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Global Anti-Corruption Wave Meets Turkey’s Reality: Around the world, the fight against corruption has intensified to an unprecedented degree. Major powers have elevated anti-corruption to a core strategic priority – in the United States, President Biden explicitly declared combating corruption a “core U.S. national security interest” in 2021, linking graft to threats against democracy and stability. Multilateral bodies like the G20 and OECD are likewise coordinating crackdowns on bribery and illicit finance, treating corruption not just as a legal issue but as a geopolitical menace. This global pressure forms the backdrop for Türkiye in 2025: a country facing scrutiny as both a high-corruption-risk environment and a nexus in international enforcement cases. Western regulators have shown they will pursue bribery wherever it occurs – from African oilfields to Turkish boardrooms – and they increasingly work together across borders. Recent years have seen multi-jurisdictional investigations (for example, the Airbus and Rolls-Royce settlements) yielding near billion-dollar penalties and involving dozens of countries. The clear message is that unethical conduct anywhere can trigger enforcement everywhere in today’s interconnected marketplace.
At the same time, Türkiye’s domestic approach to corruption stands in stark contrast. Despite formal laws against bribery, enforcement on the ground has been minimal, especially when it comes to high-level or politically connected offenders. This gap has not gone unnoticed. The OECD’s Working Group on Bribery delivered a scathing assessment in 2024, expressing “grave concern” at Türkiye’s lack of action and interference in corruption probes. As of 2025, Turkey has never secured a single conviction for foreign bribery, earning it an “absolute failing” grade from experts. In effect, the burden of policing corruption involving Turkish actors has fallen to foreign authorities – a trend underscored by U.S. and UK cases imposing hefty fines on firms for misconduct tied to Turkey. For Turkish companies and investors, this convergence of a weak domestic enforcement regime with robust international oversight creates a precarious situation. The following sections provide an updated, in-depth look at Türkiye’s corruption landscape in late 2025 – from persistent local problems and politicized crackdowns to the lessons emerging from global enforcement – and offer guidance on how businesses can navigate these challenges.
Türkiye’s Enduring Corruption Challenges in 2025
Stagnant and Backsliding on Transparency: Turkey continues to rank among the world’s more corrupt countries in perception indices, with little sign of improvement. Transparency International’s latest Corruption Perceptions Index score for Turkey is just 34 out of 100, well below the global average of 43. This score places Turkey 107th of 180 countries – a slight uptick in rank from the prior year’s 115th only because other countries worsened, not due to any Turkish progress. In fact, Turkey’s score of 34 is the lowest in over 15 years, and it has lost 16 points since 2013 when it hit a high of 50. This long-term decline marks one of the sharpest drops globally and correlates with a well-documented erosion of checks and balances since the late 2013 corruption scandals. Transparency International’s analysis identifies the root causes: the absence of an independent and effective anti-corruption body, the weakening of oversight institutions, and a lack of genuine reforms. In short, the legal framework on paper is not the issue – it’s the near-total collapse of impartial enforcement and accountability. Turkey’s standing in broader rule-of-law metrics reflects the same problem: in the World Justice Project’s 2024 Rule of Law Index, Turkey ranked a dismal 117th out of 142 countries, indicating systemic governance deficits that enable corruption.
Institutional Weakness and Political Interference: A defining feature of Turkey’s corruption climate is the impunity enjoyed by those with political influence. Laws criminalizing bribery exist, but enforcement agencies – from prosecutors to financial regulators – lack independence from the executive. No case makes this clearer than the notorious December 2013 corruption investigation. In that probe, Turkish prosecutors and police uncovered a sweeping bribery and money-laundering scheme implicating the sons of three ministers, the head of state-owned Halkbank, and an Iranian-Turkish trader (Reza Zarrab) at the center of an oil-for-gold sanctions-busting racket. Raids found evidence like $4.5 million in cash stashed in shoe boxes in Halkbank’s CEO’s home, and the allegations reached the highest levels of government. Yet instead of allowing the prosecutions to proceed, the administration of then-Prime Minister (now President) Erdoğan intervened to quash the investigations. Dozens of police chiefs and prosecutors were summarily removed from their posts; within weeks, all charges were dropped and the inquiry was reframed by the government as a “foreign plot” or coup attempt. Erdoğan’s party used its parliamentary majority to restructure the judiciary, creating special courts and installing loyalist judges. Those courts then jailed or charged the very officials who led the corruption probe, while the implicated ministers and family members never saw a day in court. This episode, effectively ending any independence in Turkey’s anti-corruption enforcement, was a turning point. Subsequent years saw further politicization: after a failed coup in 2016 (which Erdoğan blamed in part on the same network behind the 2013 probes), over 4,000 judges and prosecutors were purged and replaced largely with government-aligned appointees. Whistleblower protections remain effectively nonexistent, and investigative journalism on corruption is muzzled by censorship and the risk of reprisal. The OECD’s 2024 review bluntly noted that Turkey has not achieved a single foreign bribery conviction, citing “political interference in enforcement, limited press freedom, and nonexistent whistleblower protections” as critical flaws. In sum, the institutions that should safeguard integrity – law enforcement, judiciary, free media – have been hollowed out or co-opted, leaving honest officials with little support and corrupt actors with little to fear internally.
CHP opposition supporters march in Ankara on April 23, 2025, defying a government ban during a National Sovereignty Day rally (a protest implicitly linked to demands for accountable governance). The ruling party’s control over institutions has bred public resentment, while authorities often respond to dissent with crackdowns rather than reforms.
