finansbank anti-money laundering / know your customer procedure

DEFINITIONS 

Terrorist 

Financing 

Money 

Laundering 

Criminal 

activities 

FINANSBANK 

ANTI-MONEY LAUNDERING / KNOW YOUR CUSTOMER 

PROCEDURE 

The provision of funds or material mediums or in any way receiving, 

collecting, disposing, or managing funds with the intention to facilitate or 

assist the execution of terroristic actions either by a terrorist organization or 

by any individual terrorist. 

As money laundering, the following conduct shall be regarded: 

the conversion or transfer of property, knowing that such property is derived 

from criminal activity or from an act of participation in such activity, for the 

purpose of concealing or disguising the illicit origin of the property or of 

assisting any person who is involved in the commission of such activity to 

evade the legal consequences of his action, 

the concealment or disguise, through any medium, of the true nature, 

source, location, disposition, movement, rights with respect to, or ownership 

of property, knowing that such property is derived from criminal activity or 

from an act of participation in such activity, 

the acquisition, possession or use of property, knowing, at the time of 

receipt, that such property was derived from criminal activity or from an act 

of participation in such activity, 

the utilization of the financial sector by placing therein or moving through it 

proceeds from criminal activities for the purpose of lending false legitimacy 

to such proceeds, 

the setting up of organization or group comprising two persons at least, for 

committing one or more of the acts defined above and the participation in 

such organization or group. 

Criminal Activities shall denote the commission of one or more of the 

following offences: 

participation in an organized criminal group, 

terrorist activities and terrorist financing, 

passive and active bribery, 

bribery of judges, 

trafficking in human beings, 

computer fraud, 

sexual exploitation and narcotic drugs, 

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Suspicious 

transaction 

Unusual 

transaction 

Due 

Diligence 

P.E.P.s 

Immediate 

family 

members 

of P.E.P.s 

Persons 

known to 

be close 

associates 

bribery of employees 

offences regarding weapons, ammunition, explosives, etc, 

offences regarding antiquities and cultural heritage in general, 

any other offence punishable by deprivation of liberty for a minimum of 

more than six months and having generated any type of economic benefit 

Suspicious transaction is the case where there is an information, suspicion or 

reasonable grounds to suspect that the asset, which is subject to the 

transactions carried out or attempted to be carried out within or through the 

obliged parties, has been acquired through illegal ways or used for illegal 

purposes, used for terrorist activities or by terrorist organizations, terrorists or 

those who finance terrorism or connected or linked with them. 

Transaction or transactions or activities incompatible with the customer’s or 

beneficial owner’s economic/transacting profile (transactional, professional or 

business behaviour, financial condition) or have no apparent purpose or 

motive of a financial, professional or personal nature. 

Measures for the collection and maintenance of adequate information on a 

customer, the use of such information for identification purposes and the 

assessment of his overall economic/transacting profile on basis of procedures 

that are comprised according to the relevant risk that they represent 

regarding the use of the financial sector for ML/FT. 

Due diligence measures form the basis for AML/CFT procedures and constitute 

the most effective protection against negative effects on Bank’s solvency and 

reputation. 

“Politically exposed persons” are the natural persons who are or have been 

entrusted with prominent public functions and immediate family members, or 

persons known to be close associates, of such persons Natural persons 

entrusted with a prominent public functions include: 

heads of state, heads of government, ministers, alternate and deputy 

ministers, 

members of Parliament (MPs), 

judges of supreme courts, constitutional courts or other high-level judicial 

bodies, 

judges of courts of auditors and members of the boards of central banks, 

ambassadors, chargés d’ affaires and high-ranking officers in the armed 

forces , 

members of the administrative, management or supervisory bodies of stateowned 

enterprises. 

the spouse, 

any partner considered by national law as equivalent to a spouse, 

natural or adopted children and their spouses or partners, and 

the parents. 

any natural person who is known to have joint beneficial ownership of legal 

entities or legal arrangements, or any other close business relationships with 

a P.E.P, 

any natural person who has sole beneficial ownership of a legal entity or 

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of P.E.P.s legal arrangement which is known to have been established for the benefit of 

a P.E.P. 

Electronic 

funds 

transfer 

Crossborder 

funds 

transfer 

Shell Bank 

Beneficial 

Owner 

Offshore 

Company 

Nonprofit 

organizatio 

ns 

AML/CFT 

Officer 

Inspection 

of 

Obligations 

Any transaction that is carried out on behalf of a payer, through a credit or 

financial institution, by electronic means, with a view to making funds 

available to a payee in another credit or financial institution. The payer and 

payee may be the same person. 

A funds transfer where the credit or financial institution receiving the order 

from the payer is subject to a different legislation form that of the credit or 

financial institution that constitutes the transferred funds at payee disposal. 

A credit institution or an institution engaged in equivalent activities, 

incorporated in a jurisdiction in which it has no physical presence, involving 

meaningful mind and management, and which is unaffiliated with a financial 

group that meets the regulatory and supervisory requirements of Community 

legislation or at least equivalent requirements. 

Beneficial owner means natural persons who carry out a transaction 

within an obliged party, and natural person(s) who control(s) the 

natural persons, legal persons or unincorporated organizations on 

behalf of whom a transaction is conducted within an obliged party or 

who is the ultimate owner of the transaction or the account belonging 

to them 

Company that has no commercial or productive activity in the place of its 

establishment, such as: 

off-shore companies, 

abroad commercial-industrial companies , 

Special purpose vehicle (SPV). 

Non-profit or public benefit bodies, agencies, organizations, associations, 

societies and other unions as well as silent partnerships. 

AML/CFT Officer means the officer who is employed for the purpose of 

ensuring the compliance with obligations established through the Law no 5549 

on Prevention of Laundering Proceeds of Crime or the legislation issued on the 

basis of the Law and who is entrusted with the required authority 

Inspection of the obligations introduced by the Law no 5549 on Prevention of 

Laundering Proceeds of Crime and relevant legislation is carried out through 

Finance Inspectors, Tax Inspectors, Customs Inspectors, Revenue 

Comptrollers, Sworn-in Bank Auditors, Treasury Comptrollers and Capital 

Markets Board Experts 

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A- RISK MANAGEMENT ACTIVITIES 

A-1 KNOW YOUR CUSTOMER AND ASSESSMENT OF CUSTOMERS 

A-1-1 CONTROLS PRIOR TO OPENING BASE / ACCOUNTS 

A-1-2 INDIVIDUALS AND ORGANIZATIONS NOT ACCEPTABLE AS CUSTOMERS 

A-1-3 RISK-BASED ASSESSMENT OF CUSTOMERS AND TRANSACTIONS 

A-1-4 TRANSACTIONS WHICH SHALL NOT BE CARRIED OUT FROM CUSTOMER ACCOUNTS 

A-2 CUSTOMER IDENTIFICATION 

A-2-1 GENERAL EXPLANATIONS ON THE LIABILITY OF IDENTIFICATION 

A-2-2 IDENTIFICATION OF REAL PERSONS 

A-2-3 IDENTIFICATION OF LEGAL PERSONS REGISTERED TO TRADE REGISTRY 

(Incorporated, Limited, Unlimited, Commandite companies and cooperatives) 

A-2-4 IDENTIFICATION OF ASSOCIATIONS AND FOUNDATIONS 

A-2-5 IDENTIFICATION OF UNIONS AND CONFEDERATIONS 

A-2-6 IDENTIFICATION OF POLITICAL PARTIES 

A-2-7 IDENTIFICATION OF NON-RESIDENT LEGAL PERSONS 

A-2-8 IDENTIFICATION OF ENTERPRISES WITH NO LEGAL ENTITY 

A-2-9 IDENTIFICATION OF PUBLIC INSTITUTIONS 

A-2-10 IDENTIFICATION OF THIRD PARTIES WHO ACT ON BEHALF OF OTHERS 

A-2-11 AUTHENTICITY OF VERIFICATION DOCUMENTS 

A-2-12 IDENTIFICATION FOR SUBSEQUENT TRANSACTIONS 

A-3 IDENTIFICATION OF REAL BENEFICIARY AND LEGAL PERSONS DUE DILIGENCE 

A-4 TRANSACTIONS REQUIRING SPECIAL ATTENTION 

A-5 MONITORING OF CUSTOMERS AND TRANSACTIONS 

A-6 MEASURES TAKEN AGAINST TECHNOLOGICAL RISKS 

A-7 PRINCIPLE OF RELIANCE ON THIRD PARTIES 

A-8 REJECTION OF A TRANSACTION AND TERMINATION OF BUSINESS RELATIONSHIP 

A-9 CORRESPONDENT BANKING RELATIONSHIPS 

A-10 ELECTRONIC TRANSFERS 

A-11 ADDITIONAL MEASURES AGAINST HIGH RISK GROUPS 

A-12 RELATIONSHIPS WITH RISKY COUNTRIES 

A-13 SIMPLIFIED MEASURES 

A-13-1 TRANSACTIONS AMONG FINANCIAL INSTITUTIONS 

A-13-2 IN THE EVENT THAT THE CUSTOMER IS A PUBLIC ADMINISTRATOR OR AN 

OCCUPATIONAL INSTITUTE HAVING THE SPECIFICATIONS OF BEING A PUBLIC 

INSTITUTION 

A-13-3 IN THE EVENT THAT THE CUSTOMER IS INTERNATIONAL INSTITUTION OR EMBASSY 

OR CONSULATE RESIDING IN TURKEY 

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A-13-4 COLLECTIVE CUSTOMER ACCEPTANCE WITHIN THE FRAME OF SALARY PAYMENT 

