitoring and reporting on implementation.

V. What Has Changed Compared to the 2021-2025 Document?

Compared with the previous document, the new Strategy establishes a materially broader and more operational framework. The main changes are as follows:

• The strategic objectives were restructured. Under seven strategic objectives, the new Document addresses money laundering and terrorist financing investigations, keeping the National Risk Assessment current, seizure and confiscation, targeted financial sanctions, compliance with preventive measures and international cooperation as distinct pillars. The scope and placement of matters addressed under different headings in the previous Document were updated in light of new risks and implementation needs.
• Provisions concerning private-sector obliged entities were consolidated within a single objective. Matters previously spread across different objectives including compliance management, supervision, data sharing, beneficial ownership and reporting quality are now grouped under Strategic Objective 6. This is one of the most visible structural changes for private-sector obliged entities.
• Beneficial ownership appears for the first time as a distinct target (6.3). Concrete new steps were introduced, such as six-monthly cross-checks between the beneficial ownership registry and the trade registry, and expanding the requirement to keep share ledgers in electronic form.
• International cooperation became a stand-alone objective (Objective 7). In the previous document it existed at the level of a single target (1.2).
• Coordination structures were developed. In addition to the Coordination Board, the Strategy permits Legislation and Case Sub-Working Groups to be established where needed, and envisages sectoral Risk Analysis Working Groups and a Compliance and Supervision Working Group. The principal working groups are planned to meet quarterly.
• Emphasis on statistics and measurability strengthened. New Target 3.2 envisages establishing a systematic statistical infrastructure for risk-based, data-driven policy which is, in fact, a direct requirement of the FATF effectiveness assessment.
• The reporting line was simplified. Whereas the previous document required reporting to the Presidential Security and Foreign Policies Board and the Legal Policies Board, the new document states that progress will be reported directly to the Presidency.
• Sectoral participation was broadened. Crypto-asset service providers are expressly included in the new Document’s list of sectoral stakeholders, underscoring the sector’s growing importance in implementation and supervision.

VI. The FATF Fifth Round and the Post-Grey-List Period

Türkiye was placed on FATF’s list of jurisdictions under increased monitoring in October 2021 and was removed on 28 June 2024 after completing its action plan. FATF Plenary adopted Türkiye’s fifth-round mutual evaluation report on 19 June 2026; the report is expected to be published in September–October 2026 following the Global Network quality and consistency review. The new Strategy Document should therefore be read not as preparation for an upcoming fourth-round evaluation, but as a policy framework for sustaining the improvements that supported Türkiye’s removal from increased monitoring and for implementing, at national level, the time-bound Key Recommended Actions arising from the fifth-round evaluation once the report is published.

Under FATF’s current methodology, the decisive question is not only whether rules exist on paper, but also the extent to which they produce effective results in practice (the 11 Immediate Outcomes). The Document therefore emphasises areas in which effectiveness can be demonstrated, including statistical infrastructure, beneficial ownership, risk-based supervision and outcome-focused investigations. For obliged entities, this means that the supervisory question “Is there a process?” will increasingly become “Does the process produce effective results?

VIII. Conclusion

Obliged entities should read the Document not as a legislative instrument that itself creates new obligations, but as a roadmap indicating policy and supervisory priorities for the coming period. Proactive preparation particularly in beneficial ownership, risk-based internal controls and keeping compliance programmes current can help manage supervisory and reputational risks more effectively. The implementation calendar makes clear that this is not a one-off exercise, but a process that must continue at regular intervals.