Political Weaponization of Corruption Accusations: An ironic twist in 2025 is that while pro-government corruption is swept under the rug, Turkish authorities have aggressively pursued opposition figures for alleged graft. In the wake of Turkey’s March 2024 local elections – in which the main opposition Republican People’s Party (CHP) won or retained key mayoralties – the government launched a series of sprawling corruption investigations targeting those very municipalities. By October 2025, seven CHP mayors (including the metropolitan mayors of İstanbul, Ankara, and Adana) and nearly 200 others had been indicted on charges ranging from tender-rigging to bribery. Among those ensnared was Ekrem İmamoğlu, Istanbul’s popular opposition mayor and a potential presidential rival, who was detained in March 2025 and later suspended from office on what supporters called trumped-up corruption charges. Similarly, Ankara’s Mayor Mansur Yavaş and others came under investigation. The indictments allege that a network led by a businessman conspired with officials to rig municipal service tenders (for example, for vehicle leasing and waste collection) since 2016. Notably, that businessman turned state’s witness under a plea deal, a move cynics say conveniently provided testimony to implicate opposition mayors. The CHP vehemently denounces these probes as politically motivated “witch hunts” aimed at invalidating the opposition’s democratic victories. Indeed, the timing and scale are telling: the investigations kicked off with police raids on CHP-run city halls just months after the elections, and government officials parroted the narrative that they were cleaning up CHP corruption. Meanwhile, allegations of ruling-party corruption remain untouched by prosecutors. The markets have taken notice of this selective justice. In March 2025, when İmamoğlu’s arrest hit the news, Turkish stocks and bonds plunged, marking the year’s sharpest sell-off. Investors were rattled by what they perceived as a lurch toward authoritarianism and legal arbitrariness, undermining hopes of reform. Subsequent waves of opposition crackdowns caused further capital outflows. The episode underscores how the government’s anti-corruption rhetoric is undermined by its own partisan bias: enforcement is directed only at rivals, undercutting its legitimacy. Not only does this fail to address genuine corruption, it also deepens political polarization and deters foreign investment (as confidence in rule of law erodes). In essence, Turkey in 2025 exhibits a paradoxical dynamic – corruption remains rampant and largely unpunished, except when accusations serve to entrench those in power.
Entrenched Corruption Networks and Sectoral Vulnerabilities: Beyond the headlines of political scandal, corruption in Turkey is enabled by deeply entrenched patronage networks, especially in sectors where government and big money intersect. The construction/infrastructure sector is a prime example. Over two decades of rule, the Erdoğan administration came to rely on a coterie of favored conglomerates for huge state projects – so much so that Turkish media and opposition refer to them as the “Gang of Five.” These five firms (Cengiz, Limak, Kolin, Kalyon, and MNG Holdings) have together been awarded a staggering $203 billion in public contracts since 2002. They built airports, bridges, highways, power plants, and city hospitals, often via public-private partnerships with Treasury-guaranteed revenues (meaning the state ensures their profits). In return, they have been reliable donors and supporters of the government. This cozy arrangement has been rife with corruption red flags: many contracts are granted through less-than-transparent tenders (sometimes single-bid or with tailored specifications), and independent audits are scarce. It’s telling that four of these five tycoons were implicated in the 2013 corruption probes, accused of bribing ministers for favorable treatment. All such charges vanished after the probes were quashed, and instead of being blacklisted, the same companies went on to win even more mega-projects. Investigations by opposition lawmakers and journalists (for instance, using parliamentary questions and leaked documents) have alleged that many contracts were grossly inflated in cost – essentially, overpaying politically connected contractors with taxpayer money. A World Bank report noted that these Turkish firms dominated global rankings of public infrastructure developers by investment volume, highlighting how unusually large Turkey’s patronage has been. The consequences of this “rentier system” (as it’s often called in Turkey) are now visible. Turkey’s rapid building spree came “at all costs,” as one analyst put it – often at the cost of safety and quality. The February 2023 earthquake tragedy brutally exposed how corruption in construction can be deadly. After a 7.8 magnitude quake struck, over 24,000 buildings collapsed or were severely damaged across southeastern Turkey, contributing to a death toll above 50,000. Public outrage zeroed in on contractors who skirted building codes and officials who turned a blind eye. It was widely reported that many collapsed buildings had been flagged for code violations or were constructed under Turkey’s notorious “zoning amnesties” (periodic legalizations of unpermitted buildings in exchange for fees) – policies that Erdogan’s government championed and that critics label state-sanctioned corruption. “The murderer is not the earthquake, but those who made corruption standard practice in construction,” a Turkish columnist wrote, reflecting the popular sentiment. Indeed, Turkey’s CPI rank plummeted from 54th to 101st between 2012 and 2022 partly because the construction boom was accompanied by rising graft and fewer bribery arrests. The government, feeling the heat, promised to punish negligent builders, and some contractors were arrested. But many Turks note that authorities themselves enabled the crisis by trading safety for kickbacks and political favor. In sectors like energy and defense, similar vulnerability exists. The energy industry (oil, gas, power) involves huge licensing deals and partnerships with state enterprises, which invite rent-seeking. A glaring historical case was the “gas-for-gold” scheme tied to Iran sanctions evasion in 2012-2013, where bribes greased the wheels for illicit trade through Halkbank. In defense, where secrecy is higher, Turkey’s procurement has been criticized for opacity and favoritism – Transparency International’s Government Defense Integrity Index rates Turkey’s defense sector risk as “Very High,” citing non-transparent budgets and political influence over contracts. All these examples point to a common thread: a nexus of business and politics that operates with little transparency or accountability, resulting in systemic corruption. This domestic reality not only harms Turkey’s governance and economy – it also dramatically raises the stakes for companies operating in this environment, as discussed next.