AGREEMENTS 

A-13-5 SALARY PAYMENT TRANSACTIONS OF MEMBERS OF UNITS OF INTERNATIONAL 

INSTITUTIONS RESIDING IN TURKEY OR MEMBERS OF EMBASSY OR CONSULATES 

A-13-6 IN THE EVENT THAT THE CUSTOMER IS A PUBLIC COMPANY WITH QUOTED SHARES 

IN STOCK EXCHANGE 

A-13-7 TRANSACTIONS RELATED TO PENSION AGREEMENTS, PENSION PLANS AND LIFE 

INSURANCE 

A-13-8 TRANSACTIONS OF PRE-PAID CARDS 

A-13-9 VERIFICATION OF ACCURACY OF TELEPHONE AND FAX NUMBERS AND E-MAIL 

ADDRESSES 

A-14 REPORTING OF MONITORING AND EVALUATION RESULTS TO THE BOARD OF DIRECTORS 

B- MONITORING AND CONTROLLING ACTIVITIES 

B-1 MONITORING AND CONTROLLING OF THE TRANSACTIONS OF HIGH RISK CUSTOMERS 

B-1-1 CONTROLS CONDUCTED BY AML UNIT RELATED TO HIGH RISK GROUP CUSTOMERS 

B-2 MONITORING AND CONTROL OF THE TRANSACTIONS PERFORMED IN RISKY COUNTRIES 

B-2-1 CONTROLS CONDUCTED BY AML UNIT RELATED TO THE RISKY COUNTRIES 

B-3 MONITORING AND CONTROL OF COMPLEX AND UNUSUAL TRANSACTIONS 

B-3-1 CONTROL OF SAFE DEPOSIT BOXES 

B-3-2 INSPECTION OF CASH AND TRANSFER TRANSACTIONS 

B-4 CROSS CHECK OF THE TRANSACTIONS ABOVE A CERTAIN AMOUNT WITH THE CUSTOMER 

PROFILE BY SAMPLING METHOD 

B-5 MONITORING AND CONTROL OF THE TRANSACTIONS WHICH EXCEED IDENTIFICATION LIMIT 

AND WHICH ARE INTERRELATED 

B-6 CONTROL OF THE INFORMATION AND DOCUMENTS RELATED TO CUSTOMERS THAT ARE KEPT 

IN WRITING OR IN AN ELECTRONIC MEDIUM; CONTROL OF THE INFORMATION THAT HAS TO BE 

STATED IN ELECTRONIC TRANSFER MESSAGES; COMPLETION AND UPDATING OF THESE 

INFORMATION 

B-7 ON-GOING MONITORING OF THE TRANSACTIONS IN ORDER TO CHECK THEIR CONSISTENCE 

WITH THE CUSTOMER’S OCCUPATION, RISK PROFILE AND SOURCES OF FUNDS 

B-8 CONTROLS OF THE NON-FACE-TO-FACE TRANSACTIONS 

B-9 RISK BASED CONTROL OF NEW PRODUCTS AND SERVICES THAT MAY BECOME VULNERABLE TO 

MISUSE DUE TO TECHNOLOGICAL INNOVATIONS 

B-10 SUSPICIOUS OR UNUSUAL TRANSACTION REPORTING 

B-10-1 LAUNDERING THE PROCEEDS OF CRIME 

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B-10-2 SUSPICIOUS OR UNUSUAL TRANSACTION TYPES DESCRIBED IN GENERAL 

COMMUNIQUE NO. 6 OF THE FINANCIAL CRIMES INVESTIGATION BOARD 

B-10-3 TERRORIST FINANCING 

B-10-4 HOW TO FILL-IN, SIGN AND SEND THE SUSPICIOUS TRANSACTION REPORTING 

FORM TO THE COMPLIANCE DEPARTMENT 

B-10-5 REPORTING SUSPICIOUS OR UNUSUAL TRANSACTIONS TO THE FINANCIAL CRIMES 

INVESTIGATION BOARD 

C- TRAINING ACTIVITIES 

C-1 CONTENT AND SCOPE OF TRAINING ACTIVITIES 

C-1-1 METHODS OF TRAINING ACTIVITIES 

C-1-2 CONTENT OF TRAINING ACTIVITIES 

C-1-3 TARGET GROUPS 

C-1-4 TRAINING DOCUMENTS 

C-1-5 TRAINERS 

C-1-6 EVALUATION OF THE TRAINING RESULTS 

C-1-7 REPORTING TRAINING RESULTS TO FINANCIAL CRIMES INVESTIGATION BOARD 

D- INTERNAL AUDIT ACTIVITIES 

E- RELATIONS WITH NBG GROUP COMPLIANCE DIVISIOM 

APPENDICE 

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A-RISK MANAGEMENT ACTIVITIES 

The below mentioned risk management activities are performed by our bank related to 

prevention of laundering proceeds of crime and terrorist financing in order to identify, scale, 

monitor, evaluate and minimize the risks that our bank is subject to. 

Record Keeping 

All records and documents obtained in line with the regulations on laundering proceeds of 

crime and terrorist financing are kept for at least 8 years. 

A-1 KNOW YOUR CUSTOMER AND ASSESSMENT OF CUSTOMERS 

Where new customers are acquired without going through a careful review, the banks may be 

subjected to the risk of losing reputation, operational and legal risks which may impose 

significant financial costs. The principle of “Know Your Customer” is critically important not 

only in terms of protection from launderers of criminal income – prevention of money 

laundering and terrorist financing, but also in terms of effective management of banking risks 

In addition to knowing the customer well and knowing the customer’s type of business, it is 

also important to know the relations of the customer with other customers for prevention of 

the risk of concentration, which can be the case especially in credit transactions. 

This section sets out the principles to be implemented for new customers at our Bank in 

account openings and in monitoring the transactions of existing customers. 

• First of all, a Customer Assessment Form (Appendix 1) has to be prepared by the 

Customer Representative for each customer who asks to open an account at our Bank. 

This form shall cover, The reason for the customer’s preference and opening an 

account at our Bank (in the event that the customer himself has applied to open an 

account), 

• Principles of working with our bank, types of transactions to be carried out, 

• Customer’s occupation, commercial activities, occupational history, financial status, 

country of residence, country where the customer’s business activities operate, 

country or region of origin or destination of funds 

• Where possible, customers who work with our Bank, which may be used as reference, 

• Customer representative’s evaluation. 

If the customer is deemed as belonging to high risk group according to the assessment 

criteria above, related box in the Customer Assessment Form (Appendix 1) is checked. 

THE CUSTOMER REPRESENTATIVE SHALL DECIDE THAT THE ACCOUNT SHOULD BE OPENED 

IF THE INFORMATION S/HE RECEIVES FROM THE CUSTOMER IS CONSISTENT AND THE 

DOCUMENTS ARE CONSISTENT WITHIN THEMSELVES. ALL RESPONSIBILITY RELATING TO 

THE CUSTOMER (FULL PROCUREMENT OF DOCUMENTS AND DETAILS, COMPLIANCE WITH 

RECORDS IN COREFINANS SYSTEM AND UP–TO-DATE THEREOF, ETC.) BELONGS TO THE 

CUSTOMER REPRESENTATIVE. 

Banking Transactions Agreement shall not be signed and customer base account shall not be 

created upon power of attorney according to “Know Your Customer” principles even though 

there is a clearly defined authorization in the power of attorney. 

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The Bank officers should visit the persons who do not have the physical capability to visit the 

Bank in order to identification of these customers and signing Banking Transactions 

Agreement. After opening to the customer a base number, accounts under this base number 

can be opened by a power of attorney. 

Age limit must be observed for accounts to be opened in the name of minors. 

A-1-1 CONTROLS PRIOR TO OPENING BASE / ACCOUNTS 

• Customers who want to open base/accounts are checked against the bank’s in-house 

and international warning lists (such as OFAC; UN Sanctions List, EU Black List, SABAS, 

our bank’s warning list). The mentioned controls are automatically performed at base 

openings. The workflow is as follows; 

In the phase of customer identification by a branch, while the user is registering 

customers’ information, the system cross checks potential customer’s information with 

the persons/institutions in the following lists: 

* OFAC SDN List (Office of Foreign Assets Control Specially Designated Nationals 

List), the list prepared by the Treasury of the USA. 

http://www.treas.gov/offices/enforcement/ofac/sdn/sdnlist.txt 

* EU Sanctions List, The warning list prepared by the European Union 

http://ec.europa.eu/external_relations/cfsp/sanctions/list/version4/global/e_ct 

lview.htm 

* Banned and sanctioned countries, the link for the details is 

http://www.treas.gov/offices/enforcement/ofac/programs/ 

* List of countries with which no transactions will be performed prepared by 

Western Union; Western Union announces this list to its agencies. Information can be 

obtained from FOMER- Western Union Unit and our unit. 

* Finansbank Alert List which is prepared by AML unit including fraud, lost and 

fictitious document notifications by customers, The Banks Association of Turkey, 

prosecution offices etc. Information can be obtained from AML Unit. 

* Capital Market Board Prohibited Investors including the persons/institutions that 

are banned from operating on capital market instruments by the Capital Market Board; 

it is included in the warning list. These persons/ institutions are banned from using only 

capital market instruments. An alert will be put on the customer name and they will be 

prevented from making such transactions on the internet. 

http://www.spk.gov.tr/apps/islemyasaklilar/index.aspx 

The user is notified on the basis of a certain ratio of matching before completing the 

transaction and details on warning lists and matching records are provided in the related 

menu. The user performs the following actions in order to decide whether s/he will continue, 

make a research on the record or end the transaction: 

* Finans_Base_OFAC - should be controlled in the OFAC list. 

* Finans_Base_EU/BL - should be controlled in the EU Sanctions List. 

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* Finans_Base_Uyarı - should be controlled in the Finansbank Alert List. If there is a 

one-to-one match, AML Unit should be informed. 

* Finans_Base_Ülke - should be controlled in the banned, sanctioned countries list. 

* Finans_Base_WU – List of the countries prepared by Western Union with which no 

transactions will be performed. If there is a one-to-one match, FOMER-Western Union 

Unit or Compliance Department should be informed. 

Information checked in the phase of customer identification: 

Legal person inquiries are based on title and Taxpayer Identification Number (TIN). When 

the title and TIN match, necessary inquiries are made in order to decide on continuing or 

ending the transaction. 

