EN-US 
TR-TR 
Introduction
The summer of August 2025 cast a stark light on the vulnerabilities of Türkiye’s governance framework: from the fake diploma scandal implicating nearly 200 individuals abusing the e‑Devlet system, to politically charged arrests of municipal officials, and abrupt legal developments in ongoing corruption probes. These developments, paired with heightened global interest in sanctions enforcement and export controls, underscore that Türkiye’s existing anti‑corruption legal framework remains dangerously under-equipped to withstand internal malfeasance and evolving international scrutiny.
At its core, Türkiye’s anti‑corruption system is built upon the Turkish Criminal Code (Law No. 5237)—which criminalizes bribery, money laundering, and abuse of office—but enforcement remains inconsistent, fragmented, and frequently politicized. Structural gaps persist: corporate liability is ambiguous or limited to secondary sanctions, whistleblower protection is virtually non-existent outside piecemeal labor and penal provisions, and there is no independent anti‑corruption authority, leaving integrity enforcement fractured and vulnerable to executive capture.
Meanwhile, Türkiye’s standing on the Corruption Perceptions Index remains low—scoring just 34/100, placing it 107th out of 180 countries in 2024. The OECD has issued repeated warnings about the politicization of anti‑corruption probes, weak enforcement of foreign bribery laws, and the absence of proactive measures to detect or prosecute misconduct.
Given this reality, law firms advising international and domestic clients face dual challenges: safeguarding compliance amidst a murky domestic enforcement environment, and helping shape a legal architecture that can withstand both corruption and sensitive sanctions-related risks. What follows is an overview of key legal deficiencies — from enforcement lacunae to institutional opacity — followed by targeted reform proposals. These recommendations aim to strengthen governance resilience, align Türkiye with international anti-corruption and sanctions norms, and restore public and investor confidence in the rule of law.
Current Legal Framework in Türkiye
The legal structure addressing corruption in Türkiye is primarily grounded in the Turkish Criminal Code, which defines and penalizes bribery, embezzlement, abuse of office, and related financial crimes. Bribery provisions extend to both public officials and private sector actors, but the emphasis remains on individual liability. The Code prescribes prison sentences and monetary fines, with aggravating circumstances where offenses involve public procurement or the misuse of public office.
Complementing the Criminal Code is the Law on the Declaration of Assets and Combatting Bribery and Corruption, which requires certain categories of public officials to disclose assets and financial interests. While intended to promote transparency, implementation has been criticized as uneven, with gaps in enforcement and limited mechanisms to verify the accuracy of declarations.
The Public Servants Law provides the ethical framework for civil service conduct, setting out rules on conflicts of interest, restrictions on gifts, and duties of impartiality. However, the provisions are often broad, leaving interpretation to administrative discretion, which weakens their deterrent effect. In practice, breaches frequently result in disciplinary rather than criminal proceedings, reducing the seriousness with which corruption-related misconduct is addressed.
For the defense and strategic sectors, additional safeguards exist under Laws No. 5201 and 5202, as well as their associated regulations and security directives. These provisions establish licensing, facility security, and personnel clearance requirements, indirectly supporting anti-corruption by regulating sensitive procurement and preventing unauthorized access to classified projects. However, these measures are designed primarily for national security and export control purposes, not as anti-corruption instruments, which limits their direct applicability.
Türkiye has also taken steps to align with international commitments, including obligations under the OECD Anti-Bribery Convention, the United Nations Convention against Corruption, and participation in multilateral export control regimes. Despite these frameworks, enforcement of foreign bribery cases has been rare, and international bodies continue to note deficiencies in proactive investigations, whistleblower protections, and the absence of corporate criminal liability.
Overall, while Türkiye has a robust set of statutory instruments on paper, the legal framework remains fragmented, heavily reliant on individual accountability, and insufficiently supported by independent institutions. These limitations create systemic vulnerabilities that recent scandals have brought into sharp focus.