International Enforcement Actions Turning up the Heat
Given Turkey’s internal enforcement vacuum, foreign regulators have increasingly stepped in to police corruption that touches Turkish entities or officials. In the past few years, a string of high-profile international enforcement actions – especially under U.S. and UK laws – have held companies accountable for bribery schemes linked to Turkey. These cases carry important lessons and signals for Turkish companies.
U.S. FCPA: Broad Jurisdiction and Heavy Penalties. The United States has been particularly aggressive in pursuing foreign bribery through its Foreign Corrupt Practices Act (FCPA), and Turkey has figured in numerous enforcement actions. U.S. authorities will assert jurisdiction whenever a Turkey-related scheme has a U.S. nexus (for instance, using U.S. banks or email systems, or involving a U.S.-listed company). The outcomes have been costly. In 2022, tech giant Oracle Corp. paid $23 million to settle SEC charges that its Turkey subsidiary (and two others abroad) created off-book “slush funds” to bribe officials and win business. Oracle’s Turkish unit allegedly used these slush funds from 2014 to 2019 to pay for officials’ travel perks – including taking key government decision-makers (and even their families) on lavish trips to California under the guise of “conference” visits. The SEC penalized Oracle not only for the improper payments but for the internal controls failure that allowed side accounts to exist. Likewise, in 2020, U.S. regulators penalized Alexion Pharmaceuticals about $21 million after uncovering that its Turkey subsidiary paid consultants who funneled money to Turkish health officials to get Alexion’s pricey drug Soliris approved and reimbursed by the state. According to the SEC, from 2010–2015 Alexion Turkey made improper payments to influence regulators and covered it up with false records, evading Alexion’s weak internal audits. These cases are illustrative: even if a bribe is paid in Ankara or Istanbul, if the company has any U.S. connection, American regulators can reach it. The U.S. Department of Justice and SEC have not hesitated to investigate multinational companies and even individuals for schemes involving Turkish deals. By one OECD analysis, as of 2024 the U.S. had brought roughly 20 enforcement actions involving transnational bribery connected to Turkey, resulting in over $1.7 billion in combined penalties – a stark contrast to Turkey’s own zero such prosecutions. The FCPA’s bite can be seen not just in fines but in follow-on consequences: companies may be required to retain independent compliance monitors, overhaul their procedures, and face years of heightened scrutiny. U.S. enforcement also increasingly targets individual culpability. Notably, several foreign nationals have been charged alongside corporations. In the Halkbank case (discussed below), U.S. prosecutors indicted the deputy CEO of Halkbank and a former Turkish minister. These actions serve as a warning: Turkish businesspeople involved in bribery cannot assume they are beyond U.S. reach.
The Halkbank Sanctions-Busting Case: No discussion of Turkey and U.S. enforcement is complete without the saga of Halkbank, Turkey’s second-largest state bank, which sits at the center of a monumental sanctions-evasion and bribery case. This case, while primarily about violating Iran sanctions, is fundamentally entwined with corruption at the highest levels of the Turkish state. In October 2025, the U.S. Supreme Court dealt the latest blow to Halkbank by rejecting the bank’s final immunity appeal, clearing the way for a federal criminal trial in New York. U.S. prosecutors charge that Halkbank was a linchpin in a scheme (from 2011 to 2016) to launder billions of dollars of Iranian oil and gas proceeds, using gold and fake food shipments – all to circumvent U.S. sanctions. Critically, they allege Halkbank’s operations were greased by tens of millions in bribes to Turkish officials and conducted with the knowledge and direction of top Turkish political leaders. Evidence for these explosive claims emerged during the trial of Halkbank’s deputy general manager in 2017–2018: Reza Zarrab, the trader who orchestrated the scheme, became a U.S. witness and testified that he paid off multiple Turkish ministers (naming the ministers of economy, interior, and EU affairs) and that a cut of the illicit profits was promised to then-Prime Minister Erdoğan himself. One codeword in leaked communications was “ABI” (“big brother”), alleged to refer to Erdoğan and his share. Photos from the 2013 Turkish police raids – such as piles of cash found in shoeboxes and in a minister’s son’s safe – corroborated the scale of the graft. Erdoğan’s administration, however, shut down the Turkish case and framed it as an international plot (targeting the investigators for retaliation). But U.S. authorities picked up the thread: they arrested Zarrab in 2016 when he traveled to Miami, prosecuted Halkbank’s deputy CEO (who was convicted and later freed to Turkey), and in 2019 formally indicted Halkbank itself on fraud, money-laundering, and conspiracy charges. Halkbank tried to fight this by claiming sovereign immunity as a Turkish state entity. After years of litigation, U.S. courts definitively rejected that claim – the appellate court in 2024 and the Supreme Court in 2025 – ruling that engaging in commercial illicit transactions is not a protected state act. This means Halkbank will likely stand trial in the U.S., an event unprecedented for a state-owned bank of a NATO ally. The potential fallout is immense: a conviction could result in massive fines and effectively cut Halkbank off from the U.S. financial system. Moreover, a public trial may unearth yet more evidence of high-level Turkish corruption. The mere prospect has clearly unnerved Ankara – reports indicate Erdoğan lobbied multiple U.S. presidents to make the case “go away,” and Turkey even appeared to engage in hostage diplomacy (detaining U.S. citizens) to gain leverage over Washington regarding this case. These efforts failed. The Halkbank case starkly illustrates that conduct immunized at home can boomerang abroad. Turkish officials quashed a corruption investigation in 2013, but a dozen years later the matter is still alive in foreign courts, posing grave risks to a major Turkish institution and potentially implicating Turkey’s leadership on the international stage. For Turkish companies, the lesson is that hiding behind sovereignty or political patronage is not a reliable shield when global regulators are in play.