Real person inquiries 

For Turkish citizens; the inquiries are based on name/surname, identity number, name of the 

father, place of birth and date of birth. When name/surname+name of the father+place of 

birth+date of birth or identity number match exactly, necessary inquiries are made in order 

to decide on continuing or ending the transaction. 

For foreign citizens the inquiries are based on name/surname, name of the father, place of 

birth and date of birth. When name/surname+name of the father+place of birth+date of birth 

match exactly, necessary inquiries are made in order to decide on continuing or ending the 

transaction. 

* For the transactions approved by the Plastic Cards BDS (the name of the system 

used by Plastic Cards Department), the system automatically creates a customer 

number, and if there are similarities between the customer record and the 

persons/institutions in the warning lists, the records are listed in the menu 

Customer>Customer Identifications>Warning Lists Monitoring. The records in these 

lists are controlled, and the Plastic Cards Allocation Unit decides to stop the issuing 

of the card if there are any suspicions. 

* In case there are matching records among the persons who will be paid their 

salaries within the frame of FINBOR contracts, the system does not register them, 

and the transaction is transferred to the related branch in order to give the final 

decision after inquiry and continue the transaction if it is proper. 

The accuracy of the presented documents is checked in line with the Prevention of 

Fraud Attempts Directive (TAL.00460). 

If there are any doubts about the authenticity of the documents presented by the 

customer, authenticity of these documents is verified by consulting to the 

person/institution who has prepared the document. 

Whether the customer has high risk and his/her risk group is determined in terms of 

laundering the proceeds of crime and terrorist financing by considering his/her 

occupation, commercial activities, sources of funds, his/her country of residence and 

other relevant indicators. 

Individuals and organizations may not collect donations without having permission 

from public authorities. To the extent it is desired to open an account for collecting 

donations, if the activity of collecting donations covers more than one district of a 

province, then permission must be obtained from the governor of that province; if it 

is limited to the boundaries of a district, then permission must be obtained from the 

governor of that district. To the extent the donation collection operation covers more 

than one province, it is sufficient for the natural or legal persons to endeavor 

collecting donations to obtain permission from the governor of the province of that 

settlement. Which charitable association, agency or foundation may collect 

9

donations without obtaining permission shall be determined and announced by the 

Council of Ministers upon recommendation of the Ministry of Internal Affairs. The 

opinion of the Compliance Department shall be obtained for accounts to be opened 

for collecting donations. When such an entity has appointed more than one 

authorised signatories to operate its account, the identities of all authorised 

signatories shall be verified, according to the identity verification procedures for real 

(natural) persons provided for. 

A-1-2 INDIVIDUALS AND ORGANIZATIONS NOT ACCEPTABLE AS CUSTOMERS 

• Persons and organizations in the bank’s in-house and international sanctions lists 

(such as OFAC; UN Sanctions List, EU Sanctions List, SABAS, our bank’s warning 

list). 

• Persons and organizations who ask to open an account under a name which is 

different from their real identities; who avoid to fill in the customer information forms 

and those who are reluctant to do so; or who supply misleading or unverifiable 

information. 

• Information exists from reliable sources, of their participation in illegal activities (eg. 

Drugs’ dealing, terrorism, organized crime), or investigation is conducted for their 

participation in illegal activities. 

• Information exists, that another Bank has refused the provision of services to the 

customer. 

• The verification of their identity is difficult (e.g. very complicated business structure 

of the company that makes impossible the understanding of the ownership and the 

identification of the person who exercises control). 

• Individuals and organizations asking to open an account, stating that they have 

international connections and they will bring a large amount of funds to our Bank to 

make investments in our country. 

• Individuals and organizations wishing to open an account with the request that 

foreign currency cheques drawn on international banks are collected or purchased. 

• Shell Banks and financial institutions which have no physical address in any country, 

comprising solely a web address, which are not subject to supervision or license of 

any government authority in respect of banking transactions and records, which are 

generally established at overseas jurisdictions known as offshore tax heavens. 

• Persons and organizations for which there is doubt that their wealth and funds have 

been earned through legal means. 

• Those who demand to open accounts in the name of third parties under an 

anonymous name or nick name. 

• Real/legal persons working at Bill Payment Centers. 

Where it is believed that it is risky to open an account for the customer after the evaluation 

made by the Customer Representative but the customer insists on opening the account, the 

matter shall be forwarded to the Compliance Department. 

A-1-3 RISK-BASED ASSESMENT OF CUSTOMERS AND TRANSACTIONS 

The Bank differentiates its customers according to risk assessment by subordinating them 

into three (3) categories, namely: 

• High risk 

• Medium risk 

• Low risk 

Analytic instructions on how this categorization will be practiced will follow in due course. 

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HIGH RISK GROUP CUSTOMERS 

Customers who are in the high risk group are determined according to the following and other 

related criteria: 

• Their occupations/commercial activities, 

• Their transaction types and reasons, 

• Volume of transactions, 

• Sources of funds, 

• The countries they make transfers, and beneficiaries of those transactions, 

• The countries they receive transfers from and their principals 

• Real beneficiaries of the transactions, 

• The company profile and its shareholders, 

• Their country of residence. 

The below listed customer types are considered as belonging to high risk groups. The box 

indicating “high risk” in the Customer Assessment Form is checked at the opening of these 

kinds of bases/accounts. 

• Non-residents 

Customers having their residence abroad shall be subject to the same information 

requirements and identity verification procedures as those who live permanently in 

Turkey. Special attention is paid to opening accounts for non-resident person or 

institutions, and information on their reason for opening an account in Turkey, their 

commercial or non-commercial activities, nature of transfers that will be made to and 

received from abroad together with their principals and amounts are asked. Especially 

before opening accounts for persons residing in high risk countries, the documents 

explained in Customer Identification section should be taken and be carefully examined. 

Furthermore, when there is any doubt concerning the identity of a person, the Bank shall 

seek verification and authentication of these documents by the embassy or consulate of 

the issuing country in Turkey, or by reliable Credit Institutions in the customer’s home 

country. 

• Residents in Offshore Regions and special purpose vehicles (SPVs) 

If the customer is a company that has no commercial or productive activity in the place 

of its establishment, such as an offshore company or a company referred to in, as 

currently in force, or a Special Purpose Vehicle (SPV), the Bank shall conduct enhanced 

customer due diligence. 

Countries/Regions named as Offshore or “Tax Heaven” are; Andorra, Anguilla, Antigua, 

Aruba, Bahrain, Barbuda, Belize, Bermuda, British Virgin Islands, Cayman Islands, 

Bahamas,Cook Islands, Gibraltar, Grenada, Guernsey/Sark/Alderney, Cyprus, Isle of Man, 

Jersey, Liberia, Malta, Mauritius, Montserrat, Niue, Panama, Vanuatu, Samoa, San 

Marino, St. Lucia, St. Vincent and Grenadines, Dominica, St. Kitts and Nevis, The 

Netherlands Antilles, The Prinsipality of Liechtenstein, The Principality of Monaco, 

Marshall Islands, Nauru, Seychelles, The US Virgin Islands, Turks and Caicos Islands. 

The Bank applies the following to the above companies: 

• Verifies the ownership structure and control of the company and identifies the 

beneficial owners. In order to identify the beneficial owners, the Bank shall require 

either (i) a declaration form (Appendix 2) in writing by the legal representative of the 

11

company regarding the verification of the beneficial owners’ identity or (ii) 

certification and verification of their identity by a credit officer of the Bank, following 

approval by a member of senior management, on the basis of documents, data or 

information from a reliable and independent source. 

• Obtains from the legal representative of the company a declaration in writing to the 

effect that, if the shares of the beneficial owners are transferred to a third party or 

there is any material change in the company's status, he shall immediately inform 

the Bank. If there is any change in the beneficial owners of the company, the Bank 

shall consider whether or not to continue the business relationship 

• Compares regularly the actual transactions through the account with those expected 

on the basis of the company’s economic/transaction profile. Any significant 

divergences shall be scrutinized and the findings shall be entered in the company’s 

file. 

• Persons Residing and Transactions Carried out in Countries Which Do Not 

Act in Accordance with the Recommendations of FATF 

The Bank shall examine with particular attention transactions and conduct additional 

measures for the continuous monitoring of the business relationships and transactions 

with natural persons or legal entities, including Credit Institutions and Financial 

Institutions, from countries that are considered as non-cooperative or non-compliant or 

inadequately compliant with the requirements of FAFT. All transactions with natural 

persons or legal entities from these countries shall be examined with particular attention. 

To assess country risk for AML/CFT purposes, the Bank uses the following criteria: 

• announcements by FATF concerning countries or territories that do not comply or 

comply inadequately with its recommendations, 

• country assessment reports issued by FATF, regional bodies that have been 

established and operate according to its standards (e.g. Council of Europe Moneyval 

Committee), the International Monetary Fund and the World Bank, 

• list of countries or jurisdictions which, according to the Common Understanding of the 

Committee for the Prevention of Money Laundering and Terrorist Financing, which 

assists the European Commission, have equivalent AML/CFT systems to the EU, 

• countries characterized by FATF as non cooperative or tax havens; 

• inclusion in the EU, UN and OFAC (Office of Financial Assets Control) lists; 

• FATF membership; 

• implementation of EU directives; 

• implementation of the Wolfsberg principles; and 

• countries that ratified the UN Convention Against Illicit Traffic in Narcotic Drugs and 

Psychotropic Substances of 1988 

• PEP-Politically Exposed Persons 

Politically exposed persons are natural persons that are or have been entrusted with a 

prominent public function, including their immediate family members or the persons 

known to be their close associates. 

Specifically natural persons entrusted with a prominent public function include: 

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(a) Heads of State, heads of government, ministers and deputy or assistant 

ministers; 

(b) Members of Parliament (MPs); 

(c) Judges of supreme courts, constitutional courts or other high-level judicial 

bodies whose decisions are not subject to further appeal, other than in 

exceptional circumstances; 

(d) Judges of courts of auditors; 

(e) Members of the boards of central banks; 

(f) Ambassadors and chargés d’ affaires; 

(g) High-ranking officers in the armed forces; and 

(h) Members of the administrative, management or supervisory bodies of stateowned 

enterprises. 

