FATF gives Türkiye three years to prioritize money-laundering prosecutions amid 7,000-case backlog

Three substantial ratings and eight moderate ones fill all 11 of the effectiveness areas FATF tested, so nothing in that half of the evaluation came in above substantial ^[5][6]. The technical scoring ran the other way, at 95 per cent of recommendations compliant or largely compliant ^[23], with partially compliant marks on the other two ^[2]. On the judicial gap FATF wrote in the report that "Challenges in fully translating investigations into judicial outcomes have resulted in a backlog of more than 7000 cases pending prosecution." ^[11]

The size of that backlog depends on who is counting. BirGün reported 12,629 money-laundering cases in Turkish courts at the end of 2025, with 17,969 defendants and 28,477 underlying offenses awaiting judgment ^[13]. That works out at roughly 1.4 defendants and 2.3 offenses per case ^[15]. The gap between BirGün's docket count and FATF's pending-prosecution figure is about 5,600 cases ^[14], and the source material does not reconcile the two.

For a company, the operative finding is the one about liability. Turkish authorities can in many cases only issue administrative sanctions against companies, because criminal liability does not attach to legal persons, and FATF considers that insufficient for a country with Türkiye's risk profile ^[12]. The Key Recommended Actions reported from the evaluation are about cases and money. They cover terrorist-financing risk understanding, harder pushes on laundering tied to drug trafficking, smuggling and illegal betting, a higher conviction rate, and tracing assets moved abroad ^[16]. Corporate criminal liability is not one of those actions. It appears as a structural criticism.

Enhanced follow-up is a reporting obligation, and Türkiye has been there before, since the 2019 evaluation put it in the same category ^[7][8] and the country left the gray list in June 2024 anyway ^[9]. The label by itself costs a bank or a payments firm in Istanbul very little. What would cost them is the cheapest route available to a state that has been told to lift its conviction rate, which is to widen the set of defendants who can be convicted. The counter-argument is the Treasury and Finance Ministry's own, issued the same day. The assessment confirms no critical deficiencies in money laundering, terrorist financing or weapons-of-mass-destruction financing, and a return to the gray list is ruled out ^[10]. On that reading the three years go on court capacity and case triage, and the penal code stays as it is. If the first progress update shows convictions climbing with liability for legal persons untouched, the expectation of a legislative fix is wrong.

The same three-year deadline covers crypto supervision. The VASP framework was still being rolled out when the on-site visit took place in November 2025, 17 months after the gray-list exit. Supervisors had by then stepped up risk-based compliance checks on financial institutions and crypto platforms ^[18][21]. FATF found that firms generally understand their laundering exposure and obligations, while terrorist-financing risk handling and suspicious-transaction reporting lag outside the banking sector ^[19]. Ankara says the follow-up work runs through national strategies on money laundering, terrorist financing and asset confiscation for 2026-2030, plus a proliferation-financing plan for 2025-2029 ^[20].