UK Bribery Act and Personal Accountability: The United Kingdom has likewise shown its reach in punishing Turkey-related corruption, thanks to the UK Bribery Act’s broad scope (which, for instance, can cover non-UK companies that fail to prevent bribery by associated persons). A headline case occurred in 2023–2025 involving Entain plc, a British gambling company (owner of Ladbrokes betting shops). In 2023, Entain entered into a Deferred Prosecution Agreement after a UK investigation found extensive bribery in its former Turkish operations. The settlement was eye-popping – Entain agreed to pay £585 million (approximately $737 million) in penalties, one of the largest corporate bribery settlements in UK history. The case related to Entain’s use of third-party suppliers and affiliates in Turkey up until 2017, which were effectively paying off local officials (and possibly processing illicit funds) to facilitate the company’s online betting business in Turkey (where gambling is heavily regulated). The UK’s Crown Prosecution Service (CPS), rather than the Serious Fraud Office, handled this matter, marking the first-ever CPS DPA and signaling that multiple UK agencies are willing to pursue corruption cases. Crucially, the story didn’t end with the corporate fine. In October 2025, the CPS took the next step of criminally charging 11 former Entain executives – including the ex-CEO and ex-Chairman – for offenses like bribery, fraud, and money laundering stemming from the Turkish scheme. These individuals are accused of knowingly allowing or facilitating corrupt payments to foreign officials and of defrauding tax authorities. The first court hearings are scheduled in London, demonstrating the UK’s commitment to holding people accountable, not just companies. This development would have been unthinkable a decade ago; now, top executives face the possibility of convictions and prison. The UK Bribery Act’s corporate “failure to prevent bribery” offense essentially forced Entain to settle (since it clearly hadn’t prevented the misconduct), but it’s the traditional fraud and bribery statutes that are ensnaring the executives. For Turkish companies, this case is a potent warning. Even if a company has exited a market or ended a problematic practice, authorities can come knocking years later – and they will scrutinize the C-suite. A company’s only real defense under the UK Act is to show it had “adequate procedures” in place to stop bribery; in Entain’s case, the lack of such procedures for its Turkish business proved costly. By contrast, a company that can demonstrate a strong compliance program stands a much better chance of avoiding such fate (or may even avoid charges entirely). The UK’s activism, combined with U.S. efforts, signals that no jurisdiction is a safe haven for bribery. Enforcement is increasingly international and coordinated. For instance, many recall the 2017 Rolls-Royce case, where the UK, U.S., and Brazil coordinated a global resolution of bribery allegations (some involving markets like Asia and the Middle East) for a total of ~$800 million in penalties. Similarly, the 2020 Airbus settlement involved France, UK, and U.S. working in tandem to address a decade of bribes across multiple countries. Turkey itself was reportedly among the countries where Airbus had questionable dealings, illustrating that Turkey can be both an origin and a target of international bribery – and that external enforcers are watching.
OECD and International Peer Pressure: Turkey’s status as a signatory to the OECD Anti-Bribery Convention means it is under continuous evaluation by peers. The Phase 4 review in 2024 was unusually damning. The OECD Working Group not only highlighted Turkey’s zero foreign bribery enforcement, but explicitly criticized political interference and the stifling of journalists who expose corruption. It’s rare for the OECD to use such sharp language, calling out the government’s role in undermining investigations. The report and subsequent commentary urge Turkey to overhaul its framework – including better whistleblower protections and ending press censorship on corruption matters. If Turkey doesn’t show improvement, it risks increased reputational damage and possibly sanctions within the OECD context (in extreme cases, countries have been publicly named and shamed or suspended from certain privileges for non-compliance). More tangibly, the consequences of Turkey’s inaction are financial: as whistleblower advocate Stephen Kohn pointed out, Turkish and international firms have paid “billions of dollars” in fines to the U.S. that could have gone to Turkey’s treasury if Turkey had prosecuted the cases itself. For example, when a U.S. enforcement action penalizes a company for bribes in Turkey, the U.S. government collects the fine – effectively reaping a windfall that, in theory, Turkey could have claimed in its own courts (and perhaps compensated victims or funded services). This angle – that Turkey is forfeiting money by failing to act – might spur some reconsideration in Ankara, especially at a time of economic strain. Indeed, Turkey showed with the FATF (Financial Action Task Force) that when money is on the line, it can act: after being “grey-listed” for poor anti-money-laundering controls in 2021, Turkey implemented enough technical reforms by 2024 to get itself removed from the grey list, a move meant to boost investor confidence. However, those were largely regulatory tweaks; addressing grand corruption requires confronting powerful interests, which so far Turkey’s leadership has been unwilling to do. International lenders and allies will continue to press Turkey on governance – for instance, the EU in its reports ties progress (or regress) in accession talks to the rule of law and corruption control. While full EU membership is off the table for now, Turkey still benefits from European investment and aid that often come with good governance strings attached. All told, the international community is signaling through multiple channels – law enforcement, economic forums, diplomacy – that Turkey must clean up its act. And even if Turkey’s government remains reluctant, Turkish companies and executives find themselves squarely in the crosshairs of foreign laws if they engage in bribery. In this environment, complacency is dangerous and proactive compliance is the prudent path.