None of the categories (c) and (h) above shall be understood as covering middleranking 

or junior officials. 

The categories (b) and (g) above include functions exercised at the EU and 

international levels. 

Immediate family members of the persons referred to in the above paragraph shall 

include: 

(a) The spouse; 

(b) Any partner considered by national law as equivalent to a spouse; 

(c) Natural or adopted children and their spouses or partners; and 

(d) The parents. 

Persons known to be close associates shall include: 

(a) any natural person who is known to have joint beneficial ownership of legal 

entities or legal arrangements, or any other close business relationships, with a 

person referred to in the above paragraph and 

(b) Any natural person who has sole beneficial ownership of a legal entity or legal 

arrangement which is known to have been established for the benefit of a person 

referred to in the above paragraph. 

Without prejudice to the application, on a risk-sensitive basis, of enhanced customer 

due diligence measures, where a person has ceased to be entrusted with a prominent 

public function for a period of at least one year, the Bank shall not be obliged to 

consider such a person as politically exposed. 

The Bank must adopt the following additional customer due diligence measures when 

establishing a business relationship with a PEP: 

(a) Apply the appropriate procedures, on a risk-sensitive basis, to determine whether 

the customer is a PEP; 

(b) Obtain senior management’s approval of the establishment of business 

relationships with such customers; 

(c) Take adequate measures to verify the origin of the wealth and funds that the 

business relationship or transaction concerns; and 

(d) Monitor the business relationship on a continuous and enhanced basis. 

13

In the case of accounts of legal persons and other entities, the procedures applied shall 

aim at verifying whether the beneficial owners, legal representatives and persons 

authorized to operate the relevant account are PEPs. If any of the above persons is 

identified as a PEP, these legal persons’ and other entities’ accounts shall automatically 

be subject to the enhanced customer due diligence measures. 

Standard customer due diligence measures must apply to PEPs established in Turkey 

• Companies with Bearer Shares 

Accounts which will be opened for companies that have issued bearer shares are 

considered as high risk group accounts. Especially companies founded in offshore regions 

issue bearer shares. It is possible to detect such cases from the companies’ main 

contracts. Therefore, careful examination of the main contracts of both resident and nonresident 

companies is of vital importance. Prior to opening accounts for such companies, 

verification of the obtained information on company owners, real beneficiaries and 

financial status should be sought from relevant sources or by paying visits to the office of 

the company. 

The legal representative of the company provides a declaration in writing to the Bank 

stipulating that, if the shares of the beneficial owners are transferred to a third party or 

there is any material change in the company’s status, he shall immediately inform the 

Bank, unless the same commitment is made in an agreement with the company. When 

there is a change of the person who is the real beneficiary of the company or a different 

transaction other than the regular transactions performed from that account, an 

evaluation should be made in line with the explanations stated in the Monitoring and 

Controlling section. 

A declaration form (Appendix 2) shall be signed by the legal representative of the 

company with bearer shares, by which further information about the company is 

requested. 

• Non-profit organizations 

Non-profit organizations such as associations and foundations can be used for terrorist 

financing. Funds that are obtained as subscription fees, donations and benefactions from 

good-intentioned people may be transferred to terrorist organizations or terrorists via 

these non-profit organizations. Most of the time, people are unaware of such transfers; 

believing that the money they donate will be used for the sake of the legal aim declared 

by these organizations. Accounts that will be opened for foundations, associations and 

charity foundations are high risk group accounts. 

With respect to accounts of non-profit or public benefit agencies, organizations, 

associations, societies and other unions, the Bank shall verify the legitimacy of their 

incorporation and objects, requiring the submission of a certified copy of their establishing 

deed (charter, private agreement etc.), their certificate of incorporation, certificate of 

registration and the number of their registration by the competent public authority. When 

such an entity has appointed more than one authorized signatories to operate its account, 

the identities of all authorized signatories shall be verified, according to the identity 

verification procedures for natural persons provided for hereunder. 

• Persons with high amount of funds (Ex. Private Banking Customers) 

The Bank shall take the following additional due diligence measures when undertaking the 

management of portfolios of important clients: 

The Branch Manager approves the opening of portfolio management accounts of new 

important customers. 

The identity of all the beneficial owners of such accounts is verified. 

14

It is verified whether the owner of the account is a PEP. 

The source of the assets managed and the expected use of the account by the 

owners are established. 

It is examined whether the operation of the account is consistent with its purpose 

and the owners’ economic/transaction profiles. 

It should be stated in the Customer Assessment Form that the person is a private 

banking customer. 

• Non-Face-to-Face Transactions 

Non-face-to-face transactions are conducted through alternative networks (e.g. ATMs, 

Internet / Phone / Mobile banking, etc.) 

Our bank is obliged to devote special attention to and take necessary measures against 

risks of using advantages of new and developing technology for laundering proceeds of 

crime and terrorist financing. Therefore, transactions like cash transactions and money 

transfers carried out via alternative distribution channels such as internet, telephone 

banking and ATMs are inspected within the frame of monitoring and controlling activities. 

At the beginning of the business relationship, before establishing a business relation with 

the customer, a customer should be physically present in our branches for ID verification 

and other related actions such as signing the banking transactions agreement or other legal 

documents. Therefore, such transactions cannot be executed by walk-in customers via 

internet banking, call center, etc. 

When the customer applies for the connection of his account with an alternative network, 

it shall be ensured that the identity verification and certification procedures have been 

completed, before the account opening. Consequently, any information by declaration will 

not be accepted. 

• Risky sectors and profession groups 

The below listed sectors and occupational groups who make transactions on behalf of third 

parties and where there is an intense cash flow are considered as high risk groups. 

Authorized institutions (foreign currency dealers). 

Jewelers, traders of precious stones and metals like gold and diamond. 

Travel agencies, carriers of passengers and cargo. 

Casinos, operators of halls of games of chance. 

Gallery operators selling luxury vehicles. 

Antique dealers and art galleries, carpet dealers. 

Large real estate firms and any agents, representatives or commercial attorneys for 

the same 

Lessors of aircraft and sea vehicles. 

Manufacturers and traders of leather goods. 

Manufacturers and traders of car spare parts. 

Those operating in lines of business with high use of cash (car park operators, 

restaurants, fuel, lottery and newspaper dealers, distribution companies, traders of 

toys and stationery). 

Factoring firms. 

15

• Cash transactions 

Branch and Business Units’ Officers shall examine with particular attention cash 

transactions of a significant amount in order to verify the origin of cash and whether the 

amount and nature of the transaction are compatible with the customer’s 

economic/transaction profile. For that purpose, they shall obtain all the documents and 

data required to verify the necessity of carrying out a cash transaction of significant 

amount. 

Therefore, information on the sources of the funds and the reasons for opening accounts 

is obtained from the customer and check whether the transactions performed after 

opening the account are in accordance with the reasons for opening the accounts. 

If a customer requests to withdraw an amount of over TRY 500.000 (approx. the 

equivalent of €250,000.00) in cash, it is recommended that the money be delivered to the 

customer by cheque or an order for payment to a bank account, unless there are specific 

and adequately proved reasons that warrant a cash withdrawal. 

The results of the examination shall be documented and filed for at least eight years, 

including all supporting documents. 

• Correspondent Banking Relationship 

These relationships shall be established in line with rules and principles stated in Chapter A-9 

of this Document. 

Trusts 

Trusts are not separate legal entities and, therefore, business relationships are established 

through trustees acting on behalf of the trust. Our bank takes reasonable measures, on a 

risk-sensitive basis, to comprehend the ownership and control structure of trusts. 

Before establishment of such relationships and account opening the following shall be 

verified: 

the name and date of establishment, 

the identities of trustors, trustees and beneficial owners, 

the nature, objects and activities of the trust, 

the source of its funds. 

Copies of the establishing documents of the trust and any other necessary information on the 

beneficial owners should be obtained and shall keep the relevant data and information in the 

customer’s file. 

A-1-4 TRANSACTIONS WHICH SHALL NOT BE CARRIED OUT IN CUSTOMER 

ACCOUNTS 

The following transactions may not be carried out in customer accounts: 

No transaction of virtual nature (fictitious), seeking fulfillment of various legal 

obligations (capital increase of companies indicating that there are funds in the 

account at a specific time, etc.) 

Accounting records shall be established in line with the nature of transactions. 

Requests seeking to vary the nature of account-to-account transfers or cash payment 

transactions to be made from accounts (entering into books of wire-to-wire transfer in 

the form of cash payment, etc.) may not be accepted. 

16

Transactions which will allow the customer to avoid tax obligations or which would lead 

to loss of taxes. 

A-2 CUSTOMER IDENTIFICATION 

In this section, within the framework of the regulations issued by The Financial Crimes 

Investigation Board, the principles of identification which is one of the measures taken for the 

prevention of being an instrument of laundering proceeds of crime and terrorist financing on 

the part of our bank are explained. 

Besides our responsibilities brought about by legal regulations and the ones set out in this 

directive, attention needs to be paid to our bank’s in-house regulations in order to protect our 

bank’s reputation and avoid risky transactions. Apart from regulations set out in this directive 

relating to identification during payment transactions, it is obligatory to consider our bank’s 

in-house regulations with due care. 

The most important measure to take for not being an instrument of laundering proceeds of 

crime and terrorist financing transactions is customer assessment at the phase of gaining new 

customers and proper identification. Therefore; identification of potential real and legal 

customers prior to opening accounts, and obtaining information on their terms of working 

with our bank and activities are of utmost importance. The liability of these issues lies on the 

employee acquiring a new customer for the Bank. Finansbank also ensures that customer’s 

data are continuously updated during the business relationship, 

The principles of opening base/accounts have been explained in Section A-1. 