Structural Deficiencies
Despite the existence of a statutory framework, Türkiye’s anti-corruption regime is undermined by persistent structural weaknesses that reduce the effectiveness of enforcement and weaken institutional credibility. The most significant issue is the selective application of anti-corruption laws. Investigations and prosecutions often appear concentrated on opposition figures or politically sensitive municipalities, while similar allegations in other contexts may not be pursued with equal vigor. This perception of politicization erodes public trust and diminishes the deterrent effect of legal provisions.
Another critical deficiency lies in the absence of clear and enforceable corporate liability for corruption offenses. While individuals can face criminal sanctions, companies implicated in bribery, bid-rigging, or illicit financial practices are largely shielded from direct criminal accountability. This creates a regulatory imbalance, as corporate structures can be used to conceal misconduct, yet remain beyond the reach of meaningful penalties. International standards, particularly those under the OECD Anti-Bribery framework, emphasize the need for corporate responsibility, an area where Türkiye continues to lag.
Transparency deficits compound the problem. Public procurement processes, particularly in large-scale infrastructure and defense projects, often lack sufficient oversight. Limited disclosure of beneficial ownership and exemptions applied to certain tenders create fertile ground for corrupt practices. The opacity of state-owned enterprises and the Türkiye Wealth Fund further restricts external scrutiny, leaving substantial areas of public spending beyond the reach of independent audit.
Whistleblower protection is another area of weakness. Existing labor and administrative provisions offer no comprehensive safeguards for individuals reporting corruption, sanctions evasion, or other misconduct. Without legal guarantees of anonymity, non-retaliation, and judicial remedies, potential whistleblowers are deterred from coming forward, cutting off a vital channel of early detection.
Finally, the absence of an independent anti-corruption body reduces the institutional weight behind existing laws. Oversight is dispersed among prosecutorial offices, audit courts, and inspectorates, none of which operate with full autonomy or a singular mandate to combat corruption. This fragmentation leads to overlap in some areas, neglect in others, and ultimately undermines the coherence of enforcement policy.
These deficiencies collectively create an environment where corruption cases are pursued inconsistently, sanctions enforcement risks remain high, and international confidence in Türkiye’s governance is diminished. Addressing them requires not only legislative amendments but also institutional reforms that align enforcement practices with international standards of independence, accountability, and transparency.
Corruption–Sanctions Nexus
The deficiencies in Türkiye’s anti-corruption framework have implications that reach far beyond domestic governance. In today’s regulatory climate, corruption and sanctions compliance are increasingly intertwined, particularly in sectors such as defense, aerospace, and strategic trade where Türkiye is both a regional hub and a global supplier. Weak enforcement against bribery, bid manipulation, or fraudulent documentation not only undermines the integrity of public institutions but also exposes the country to heightened sanctions risk.
The most immediate concern is that corruption creates entry points for sanctions circumvention networks. Fraudulent practices in licensing, procurement, or customs declarations can be exploited to channel controlled goods into prohibited markets. When oversight mechanisms are weak or selectively enforced, international regulators view Türkiye as a potential jurisdiction of concern, leading to stricter due diligence by foreign banks, suppliers, and compliance departments. This was evident during Türkiye’s recent experience on the FATF grey list, where deficiencies in financial transparency and monitoring were linked to systemic governance weaknesses.
In the defense sector, opacity in procurement and industrial participation agreements raises additional risks. Complex offset arrangements, exemptions from procurement rules, and limited beneficial ownership disclosure make it difficult to ensure that contracts are free from corruption or sanctions exposure. International buyers and partners increasingly demand compliance not only with export control regulations but also with anti-bribery and anti-money laundering standards. Failure to meet these expectations places Turkish companies at a competitive disadvantage and exposes them to reputational harm.
Moreover, selective enforcement of corruption cases undermines confidence in the independence of the judiciary, which is a key factor in assessing the reliability of Türkiye’s legal environment. International institutions and counterparties are more likely to impose enhanced compliance requirements, or even restrictions, where they perceive the rule of law to be compromised. For companies engaged in cross-border trade, this translates into higher compliance costs, reduced access to financing, and greater scrutiny of contracts and counterparties.
The intersection of corruption and sanctions compliance is therefore not merely theoretical. It is a practical challenge for businesses, investors, and public institutions that must navigate an environment where the perception of weak governance can trigger tangible regulatory and financial consequences. Strengthening the anti-corruption framework is thus not only a matter of domestic reform but also a prerequisite for securing Türkiye’s standing in global trade and mitigating exposure to sanctions-related enforcement.