Implications for Turkish Companies – From Legal Exposure to Competitive Edge
No Safe Harbor for Bribery: The foremost lesson for Turkish companies is that geography offers no immunity. In years past, a belief might have persisted that as long as questionable payments happened abroad (or under local cover) and Turkish authorities looked the other way, the risks were low. That belief is untenable in 2025. Extraterritorial laws like the FCPA and UK Bribery Act enable enforcement agencies to prosecute corrupt acts that touch their jurisdictions, even indirectly. If a Turkish construction firm bribes an official in Central Asia and routes the payment through a New York bank, or if a Turkish pharma company listed in London pays kickbacks to a health director in Ankara, these can become cases for U.S. or UK prosecutors. We’ve seen ample evidence: U.S. enforcers penalized Turkish dealings by a French-American oil company (Total SA, in a 2013 case, for bribery in Iranian oil contracts via Turkish mediators), by a U.S. firearms manufacturer (Smith & Wesson, which in 2014 admitted its agent attempted to bribe a Turkish general to win a gun contract), and by numerous others. The long arm of U.S. jurisdiction will reach transactions in Turkey if, say, they involve U.S. correspondent bank accounts (virtually unavoidable in dollar trades) or if a company’s emails transit U.S. servers – both common occurrences. The UK has even made it an offense for a company anywhere to fail to prevent bribery by those performing services for it, which is how it nabbed Entain. What this means for Turkish businesses is that local complacency can be fatal. A company might reason that paying a bribe in an African country is “how business is done” and that Turkey doesn’t enforce against it – but if that country has an anti-bribery treaty partner, or if the payment surfaces through an international bank’s compliance systems, an investigation can kick off abroad. Moreover, enforcement agencies share information. Europol and the FBI, for example, exchange intelligence on corruption and money laundering. In one recent case, U.S. prosecutors indicted individuals involved in bribes to Petrobas (Brazil’s oil company) and explicitly referenced how illicit Turkish and Chinese bank transactions were part of how funds flowed – entwining multiple jurisdictions’ enforcement interests. The bottom line: Turkish companies must assume that corrupt acts will eventually come to light and be judged by the strictest laws applicable. Unethical behavior that might seem hidden in Izmir or Lagos could land a company in a courtroom in New York or London.
Reputation, Investment, and Market Access: Apart from direct legal penalties, corruption poses a significant business risk in terms of reputation and access to opportunities. Turkey’s persistent corruption problems have already undermined foreign investor confidence in the country’s economy, contributing to higher risk premiums. Companies seen as tied into corrupt practices may find Western investors shying away from their bonds or equities. Lenders (especially development banks or export credit agencies) often require anti-corruption covenants – a known corruption scandal could lead to loan defaults or exclusion from credit programs. On the flip side, a clean reputation is increasingly a competitive advantage. Global supply chains and big multinationals are under pressure (from regulators and stakeholders) to ensure their partners adhere to ESG (Environmental, Social, Governance) standards, which include ethical business conduct. A Turkish engineering firm with strong anti-corruption credentials is far more likely to win a subcontract with, say, a European contractor building a clean energy project, than one that has a history of dubious payments. Similarly, if Turkish defense companies want to integrate into European or NATO supply chains, they will undergo rigorous due diligence – any whiff of bribery (past or present) could disqualify them or at least make the approval process arduous. We can already see this in action: defense tenders in Western countries often ask bidders to disclose any past corruption investigations; companies with incidents may be required to certify improvements or risk being barred. Furthermore, consider foreign direct investment: Turkey’s need for external capital is acute, and its policymakers know that transparency is key to attracting it. Mehmet Şimşek, Turkey’s finance minister appointed in 2023 to help restore economic credibility, has repeatedly signaled the importance of rule-of-law improvements to reassure investors. When Turkey got off the FATF grey list in mid-2024, officials touted it as making the financial system more attractive to investors. By the same token, if Turkey were ever to show progress on anti-corruption, it could unlock investment flows. But absent that, Turkish companies can take micro steps: demonstrating self-regulation and clean business practices to differentiate themselves from the negative perception of their environment. Some forward-looking Turkish firms have begun voluntarily adopting international compliance standards (for instance, obtaining ISO 37001 Anti-Bribery Management certification) to send a message to partners and clients. In the long run, aligning with global anti-corruption norms isn’t just about avoiding trouble – it’s about being part of the legitimate global economy. With the EU looking to impose stricter due diligence on supply chains and the U.S. considering requirements on companies to report beneficial ownership and corruption risks, the writing is on the wall: companies that play clean will have more doors open to them, those that don’t will see doors close.
Personal Liability for Executives and Directors: Turkish corporate leaders should also heed the shifting landscape of individual accountability. It is no longer unthinkable that a Turkish CEO or board member could face charges or travel restrictions due to an anti-corruption probe. The UK’s charging of former Entain executives is a case in point – one of those charged is the company’s former CEO, a very public figure in the betting industry. If convicted, he and others could face prison and hefty fines. The U.S. Department of Justice, under its current guidelines, prioritizes prosecuting individuals responsible for corporate misconduct. We have seen U.S. indictments of foreign officials and businessmen in various FCPA cases; notably, a Turkish citizen who was a key intermediary in a Balkan bribery scheme was indicted by the DOJ a couple of years ago, demonstrating they go beyond just Americans. For Turkish executives, this trend means that turning a blind eye is dangerous. In the past, one might claim ignorance of a corrupt underling’s actions. Today, if you are a senior manager, regulators ask: did you foster the environment that allowed this to happen? If yes, you could be deemed complicit or negligent. Another risk: extradition. Many countries will extradite individuals for corruption charges (especially if money laundering is involved, which it often is). A Turkish executive charged in the UK or US who travels outside Turkey might be arrested in a third country that has an extradition treaty. Even within Turkey, personal liability can arise in new ways. Should there be a political change in the future or an empowered anti-corruption drive domestically, those who oversaw misconduct could be held to account. We already saw hints of this: when opposition mayors took over some municipalities in 2019, they exposed alleged corrupt spending by the previous administrations (aligned with the ruling party) – while no prosecutions ensued (due to the system), the reputational damage to those officials was real. In summary, responsible Turkish business leaders should treat anti-corruption compliance as part of their fiduciary duty. Not only is it about protecting the company, it’s about protecting oneself. This implies setting a strong “tone at the top,” actively inquiring about high-risk transactions, and supporting internal controls and audits. If something does go wrong, regulators will ask: what did the board and CEO do to prevent and respond to this? It’s far better to be able to show that you took decisive steps than to plead ignorance. The era of plausible deniability is ending.