A-2-1 GENERAL EXPLANATIONS ON LIABILITY OF IDENTIFICATION 

Banks shall; 

Regardless of the monetary amount in permanent business relationships as in opening 

of accounts, hiring safe boxes, granting credit or issuing credit cards ; 

When the amount of a single transaction or the total amount of multiple linked 

transactions is equal to or more than TRY 20.000,-; 

When the amount of a single transaction or the total amount of multiple linked 

transactions is equal to or more than TRY 2.000,- in electronic transfers (such as 

SWIFT, Western Union, EFT) 

Regardless of the monetary amount in cases requiring Suspicious Transaction Report; 

Regardless of the monetary amounts in cases where there is suspicion about the 

sufficiency and the truth of previously acquired identification information, 

Identify persons carrying out transactions and the persons acting on behalf of or for the 

benefit of the customers by means of obtaining information on identity and verifying their 

authenticity. Moreover, in the establishment of permanent business relationship, information 

about the purpose and the nature of the business relationship shall be obtained. 

In permanent business relationships such as opening of accounts, hiring safe boxes, 

granting credit or issuing credit cards; 

For real persons, besides verification of the below stated information from ID cards, 

the authenticity of the declared address is verified by a settlement license or a bill of a 

service which requires a subscription (like an electricity, water, gas, telephone bill) 

and has been issued within 3 months, and/or a document issued by a government 

office (or by other documents and methods approved by The Financial Crimes 

Investigation Board). A legible photocopy is made or digital image of this verification is 

taken or the distinctive information on these documents is recorded. 

17

For legal persons, unincorporated enterprises and other institutions and 

establishments, verification of address is performed as set out in the later chapters of 

this directive. 

In transactions which do not constitute a permanent business relationship but 

necessitates identification, 

It is obligatory to obtain the relevant person’s ID Card and number, address, contact 

information like telephone number, sample signature . 

Determination of the TRY equivalent of F/X transactions are based on the buying rate of 

exchange of the Central Bank on the day of the transaction. 

The relevant branch or unit employee in Turkey is responsible for the proper performance of 

identification. Our branches abroad carry out the transactions in line with the bank’s in-house 

policies and the legislation of the country of residence and “Regulation on Measures 

Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism” of MASAK 

as far as authorities allow. 

In transactions which do not constitute a permanent business relationship and do 

not legally necessitate identification, 

The identification number should be obtained by branches even if the transaction does not 

exceed the above mentioned thresholds. 

A-2-2 IDENTIFICATION OF REAL PERSONS 

The following information should be obtained for the identification of a real person, 

Name, Surname 

Place and date of birth, 

Name of father and mother for Turkish Citizens. 

Nationality, 

Identity number for Turkish citizens, 

Type of identity card and number, 

Address and if possible fax, telephone number, email, 

Information on job and occupation, 

Occupational address 

Sample signature. 

The authenticity of name, surname, place and date of birth, name of father and mother, 

nationality, type and number of identity card is verified by, 

and, 

ID Card 

Driver’s License, 

Passport for Turkish citizens 

Passport, 

Residence Certificate, 

ID Cards approved by The Ministry of Finance for foreign citizens. 

In order to present to the authorities when demanded, a legible photocopy is made or digital 

image of this verification is taken or the identification information on these documents is 

recorded after the related documents are presented by the customer. 

18

The authenticity of the declared address during the transactions which constitute a 

permanent business relationship is verified by; 

Settlement license, 

Bill of a service which requires a subscription (like electricity, water, gas, telephone 

bill) and has been issued within 3 months including the electronic bills which can be 

confirmed by the obliged that they have been issued by the relevant institution. 

Any document given by a public institution, 

On the condition that they cover information pertaining to the last three months, lists 

prepared by institutions which have public institution specification like BEDAŞ and 

ASKİ or by telecommunication companies which provide subscription. 


bill) and has been issued within 3 months in the name of the third party on the 

condition that a recognized document showing the relatedness with the third party is 

presented, 


bill) and has been issued within 3 months in the name of the parents for majors who 

live with their parents, 

A declaration of address given by the education or institution or the dormitory for 

majors who reside in dormitories. 

A document showing that the customer has received a certified mail, 

For banks, credit card delivery forms which shows that the customer was in sight of 

the declared address, 

Reports showing that the posts sent by the obliged have been received by their 

customers at the declared address, 

The originals or notarized copies of the above mentioned documents do not have to be 

presented. Legible photocopies or digital images of the documents are valid. 

ID Cards approved by The Ministry of Finance; 

Citizens of Council of Europe Member States: Identification of the residents of the 

countries listed in the appendix of “European Agreement on Travel of Council of 

Europe Member States” (Austria, Belgium, France, Germany, Greece, Italy, 

Liechtenstein, Luxembourg, Malta, Holland, Spain, Switzerland, and Portugal) who visit 

Turkey for a maximum period of three months and do not seek profit is verified by the 

following documents: 

ID cards of the relevant countries, 

Form of entry/exit from border crossings for persons travelling with ID cards. 

Citizens of Turkish Republic of Northern Cyprus (T.R.N.C.); 

Identification is made by T.R.N.C ID card. 

Documents for identification of small business owners are; 

ID card of the real person, Tax form, 

Statement of signature (or a signature card signed in the presence of a bank 

employee), 

Notarized copy of Chamber of Tradesman/Trade Registry entry (to be taken only for 

transactions involving granting credits such as issuing a credit card or granting 

credit). 

19

A-2-3 IDENTIFICATION OF LEGAL PERSONS REGISTERED TO TRADE REGISTRY 

(Incorporated, Limited, Unlimited, Commandite companies and cooperatives) 

For identification of legal persons registered to trade registry, the following are needed: 

Title of the legal person, 

Trade registry number, 

Taxpayer identification number (TIN), 

Company’s field of activity, 

Detailed address, telephone number, and if possible fax number and email address, 

Name/surname, place and date of birth, nationality, type and number of ID card, 

sample signature and additionally for Turkish citizens name of the father and mother 

and ID Number of the authorized representative of the legal entity, 

The authenticity of the legal person’s title, trade registry number, field of activity and address 

is verified by below mentioned entries in the trade registry. Authenticity of TIN is verified by 

the documents issued by relevant departments of Revenue Administration. 

Authenticity of the ID information of the authorized representatives of the legal person is 

verified by the ID documents stated in the identification section for real persons and the 

authenticity of their power of attorney is verified by entries in the trade registry. 

In order to present to the authorities when demanded, a legible photocopy is made or digital 

image of this verification is taken or the identification information on these documents is 

recorded after the related documents are presented by the customer. 

In permanent business relationships, in the event that a transaction is performed on behalf of 

the legal person upon his/her written order by the person/s authorized to represent, the 

authenticity of the ID information of the authorized representative/s is verified by notarized 

signature circular including the information on ID cards, after being sure that the order is 

given by a company executive. 

In a permanent business relationship, the currency and authenticity of the information in the 

presented registration documents is verified by checking the records of the relevant trade 

registry office or by Trade Registry Gazette interrogation from The Union of Chambers and 

Commodity Exchanges of Turkey. (http://www.tobb.org.tr) 

With respect to the certification of the identity of legal persons or entities, if it is requested by 

branch, the completeness of the required authorizations and certificates shall be certified by 

the Bank’s legal department .Copies of the above documents shall be kept for a time period 

of at least eight years from the end of the business relationship or transaction, in a manner 

ensuring the confidentiality of the data received. 

In order to determine the real beneficiary, 

The identification of the real or legal person partners whose shares exceed 25% is made in 

line with the explanations in this directive. 

Documents that shall be obtained from incorporated companies are; 

Photocopy of the Trade Registry Gazette that covers the complete main contract 

(showing the establishment of the company), 

Original notarized signature circular of the member/s of Board of Directors who will 

represent the company in front of the bank, and photocopies of ID cards of such 

persons, 

Tax form of the company. 

20

Documents that shall be obtained from limited companies are; 



Original, recently signed and notarized signature circular of the manager/s who will 

represent the company in front of the bank, and photocopies of ID cards of such 

persons, 

Tax form of the company. 

Documents that shall be obtained from Cooperatives are; 

Notarized copy of the main contract of cooperative, and photocopy of the Trade 

Registry Gazette showing the establishment of the cooperative. 

Photocopy of the Trade Registry Gazette showing resolution of the Cooperative 

General Board on the appointment and power of Board of Directors. 

Notarized copy of the resolution of the Board of Directors on the authorized 

representative/s, 

If attainable, resolution of Board of Directors on the opening of an account, Notarized 

original of the signature circular of the authorized persons, 

ID cards of the authorized persons, 

Tax form of the cooperative. 

Documents that shall be obtained from unlimited companies are; 



Original notarized signature circular of the shareholder/s who will represent the 

company in front of the bank as stated out in the main contract, and photocopies of ID 

cards of such persons, 

Tax form of the company and its shareholders (Base is opened under the TIN of the 

company and tax forms of the shareholders are kept in the base folder.) 

Documents that shall be obtained from commandite companies are; 



Original notarized signature circular of the shareholder/s who will represent the 

company in front of the bank as stated out in the main contract, and photocopies of ID 

cards of such persons, 

Tax form of the company and its shareholders (Base is opened under the TIN of the 

company and tax forms of the shareholders are kept in the base folder.) 

Documents that shall be obtained from the branch offices of companies are; 

Documents of the main company, 

Notarized copy of the resolution of the Shareholders Assembly/Board of Directors on 

the opening of the branch office (including commercial title of the branch office, 

detailed address, its representatives and powers), 

Photocopy of the Trade Registry Gazette showing the establishment of the branch 

office, 

Recently signed, notarized original of signature circular of the branch office manager 

and his/her ID card, 

Tax form of the company/shareholders. 