Proposed Legal Reforms
To address the systemic weaknesses revealed by recent scandals and to align Türkiye with international standards, a series of legislative and institutional reforms are necessary. These reforms should focus not only on tightening anti-corruption measures but also on integrating them into the broader sanctions and compliance framework.
The first priority is to introduce comprehensive corporate liability provisions into the Turkish Criminal Code. At present, companies are largely insulated from direct criminal accountability, with sanctions falling almost exclusively on individuals. A modernized approach would ensure that corporations can be held liable for bribery, bid-rigging, and sanctions circumvention conducted through their officers, employees, or intermediaries. This would bring Türkiye into alignment with the OECD Anti-Bribery Convention and enhance deterrence by making companies responsible for implementing internal compliance programs.
Second, Türkiye should establish an independent anti-corruption authority with investigative and prosecutorial powers. Current oversight is fragmented across inspectorates, courts, and ministries, diluting accountability. A dedicated body, operating with institutional autonomy and parliamentary oversight, would centralize expertise, ensure consistent enforcement, and reduce the perception of selective prosecutions.
Third, the enactment of a Whistleblower Protection Law is essential. The law should guarantee anonymity, prohibit retaliation, and provide judicial remedies for individuals reporting corruption, sanctions breaches, or other forms of misconduct. By creating a safe channel for disclosures, authorities would gain early visibility into corruption risks that currently remain hidden.
Fourth, reforms must enhance transparency in public procurement and defense contracts. Amendments to the Public Procurement Law should limit exemptions, mandate disclosure of beneficial ownership, and subject high-value or strategic projects to independent audits. In the defense sector, offset agreements and industrial participation contracts should include mandatory compliance clauses addressing anti-corruption and sanctions risks.
Fifth, export control laws and defense security regulations (notably Laws No. 5201 and 5202) should be updated to integrate corruption-screening mechanisms into licensing procedures. This could include requiring applicants for export and production licenses to certify compliance with anti-bribery laws, submit internal compliance policies, and disclose any ongoing investigations. Linking corruption enforcement with export controls would address the dual risks of sanctions evasion and illicit procurement.
Finally, reforms should strengthen judicial independence and oversight. Legal amendments alone are insufficient without credible enforcement by impartial courts. Ensuring transparent judicial appointments, protecting judges from political interference, and creating specialized chambers for corruption and compliance cases would reinforce the rule of law and restore international confidence in Türkiye’s legal system.
Collectively, these reforms would modernize Türkiye’s anti-corruption regime, close critical gaps in the current framework, and enhance resilience against both domestic misconduct and international sanctions risks. By embedding compliance at the core of public governance and corporate responsibility, Türkiye would strengthen its legal credibility, support sustainable foreign investment, and safeguard its role in sensitive defense and strategic trade markets.
Conclusion
The events of August 2025 exposed how fragile Türkiye’s anti-corruption architecture remains in the face of systemic misconduct and politicized enforcement. The fake diploma scandal and ongoing municipal investigations have highlighted not only the prevalence of fraudulent practices but also the risks of undermining institutional credibility through selective prosecutions. At the same time, Türkiye’s obligations under international sanctions and export control regimes demand a higher standard of governance, compliance, and transparency than the current system provides.
Reform is therefore no longer optional. Introducing corporate liability, protecting whistleblowers, and creating an independent anti-corruption authority are structural steps that would address the root causes of recurring scandals. Enhancing transparency in public procurement and embedding anti-corruption safeguards into defense and export control regulations would close critical compliance gaps. Above all, strengthening judicial independence remains the linchpin for ensuring that reforms are not only enacted but effectively enforced.
By addressing these deficiencies through targeted legislative and institutional amendments, Türkiye can restore trust in its governance framework, safeguard its economic and defense partnerships, and demonstrate its commitment to international compliance standards. In doing so, it will not only confront the immediate challenges of corruption but also secure long-term resilience against the twin pressures of sanctions enforcement and global market scrutiny.