Turning Compliance into Competitive Advantage: While the heightened enforcement landscape may seem intimidating, Turkish companies should also see an opportunity in embracing compliance. Given the country’s reputation issues, those firms that manage to distinguish themselves as transparent and ethical can gain trust that competitors lack. For example, a Turkish company with robust anti-corruption procedures might find it easier to partner with a European firm on a Middle East project because the European side can confidently report to its regulators that its Turkish partner meets international compliance standards. In some sectors, having a good compliance record is becoming as important as price or quality in winning contracts. Think of procurement tenders by multinationals or IFIs (international financial institutions): they often include compliance questionnaires and contractual clauses that allow termination if corruption is found. A firm that already has a culture of zero tolerance will navigate those requirements smoothly, whereas a firm that hasn’t addressed these issues may stumble or even be disqualified. Furthermore, internal benefits exist. Studies have shown that companies with strong ethical practices tend to have less waste, fraud, and abuse internally. Money not lost to bribes or embezzlement is money that can be invested productively. Companies also report that it’s easier to recruit and retain talent when they are known to operate with integrity – young professionals increasingly seek employers whose values align with theirs. In Turkey, where “who you know” has often trumped “how you perform,” a shift towards meritocracy and clean business can actually improve efficiency and innovation in the long run. To draw an analogy: compliance can be like a fitness regime – it may be hard at first for an out-of-shape organization, but once ingrained, it strengthens the overall health and resilience of the company. The many enforcement horror stories – years of legal battles, monitor oversight, and public scandal – provide a roadmap of what not to do. Conversely, companies that proactively self-disclose problems, fix them, and cooperate (when something does slip through) have often avoided the worst outcomes. This proactive approach essentially acts as a shield that can prevent minor issues from becoming existential threats to the business.
Building a Culture of Compliance – Recommendations for Risk Mitigation
1. Invest in Robust Compliance Programs: Every Turkish company operating in corruption-prone environments (which, realistically, includes domestic operations in Turkey itself) should establish a comprehensive anti-corruption compliance program. This isn’t about having a paper code of ethics that sits on a shelf – it’s about embedding processes and controls into daily operations. Leadership must lead by example: company owners, CEOs, and boards should openly commit to ethical conduct and support compliance staff when tough decisions arise (e.g. turning down a deal that poses bribery risks). A good program starts with a risk assessment: identify where the company interfaces with government officials or other high-risk scenarios (permits, procurement, customs, local agents, etc.) and tailor controls accordingly. Policies and procedures should then address these risks – for instance, clear rules on giving gifts or hospitality (with modest value limits and approval requirements), due diligence procedures for vetting third parties, and financial controls like requiring dual sign-offs on large payments. Regular training is crucial: employees and even third-party contractors should be educated on what constitutes bribery, how to recognize solicitation or extortion attempts, and how to report concerns. Effective training will include real-world scenarios relevant to Turkey (such as a tax inspector asking for “commission” to clear a refund, or a project partner hinting at paying an official for zoning approval) so that staff know how to respond. One important element is ensuring the compliance function has clout – the compliance officer (or team) should have direct access to top management or the board and authority to halt transactions if red flags appear. Regulators assessing a compliance program often look at “tone at the top” and “empowerment of gatekeepers.” For example, the UK’s guidance on the “adequate procedures” defense outlines the need for top-level commitment and risk-based due diligence, while U.S. DOJ guidance (updated in 2020 and 2023) lists hallmarks of effective programs such as autonomy of the compliance function and a culture of incentives for ethical behavior. Turkish firms can also seek external certification or advice – there are local chapters of organizations like Transparency International and professional services firms in Turkey that can help benchmark a program against global standards. It’s worth noting that regulators don’t expect perfection; they do expect a good faith effort. In cases where companies avoided prosecution, it’s often because they were able to show that they had a strong program and the misconduct was an outlier that they reacted to swiftly. Thus, investing in compliance is like an insurance policy – it may not yield immediate profit, but it guards against potentially catastrophic losses and can pay dividends by improving operations.
2. Rigorous Due Diligence on Third Parties: A vast majority of bribery cases involve intermediaries or third parties. In Turkey, it’s common to use local “consultants” or “facilitators” to navigate bureaucratic hurdles; unfortunately, such middlemen sometimes act as conduits for corrupt payments. To mitigate this, Turkish companies must tighten their scrutiny of any third party who will interact with government officials on their behalf or manage funds. Before hiring an agent, ask critical questions: Who exactly are the owners and principals of this intermediary? Do they have relatives in political office? What services are they truly providing – is there a legitimate need, or are they promising undue influence? Conduct background checks (there are databases and services that can flag if a person or entity has been involved in past scandals or is on watchlists). Demanding transparency is key – for instance, if a distributor will be selling your product to government customers, insist on knowing their pricing and margins to ensure they aren’t building in a cushion for bribes (the Oracle case involved exactly this problem: excessive discounting to distributors to create slush funds). All third-party contracts should include anti-corruption clauses – e.g. the right to terminate if misconduct is found, and perhaps the right to audit their books related to your business. High-risk relationships (such as lobbyists obtaining permits, or sales agents in countries known for graft) should require higher-level executive approval and periodic re-approval. It’s also wise to train your third parties – make it clear you expect them to uphold your standards. Some Turkish companies have begun implementing “channel partner codes of conduct” that mirrors their own policies and requiring agents to sign them. Monitoring is the next step: keep an eye on invoices and payment requests. Beware of vague descriptions like “consultancy fee” or “facilitation expense” without detail – ask for receipts and clear documentation of services rendered. If an agent asks for an unusually large commission or for payment to an offshore account unrelated to their base of operations, those are classic red flags. One red flag example from enforcement cases: an agent requests payment to a third-country shell company – this happened in multiple FCPA cases. By exercising diligence at the onboarding stage and throughout the relationship, companies can drastically reduce the chance that an agent will secretly pay bribes on their behalf. In the event that misconduct does occur, being able to show authorities that you had a robust third-party management process can significantly mitigate your liability. Under the U.S. DOJ’s evaluation guidelines, one of the first things they ask is how the company vetted and monitored the people who actually paid the bribe. Don’t let your company be the one that says “we just trusted them” – in this climate, trust must be earned and verified.