21

A-2-4 IDENTIFICATION OF ASSOCIATIONS AND FOUNDATIONS 

For identification of associations, the documents that shall be obtained are; 

Name of the association, 

Cause of establishment, 

Associations Record Registration number, 

Detailed address, telephone and fax number (if attainable) and email address, 

Name/surname, place and date of birth, nationality, type and number of the ID Card, 

sample signature, and additionally for Turkish citizens name of the father and mother 

and ID Number of the authorized representative of the association 

The authenticity of the name, cause, record registration number and address is verified by 

below mentioned documents related to association record and the registration; authenticity of 

the ID information of the authorized representatives of the association is verified by the ID 

documents stated in the identification section; and the authenticity of their power of attorney 

is verified by the documents showing this power. 

For identification of foundations, the documents that shall be obtained are; 

Name of the foundation, 

Cause of establishment, 

Central commerce registration number kept at General Directorate of Foundations, 

Detailed address, telephone and fax number (if attainable) and email address, 



and ID Number of the authorized representative of the foundation. 

The authenticity of the name, cause, central commerce registration number and address is 

verified by below mentioned documents related to foundation record and the registration kept 

at General Directorate of Foundations; authenticity of the ID information of the authorized 

representatives of the foundation is verified by the ID documents stated in the “Identification 

of Real Persons” section; and the authenticity of their power of attorney is verified by the 

documents showing this power. 

In order to present to the authorities when demanded, originals or notarized legible 

photocopies/digital images of the verification documents are taken or the identification 

information on these documents is recorded. 

Identification of the branches and agencies of foreign associations and institutions is based on 

the documents kept at the Ministry of Internal Affairs. 

Documents that shall be obtained from associations are; 

Notarized copy of the Association Record 

Notarized copy of the document stating that the association is recorded in the 

Association Record Book, 

Notarized copy of the resolution of the Board of Directors on the members and powers 

of the General Assembly, 

Notarized copy of the resolution of the Board of Directors on the appointment of 

representative/s among themselves, 

Notarized copy of the resolution of the Board of Directors on the opening of an account 

(if attainable), 

Notarized original signature circular of the authorized persons, ID cards of authorized 

persons, 

TIN of the association. 

22

Documents that shall be obtained from foundations are; 

Notarized copy of foundation voucher, 

Copy of the Official Gazette stating the establishment of the foundation, 

Notarized copy of the resolution of the Board or Committee on the members and 

powers of the Board of Directors (for the foundations appointed by Board of Directors, 

Board of Trustees or General Assembly), 






persons, 

TIN of the association. 

A-2-5 IDENTIFICATION OF UNIONS AND CONFEDERATIONS 

For identification of unions and confederations, the documents that shall be obtained are 

Full name of the union or confederation, 

Cause of the union or federation, 

Registry number kept at Regional Directorate of Working of Ministry of Labor and 

Social Security, 

Detailed address, telephone number, fax number (if possible), and email address, 



and ID Number of the authorized representative of the union or confederation. 

The obtained information is verified by the statutes of these institutions and documents 

recorded in the registry kept at Regional Directorate of Working of Ministry of Labor and 

Social Security; the authenticity of the ID information of the authorized representative/s is 

verified by the identity documents listed in the “Identification of Real Persons” section; and 

their representative status is verified by documents recorded in the registry or a document 

stating their authorization. 




Documents that shall be obtained from unions are; 

Notarized copy of the statute of the union, 

Copy of the registry document kept at Ministry of Labor and Social Security, 

Notarized copy of the resolution of the Union General Assembly on the members and 

powers of the Board of Directors, 






persons, 

TIN of the union. 

23

Documents that shall be obtained from confederations at the opening of accounts 

are; 

Notarized copy of the statute of the confederation, 

Copy of the registry document kept at Ministry of Labor and Social Security, 

Notarized copy of the resolution of the Confederation General Assembly on the 

members and powers of the Board of Directors, 






persons, 

TIN of the confederation. 

A-2-6 IDENTIFICATION OF POLITICAL PARTIES 

For identification of political party organizations, the documents that shall be obtained are; 

Name of the relevant unit of the political party, 




and ID Number of the authorized representative of the political party. 

The name and address of the relevant unit of the political party is verified by their statutes; 

the authenticity of the ID information of the authorized representative/s is verified by the 

identity documents listed in the “Identification of Real Persons” section; and their 

representative status is verified by the documents of authorization. 




Documents that shall be obtained from political parties are; 

Notarized copy of the statute of the political party, 

Resolutions of Center and Central Executive Committee on the powers of 

Province/District Executive Committee (there is no need to obtain these documents if 

they are clearly stated in the statute), 

Notarized copy of the resolution of the Congress on the appointment of the chairman 

and members of Central Executive Committee, 


representative/s of the political party among themselves, 

Notarized copy of the resolution of the Central Executive Committee on the opening of 

an account (if attainable), 


persons, 

TIN of the political party. 

24

A-2-7 IDENTIFICATION OF NON-RESIDENT LEGAL PERSONS 

For the identification of the non-resident legal persons, equivalents of the documents that are 

necessary for identification of resident legal persons are required. These documents need to 

be approved by relevant Turkish Republic Consulates. Identification can also be made within 

the frame of “Agreement on Lifting the Obligation of Foreign Official Documents Ratification” 

by the notarized translations of the copies of these documents which have an annotation of 

ratification by the relevant institution of a country who has signed that agreement. 

Documents that shall be obtained from non-resident legal persons are; 

Documents related to the establishment of the company (approved by the Turkish 

Consulate/having an apostil) and notarized photocopies of their translations. 

Documents related to the authorized representatives of the company (approved by the 

Turkish Consulate/having an apostil) and notarized photocopies of their translations. 

Document showing the scope of the person authorized to perform transactions on 

behalf of the company (approved by the Turkish Consulate/having an apostil) and 

notarized photocopies of their translations. 

Newly signed signature circular (approved by the Turkish Consulate if it has been 

issued abroad/having an apostil) and notarized original of its translation 

ID cards of authorized persons, 

Photocopy of the authorization document TIN of the company 

A-2-8 IDENTIFICATION OF ENTERPRISES WITH NO LEGAL ENTITY 

For identification of enterprises with no legal entity like building, site or office 

building managements, the documents that shall be obtained are; 

Name of the building, site or office building management, 




and ID Number of the authorized representative of the building, site or office building 

management. 

The authenticity of the identity information of the person acting on behalf of the management 

is verified by the identity documents listed in the “Identification of Real Persons” section; 

information on management and representative status of the person acting on behalf of the 

management are verified by notarized resolution book. 

Documents that shall be obtained from management of apartment, site and office 

buildings are; 

A list showing the name, surname and separate block numbers of flat owners, 

Notarized copy of resolution book related to building manager (or Assembly of 

Managers) by assembly of flat owners, 

Management plan (in order to check is there is a limitation on transactions) Notarized 

original of the signature circular of the manager 

ID card of manager (or of Assembly of Managers) 

TIN of building management 

For the identification of enterprises such as business partnerships with no legal 

entity, the documents that shall be obtained are; 

Name of the partnership, 

25

Cause of the partnership, 

Field of activity of the partnership, 

TIN, 


The authenticity of the information on the name, cause, field of activity and address of the 

partnership is verified by notarized partnership contract; TIN is verified by the documents 

issued by the relevant units of Revenue Administration; the identity of persons demanding a 

transaction on behalf of the partnership is verified by the documents listed in the 

“Identification of Real Persons” section; their representative status is verified by the 

document stating this power. 




Documents that shall be obtained from business corporations of ordinary 

partnership nature that have been formed by two or more persons are; 

Notarized copy of the partnership contract, 

Newly signed signature circular/statement of the authorized partner, 

ID cards of the partners, 

Tax forms of the partners. 

Documents that shall be obtained from ordinary partnerships and consortiums are; 



ID cards of the partners/documents related to entry in the trade registry of the 

partner companies, 

Tax forms of the partners. 

Documents that shall be obtained from joint ventures are; 



ID cards of the partners/documents related to entry in the trade registry of the 

partner companies, 

Tax forms of the partnership. 

A-2-9 IDENTIFICATION OF PUBLIC INSTITUTIONS 

According to the Public Financial Management and Control Law No.5018; for transactions 

where the customers are public administrations within the scope of general government and 

occupational institutes having the quality of public institutions, identification of the person 

who acts on behalf of these is made by the identity information listed in the “Identification of 

Real Persons” section; their representative status is verified by power of attorney prepared in 

accordance with the relevant legislation. 

A-2-10 IDENTIFICATION OF THIRD PARTIES WHO ACT ON BEHALF OF OTHERS 

In the event that a transaction is demanded to be performed by authorized persons 

on behalf of legal persons or enterprises with no legal entity; 

Identification of legal persons or enterprises with no legal entity is made within the 

frame of above mentioned explanations. 

26

Identification of authorized representatives of legal persons and enterprises with no 

legal entity and the persons they authorize is made within the frame of the 

explanations in the “Identification of Real Persons” section. 

Identification of authorized representatives of legal persons and enterprises with no 

legal entity can be made by power of attorney or signature circular on the condition 

that these documents are notarized and contain information found on ID card if their 

identification can not be made in line with the explanations in the “Identification of 

Real Persons” section. 

Representative status of those authorized by representatives is cross checked with the 

notarized power of attorney or the written order given by representatives. The 

signatures of the authorized persons on those orders are cross checked with the 

signatures on the notarized signature circular belonging to these persons. 

In the event that a person acts on behalf of a real person; 

Identification of a person acting on behalf of a real person within the frame of the 

documents listed in the “Identification of Real Persons” section. 

Representative status of those acting on behalf of a real person is cross checked with 

a notarized power of attorney. 

Identification of the customer on whose behalf a transaction is performed can be made 

by a notarized power of attorney in cases where identification can not be made by the 

documents listed in the “Identification of Real Persons” section. 

In the event that identification of the person on whose behalf a transaction is 

performed has been made before due to earlier transactions, the transaction can be 

performed upon the written order of the person on whose behalf the transaction will 

be performed on the condition that the signature of the customer on the written order 

is cross checked with the signature kept at the bank. 

In the transactions carried out by legal representatives, representative status of the parents, 

guardians and trustees appointed by courts who act on behalf of minors or other persons 

lacking full capacity is verified by the original or notarized copy of the relevant court decision. 

In the event that parents acts on behalf of their minor children, identification of the minor 

and the parents is made within the frame of the explanations in the “Identification of Real 

Persons” section. 

In order to present to the authorities when demanded, a legible photocopy or digital image of 

these documents are taken or the identification information on these documents is recorded. 

A-2-11 AUTHENTICITY OF THE VERIFICATION DOCUMENTS 

If there are suspicions on the authenticity of the above mentioned documents used for 

verification of identity and other information, the person or institution who has issued the 

documents or other relevant authorities are consulted. 

A-2-12 IDENTIFICATION FOR SUBSEQUENT TRANSACTIONS 

In the subsequent transactions, which will constitute a permanent business relationship, of 

those who have been duly identified, documents related to ID are taken and cross checked 

with the documents kept at bank. If there are suspicions on the authenticity of the obtained 

information, the documents of verification related to ID information or their notarized copies 

are cross checked with the information kept at the bank. 

A-3 RECOGNITION OF BENEFICIAL OWNERS AND PAYING SPECIAL ATTENTION TO 

LEGAL PERSONS 

Beneficial owner means natural persons who carry out a transaction with the bank, and 

natural person(s) who control(s) the natural persons, legal persons or unincorporated 

27

organizations on behalf of whom a transaction is conducted with the bank or who is the 

ultimate owner of the transaction or the account belonging to them. 

We take necessary measures in order to detect whether action is carried out for the benefit of 

another person and to identify the beneficial owner of the transaction. Within this scope, an 

announcement is presented at customer’s convenience in our branches and internet banking 

stating that the liability lies on the persons who transact under their name but on behalf of 

another person. It is also specified in the Banking Transaction Agreement signed with the 

customer in the establishment of permanent business relationship. 

In cases where the person requesting the transaction declares that S/he is acting for the 

benefit of someone else, the identity and the authority of the person requesting the 

transaction and the identity of the person for the benefit of whom the transaction is 

conducted shall be identified in accordance with above mentioned identification rules. 

In the establishment of permanent business relationship with legal persons registered to 

trade registry we also identify, the natural and legal person partners holding more than 25% 

of the legal person shares. 

We take necessary measures to obtain accurate information regarding the persons ultimately 

managing, or having the control or ownership of the legal person which is their customer 

within the scope of a permanent business relationship. 

In cases where there is a suspicion that the person is acting in his/her own name but for the 

benefit of someone else although S/he has declared that S/he is not acting for the benefit of 

someone else, we carry out reasonable inquiry in order to reveal the beneficial owner. 

A-4 TRANSACTIONS REQUIRING SPECIAL ATTENTION 

As described in the part B-10-2 and B-10-3, 

Transaction or transactions or activities incompatible with the customer’s or beneficial 

owner’s economic/transacting profile or have no apparent purpose or motive of a 

financial, professional or personal nature, 

Transaction or transactions or activities giving rise to sufficient indications or 

suspicions of actual or attempted commission of money laundering and terrorist 

financing offences or of involvement of the customer or beneficial owner in criminal 

activities, on the basis of the assessment of data of the transaction and the person, 

Require special due diligence either they are to be performed from an account or without 

opening an account. 

Information and documents shall be obtained related to the cause of the demanded 

transaction, and they have to be kept in order to present to authorities if requested. 

A-5 MONITORING CUSTOMERS AND TRANSACTIONS 

Detailed information on ongoing customer due diligence and transaction monitoring by 

branches and the Head Office can be found in Monitoring and Control Activities section. 

A-6 MEASURES TAKEN AGAINST TECHNOLOGICAL RISKS 

Our bank is obliged to devote special attention to and take necessary measures against risks 

of using advantages of new and developing technology for laundering proceeds of crime and 

terrorist financing. 

Therefore, transactions like cash transactions and money transfers carried out via alternative 

distribution channels such as internet, telephone banking and ATMs are inspected within the 

28

frame of monitoring and control activities. 

Only current customers, who already have relationship with the bank and who are fully 

identified according to KYC rules, can open accounts using internet and phone banking. 

A- 7 PRINCIPLE OF RELIANCE ON THIRD PARTIES 

A business relationship can be established or a transaction can be performed by relying on 

the measures taken by another financial institutions against a customer related to the issues 

of identification of a person acting on behalf of the customer and the beneficiary or 

information on the reason of the transaction. The relevant terms and conditions are defined in 

individual contracts established between the Bank and the third parties. In any case, the 

Bank is ultimately responsible for the identification and verification of its customers and 

ensures that any additional data and information for updating and formulating the customer’s 

economic/transaction profile, on a risk-sensitive basis is directly received from the customer 

or beneficial owner and/or third sources. 

The third parties we rely upon for the identification and verification of our customers are as 

the following: 

Banks 

Institutions other than banks who have the authority to issue bank cards or credit 

cards. 

Authorized exchange offices given in legislation on foreign exchange. 

Money lenders, financing and factoring companies within the scope of legislation on 

money lending. 

Capital Markets Brokerage Houses, Futures Brokerages and portfolio management 

companies 

Investment Fund managers. 

Investment partnerships. 

Insurance, reinsurance and pension companies, and insurance and reinsurance 

brokers 

Financial leasing companies. 

Institutions furnishing settlement and custody services within the framework of capital 

markets legislation. 

Principle of reliance applies when it is certain that; 

The third party maintains a business relationship with the potential client and applies 

customer due diligence and record-keeping measures that commensurate with the 

applicable laws and regulations. 

Third parties duly meet the requirements of identification, record keeping and Know 

Your Customer policy, 

Non-resident third parties are subject to effective regulations and audits regarding 

combat against laundering proceeds of crime and terrorist financing (this is 

confirmed via sending related questionnaires), 

Third parties will present approved copies of documents on identification upon 

request. 

In the event that a business relationship is established or a transaction is performed 

upon reliance on a third party, identity information of the customer is obtained from 

the third party. 

Principle of Reliance on Third Parties does not apply; 

When third parties are residing in risky countries, 

When transactions on behalf of customers are performed among financial 

29

institutions, 

For relationships of financial institutions with their agencies and alike units, and 

people who provide complimentary or extension services for their main activity units. 

AML/CFT Compliance Officer assesses the customer identification and Customer Due Diligence 

procedures applied by the professional intermediary or third party/associate recommending 

the customer, and he/she verifies that they are in line with acceptable international 

standards. The relevant assessment report is prepared and entered in a separate file kept for 

every professional intermediary or third party/associate. 

A-8 REJECTION OF A TRANSACTION AND TERMINATION OF BUSINESS 

RELATIONSHIP 

Business relationship is terminated when necessary identification and verification processes 

cannot be conducted due to suspicions regarding the authenticity and adequacy of the ID 

information. 

We consider the termination of the business relationship with a customer in the following 

cases: 

Whenever the customer is detected on lists of suspect persons and entities (Watch 

Lists) through real-time systemic review; 

whenever customer’s transactions entail unacceptable level of risk; 

in case of difficulties regarding the update of customers’ identification and verification 

data, during the regular review or whenever there are doubts about data validity or 

whenever the customers are classified as high risk; 

in case the customer has not provided the required identification documents and the 

relevant investigation returns no results, irrespective of the customer’s consent for 

inspection of other data required; 

in case there are valid suspicions or knowledge that the Bank’s customers are involved 

in criminal activities, according to the current legislation for the prevention of ML & FT; 

in case the customer has repeatedly been reported to the relevant local authority for 

AML and CFT; 

when during the high risk customer’s reassessment a recommendation is made for 

terminating the business relationship; 

For the termination of a business relationship with Bank’s customers, the relevant Business 

Units prepare and submit a report to the Compliance Department. 

The reports are assessed by the AML/CFT Officer and (if it is required) an overall consolidated 

report is submitted to the AML/ CFT Committee of the Bank recommending the termination of 

the business relationship. 

The AML/ CFT Committee of the Bank decide on the termination or not of the business 

relationship and determine the procedure and the means to inform the customer accordingly. 

In any case it is required Financial Crimes Investigation Board (MASAK) should be informed 

promptly about the Bank’s intention to terminate the business relationship with the 

aforementioned customer. 

The Bank, during the termination of the business relationship with a customer, applies all the 

required confidentiality measures. 

For all the aforementioned, relevant records are maintained according to Record Keeping 

rules. 

30

A-9 CORRESPONDENT BANKING RELATIONSHIPS 

Before establishing correspondent banking relationship with a non-resident bank; 

Information should be obtained from public resources on whether the financial 

institutions have gone through an inquiry related to laundering or terrorist financing 

and have been imposed a penalty; their field of business; reputation; and adequacy of 

audits performed in that bank. 

Assessment should be made about the quality of supervision exercised by regulatory 

authorities, 

Taking into consideration the country assessment reports of FATF, the IMF and the 

World Bank, as well as other independent and reliable sources, adequacy of the 

AML/CFT system in place in the correspondent institution’s country of establishment 

should be evaluated, 

Our bank’s responsibilities and those of the correspondent institution under the 

banking correspondence agreement should be specified clearly, 

It has to be ensured that financial institutions’ combat system against laundering and 

terrorist financing is appropriate and efficient via sending relevant questionnaires. 

Approval of Assistant General Manager of Foreign Relationships shall be taken. 

In the event that correspondent banking relationship includes using transfer 

correspondent accounts (a type of account opened in Turkey by a non-resident 

company. Customers of the account owner company can directly use this account 

which enables drawing cheques), it has to be ensured that the financial institution 

takes necessary measures within the frame of “Know Your Customer” principles and 

can provide customers’ identity information when requested 

Correspondent banking relationships shall not be established with shell banks, and financial 

institutions that are suspected to enable their accounts to be used by shell banks. 