3. Strengthen Internal Controls and Encourage Reporting: Building a culture of integrity requires both systems and people. On the systems side, internal financial controls should be calibrated to detect anomalies that could indicate bribery or fraud. For example, implement expense controls that flag if an employee is claiming unusually high “business promotion” expenses, or if a project’s budget has an excessive “consulting fee” component. Many bribery schemes hide in plain sight as consulting contracts, charitable donations, or marketing events. A real scenario: a company’s local office sponsors a “conference” that public officials attend in a resort town – ostensibly a marketing event, but in reality a paid vacation for decision-makers. Controls can catch this if, say, any sponsorship over a certain amount requires legal approval and documentation of how invitees were chosen and why it’s legitimate. Another control is to limit cash handling. If petty cash or cash advances are common, that’s a risk – wherever feasible, require electronic payments which leave an audit trail. Procurement processes should be transparent and competitive to prevent collusion and kickbacks. Ensure that any deviations (like sole-source awards or use of urgency exceptions) are justified in writing and reviewed by independent persons. On the people side, employees are your eyes and ears. Companies should establish confidential whistleblower channels (phone hotlines, secure emails, even third-party ombuds services) whereby employees or even suppliers can report suspected misconduct. Given the Turkish context where whistleblowers have little external protection, it’s vital that internally you reassure staff that speaking up won’t cost them their job. This might involve having a strong non-retaliation policy and training managers to handle complaints discreetly. When a tip comes in, act on it. Even if initially anonymous or seemingly minor, investigate professionally. Some companies create a small internal investigations unit or task their internal audit department with handling such matters. By responding to reports, you not only address issues early (before they explode into major scandals), but you also send a message to employees that the company is serious. It’s equally important to impose consequences for violations. If an investigation finds that a manager paid a bribe or falsified records, there must be discipline (up to termination) – regardless of that person’s rank or connections. Nothing undermines a compliance program more than a perception that senior or high-performing employees are “untouchable” and will be quietly protected if they break rules. Conversely, celebrating employees who refuse to engage in corruption can reinforce the desired culture. For example, if a sales team loses a deal because they refused a bribe request, acknowledge their integrity and perhaps find other ways to reward their effort so the message is that ethical behavior is valued above short-term profit. Over time, these practices can shift attitudes: employees will see that doing the right thing is not only safe but recognized. This is crucial in Turkey, where historically many might have felt that reporting corruption was futile or dangerous. A company that cracks that code internally will stand out.
4. Be Prepared: Incident Response and Remediation: Despite best efforts, there is always a possibility that some misconduct occurs – perhaps a rogue employee succumbs to pressure or a legacy issue comes to light. What differentiates resilient companies is how they respond when a problem is discovered. Turkish companies should craft an incident response plan for corruption allegations, much like they might have for a cyber breach or safety accident. This plan would designate a response team – typically including legal counsel (both internal and external), compliance officers, finance controllers, and communications advisors. The first step on discovering a serious issue (say, evidence of bribery in a project) is to ensure all relevant data and documents are preserved. This prevents any accusation of a cover-up and ensures you can investigate thoroughly. Next, investigate promptly and objectively. Depending on the magnitude, it might be wise to bring in an outside law firm or forensic accounting team experienced in such investigations to ensure independence. Turkish companies might worry about airing dirty laundry, but keep in mind that if the issue might trigger foreign laws, having a credible independent investigation will be viewed favorably by those foreign regulators. Once you know the facts, remediation is key. This includes accountability (disciplining or firing those involved, no matter their position – enforcement agencies will ask if the company took action against wrongdoers) and plugging the control gaps that allowed the misconduct. For instance, if it turns out improper payments were made through a particular distributor, perhaps the fix is enhancing oversight of distributors or discontinuing those who won’t cooperate with audits. Regulators often require companies to implement specific improvements as part of settlements; doing so proactively can save time and show good faith. Now, an inflection point: to disclose or not to disclose? In a situation where the misconduct could violate laws like the FCPA or UK Bribery Act, companies should seriously consider voluntary disclosure to the relevant authorities. Both the U.S. DOJ and SEC offer significant incentives for self-reporting, cooperation, and remediation. In recent policy updates, the DOJ even suggested that in extraordinary cases of full cooperation and swift remediation, they might decline to prosecute entirely (even for serious misconduct). While each case differs, Turkish firms should at least obtain legal advice on the pros and cons of disclosure. One notable consideration: given Turkey’s lack of enforcement, a company might fear that reporting to Turkish authorities would go nowhere or be politicized – however, reporting to U.S. or UK authorities is a different matter since those are independent. Self-reporting to them could pre-empt a harsher outcome if they learn about it through other channels (and with whistleblowers and international data sharing, they very well might). If a company chooses not to self-report, it should still document the steps it took internally, so that if the matter is later discovered, it can demonstrate it didn’t ignore the issue. Another aspect of response is communication – both internal (to employees, to reassure them if something hits the press) and external (to investors or media if required). Transparency, to an appropriate degree, helps maintain trust. For example, some companies issue brief statements: “We identified an issue in X country, took immediate action, and have reported the matter to authorities. We are strengthening our controls to ensure this does not recur.” Such openness, as opposed to silence or denial, can preserve a company’s reputation as a responsible actor. Overall, having a playbook for crisis management can turn a potential company-ending scandal into a survivable event. Many companies that went through FCPA cases emerged still viable – often after replacing management and improving governance. The key was their willingness to confront problems head-on. Turkish businesses that adopt this mindset – “if something goes wrong, we fix it and own up to it” – will ultimately thrive in the new enforcement era.
Conclusion – Embracing Integrity for Sustainable Success
Ethical Governance as a Strategic Imperative: The trajectory of global and domestic trends leaves little doubt: for Turkish companies, robust anti-corruption practices are no longer optional niceties but core components of corporate governance and risk management. Persisting in old ways – greasing palms, relying on patronage networks, ignoring compliance – may yield short-term gains or expedite deals, but it now comes with exorbitant long-term costs. These costs may come as multi-million-dollar fines imposed by foreign courts, as lost business opportunities, or as the instability of being caught in political crossfires. Conversely, companies that cultivate ethical governance position themselves for resilience and growth. They contribute to rebuilding trust in Turkey’s business environment, which has suffered from high-profile scandals and the perception of impunity. This, in turn, can attract higher-quality investment and partnerships. It’s telling that Turkey’s economic reformers have been advocating improvements in rule of law and transparency; they understand that without a cleaner business climate, efforts to stabilize the economy or bring in foreign capital will falter. In essence, doing business with integrity is part of being competitive in the 21st century. Turkish firms should internalize that corruption is corrosive not only to the country but to their own viability – it undermines innovation, efficiency, and employee morale. Strong internal anti-corruption measures, overseen by engaged boards and supported by shareholders, should therefore be seen as integral to corporate strategy. They are as important as financial targets or market expansion plans, because without a foundation of integrity, those targets and plans can collapse overnight in a legal or reputational crisis.
International Competitiveness and Turkey’s Future: Turkey today stands at a crossroads. On one hand, it has dynamic entrepreneurs, a young workforce, and strategic geographic position. On the other, its governance lapses have held it back. For Turkish companies aspiring to go global, aligning with international anti-corruption standards is part and parcel of being world-class. Multinational companies from countries with strict compliance regimes are more inclined to do business with counterparts they perceive as low-risk and compliant. We have already seen Turkish sectors like banking adapt to global AML rules under pressure – now the same needs to happen with anti-bribery standards across all sectors. Those who adapt early will reap benefits. For example, a Turkish construction firm with ISO 37001 certification and a clean track record could market itself as a transparent alternative in regions notorious for corruption, thereby winning contracts from clients who must answer to financiers or governments about clean supply chains. Turkish exporters can leverage compliance as part of their brand – “Made in Turkey” can also imply adherence to ethical standards if enough leading companies push that narrative. There may come a time (especially if Turkey ever revives EU accession talks or similar trade agreements) when demonstrating compliance programs will be necessary to access certain markets or funds. Forward-thinking companies will be ahead of that curve, turning what could be seen as a constraint into an opportunity. Additionally, the more Turkish companies commit to integrity, the more pressure it creates on industry peers and even the government to improve. It sets a positive peer example and could foster a business-led demand for better public governance. In a sense, companies can help “crowd in” honest behavior by refusing to partake in corruption – if enough do so, it raises the cost for corrupt officials as well, who find fewer takers for their solicitations.
A Cultural Shift – From Risk to Resilience: Ultimately, what’s needed – and what we are beginning to witness in pockets – is a culture shift within Turkish business. The old assumption that “everyone pays bribes here, it’s how it works” must give way to a new norm: “we compete and succeed without bribery.” Cultivating that culture starts with leadership but must permeate all levels. It means celebrating employees who act with integrity, even if it means losing some business. It means integrating ethics into the company’s identity and mission (not as PR fluff, but in everyday decision-making). This cultural shift is not easy; it faces inertia and sometimes active resistance from those benefiting from the status quo. But it is necessary. The companies that successfully navigate it will be more resilient to scandals, more trusted by stakeholders, and often more efficient (since decisions will be made on merit and data, not on shady dealings). They will also be better prepared for any eventual improvements in Turkey’s own legal environment. Imagine a future where Turkey does strengthen its enforcement (whether through political change or external pressure) – companies that cleaned up their act will have nothing to fear, while those that didn’t will scramble or suffer consequences. Preparing for that eventuality is simply prudent risk management.
In conclusion, the developments up to October 2025 – from Turkey’s domestic corruption turmoil to the global enforcement spotlight – all point to the same advice for Turkish companies: embed integrity at the heart of your business strategy. Learn from the costly lessons seen in enforcement actions; don’t wait to be the next headline. By instituting strong anti-corruption measures, you protect your business from legal landmines, enhance your appeal in the global market, and contribute to a better business environment at home. The cost of compliance is far smaller than the cost of corruption. And beyond costs, conducting business ethically is about sustainable success – building a company that can endure and thrive on the strength of its products, services, and people, not on backdoor dealings. Turkish companies that embrace this philosophy will not only avoid the risks of this new era but can actively thrive in it, proving that doing well and doing good can indeed go hand in hand. The time to act is now, before others dictate the terms – by taking the lead in anti-corruption efforts, Turkish businesses can shape a brighter, more competitive future for themselves and their country.