A- 10 ELECTRONIC TRANSFERS 

It is required that the following information of the originator is included in the cross border 

and domestic wire transfer messages which amount to 2.000.-TRY or more; 

a) Name and surname, title of the legal person registered to trade registry, full name of the 

other legal persons and unincorporated organizations; 

b) Account number or reference number of the transaction where no account number exists; 

c) Address or place and date of birth and at least one of the numbers such as customer 

number, TR-ID number, passport number, tax ID number for identifying the originator; 

The above mentioned obligation does not apply to the transfers of banks among themselves 

on behalf of their own name and accounts; and on the condition that card numbers are 

stated in the messages, transfers made from bank and credit cards. 

In the event that an electronic transfer that does not include the above mentioned 

information is received, the transfer is returned or the missing information is completed by 

contacting the related financial institution making the transfer. 

31

On the condition that electronic transfers always have missing information and they cannot 

be completed, denying the transfers, limiting the transactions of the sender institution or 

terminating the business relationship with that institution is considered. 

A-11 ADDITIONAL MEASURES AGAINST HIGH RISK GROUPS 

The definition of high risk groups, the issues that shall be taken into consideration during 

their transactions, and the measures that shall be taken are explained in the “Monitoring and 

Control Activities” section. 

A-12 RELATIONSHIPS WITH RISKY COUNTRIES 

The definition of risky countries, the scope of risky countries, and the measures that shall be 

taken are explained in the “Monitoring and Control Activities” section. 

A-13 SIMPLIFIED MEASURES 

Simplified measure is performance of a transaction or identification of customers who are 

thought to be unrelated to laundering and terrorist financing without taking any documents or 

taking some of the necessary documents, or without fulfilling some obligations. In order to 

decide whether simplified measures can be taken for a customer or the transaction has the 

below mentioned characteristics, adequate knowledge has to be obtained on customers and 

transactions. Therefore, information shall be obtained from the customer, public sources, 

third parties who has worked with the customer before and other sources and these data 

shall be recorded in writing or in an electronic medium. For every circumstance that simplified 

measures will be taken; abuse of these measures in terms of laundering and terrorist 

financing shall be considered, these measures shall not be taken if there are any suspicions 

and suspicious transactions shall be reported. Moreover, risk assessment shall be made 

before taking simplified measures on customer basis. 

For the customers for whom simplified measures will be taken, the following liabilities may 

not be fulfilled: 

Paying close attention to legal persons and identifying the real beneficiary. 

Monitoring the customers and their transactions. 

A-13-1 TRANSACTIONS AMONG FINANCIAL INSTITUTIONS 

For transactions of financial institutions (Appendix 3) among themselves on behalf of their 

own name and accounts; their title, trade registry number, TIN, field of activity, detailed 

address, telephone number, fax number and email address (if possible), and and 

name/surname, place and date of birth, nationality, type and number of the ID Card, sample 

signature, and additionally for Turkish citizens name of the father and mother and ID Number 

of the authorized representative of the legal person are deemed as adequate. This 

information does not have to be verified. 

If it is a non-resident financial institution, the institution must be a resident of one of the 

member states of Financial Action Task Force where the states are subject to sufficient 

regulations and supervision required by international standards related to prevention of 

laundering proceeds of crime and terrorist financing 

For the transactions made through alternative distribution channels with non-resident 

financial institutions; in order to verify that the person acting on behalf of the financial 

institutions is authorized, the transactions have to be made via SWIFT or by using passwords 

which will enable verification and confirmation of the identity and authority of that person. 

32

A-13-2 IN THE EVENT THAT THE CUSTOMER IS PUBLIC ADMINISTRATION OR 

OCCUPATIONAL INSTITUTES HAVING THE SPECIFICATION OF BEING A PUBLIC 

INSTITUTION 

In the event that the customer is public administration or occupational institute having the 

quality of public institutions (Appendix-2) as per the Law No.5018, the information on title, 

license date/number given by official authority, field of activity, detailed address, telephone 

number, fax number and email address (if attainable) should be obtained. This information 

does not have to be verified. However, the identification of the representative is made in line 

with the explanations stated in the “Identification of Real Persons” section, his/her sample 

signature is taken and representative status is verified by power of attorney prepared in line 

with relevant regulations. 

A-13-3 IN THE EVENT THAT THE CUSTOMER IS INTERNATIONAL INSTITUTION OR 

EMBASSY OR CONSULATE RESIDING IN TURKEY 

In the event that the customer is an institution such as The International Monetary Fund, The 

World Bank, European Development Bank or an embassy or consulate residing in Turkey; 

financial institutions record the information of the real persons acting on behalf of these 

institutions stated in Section A-2-2. Authorization of these persons is verified through a 

document showing that they are authorized. Verification of the information obtained 

according to Section A-2-2 is not obligatory. 

As for the transactions carried out within this scope, liabilities of recognition of beneficial 

owners and paying special attention to legal persons and monitoring the customer profile and 

the transactions are not obligatory. 

A-13-4 COLLECTIVE CUSTOMER ACCEPTANCE WITHIN THE FRAME OF SALARY 

PAYMENT AGREEMENTS 

In the establishment of permanent business relationships by the opening of accounts for 

public administration or occupational institute having the quality of public institutions 

pursuant to Law No.5018, or institutions, companies or firms employing more than 100 

people with the aim of paying their salaries through the bank, the following information of the 

real persons shall be obtained: 

Name and surname, 

Date and place of birth, 

Nationality, 

Name of the mother and father and Identity number for Turkish citizens, 

Work or residence address, 

Telephone number, fax number, and email address if attainable. 

The information pertaining to identity is verified in line with the Article 6 of the Regulation. 

Verification can also be made by using identity sharing system database of Ministry of 

Internal Affairs on the condition that digital image is taken. 

The documents of identity as has been explained in the identification section and sample 

signatures are obtained within three months maximum beginning from the date of 

transaction. Verification of address and contact information is also conducted within this 

period. Reporting the names of the persons who will receive their salaries through the bank 

and detailed addresses of their institution is deemed adequate for address verification of the 

institution 

33

A-13-5 SALARY PAYMENT TRANSACTIONS OF MEMBERS OF UNITS OF 

INTERNATIONAL INSTITUTIONS RESIDING IN TURKEY OR MEMBERS OF EMBASSY 

OR CONSULATES 

In the establishment of permanent business relationships by the opening of accounts for 

members of units of international institutions residing in Turkey or members of embassy or 

consulates with the aim of paying their salaries through the bank, the following information 

of the real persons shall be obtained: 

Name and surname, 

Date and place of birth, 

Name of the mother and father and ID Number for Turkish citizens, 

Nationality, 

Work or residence address, 

Telephone number, fax number, and email address if attainable. 

The information pertaining to identity is verified in line with Section A-2-2. Verification can 

also be made by using identity sharing system database of Ministry of Internal Affairs on 

the condition that digital image is taken. 

As for verification of identification, the documents of identity as has been explained in 

Section A-2-2 and sample signatures are obtained within three months maximum 

beginning from the date of transaction. Verification of address is also conducted within this 

period. Reporting the names of the persons who will receive their salaries through the bank 

and detailed addresses of their institution is deemed adequate for address verification of 

the institution. 

Since, the ambassadors and the chargés d’ affaires are considered as PEP’s; related due 

diligence measures are applied prior to account opening. Simplified measures referred 

under this chapter are related to the other members (Turkish or foreign citizens) of the 

embassy or consulates such as mid-level staff members other than senior officials. 

A-13-6 IN THE EVENT THAT CUSTOMER IS A PUBLIC COMPANY WITH QUOTED 

SHARES IN STOCK EXCHANGE 

For the transactions of such companies, information that has been stated in the identification 

section shall be obtained for legal persons related to the company. This information does not 

have to be verified. 

A-13-7 TRANSACTIONS RELATED TO PENSION AGREEMENTS, PENSION PLANS AND 

LIFE INSURANCE AGREEMENTS 

In transactions carried out within the frame of pension agreements, pension plans which grant 

pension rights by making deductions in the salary or life insurance agreements where the total 

amount of premium paid in a year is TRY 2.000,- or below or in single premium accounts 

where the premium amount to be paid is TRY 5.000,- or below; the information listed in the 

“Identification of Real Persons” shall be obtained without regard to verification documents. 

In case of disbursements, verification documents shall also be obtained and verified. 

34

A-13-8 TRANSACTIONS OF PRE-PAID CARDS 

Pre-paid cards are related to the Finansbank accounts of our customers. 

Identification is not obligatory for the below mentioned pre-paid cards which are followed on 

card number basis, do not have a name on them, effective when an amount is preloaded or 

loaded, and allow spending up to the limit of loading. 

Single use pre-paid cards in which the loaded amount does not exceed TRY 300,-, 

Reloadable pre-paid cards for which the total loaded limit does not exceed TRY 5.000,- 

(those cards that allow cash withdrawal or wire transfer to another account amounting 

to a total of more than TRY 2.000 in the same calendar year are excluded) in a calendar 

year. 

A-13-9 VERIFICATION OF ACCURACY OF TELEPHONE AND FAX NUMBERS AND E- 

MAIL ADDRESSES 

Telephone and fax numbers and e-mail addresses of customers obtained for identification 

purposes in the establishment of permanent business relationships are verified by contacting 

the relevant persons through these contact information on a risk based approach when 

necessary. 

A-14 REPORTING OF MONITORING AND EVALUATION RESULTS TO THE BOARD OF 

DIRECTORS VIA AUDIT COMMITTEE 

The results of the monitoring and evaluation activities carried out by AML Unit are reported to 

the Audit Committee every three months, which brings the report to the attention of the 

Board of Directors. 

B- MONITORING AND CONTROL ACTIVITIES 

Monitoring and control activities aim at prevention the risks mentioned in this document and 

continuous monitoring and control of the activities in order to ensure that they are being 

carried out in line with the Law and relevant regulations, communiqués, bank’s in-house 

policy and procedures. 

The deficiencies detected at the end of the controls carried out or the sake of compliance with 

the obligations brought about by the Law is reported to relevant units so that necessary 

measures are taken and the results are followed. It has to be ensured that the officer who 

conducts monitoring and control activities have access to in-house information sources. 

B-1 MONITORING AND CONTROL OF THE TRANSACTIONS OF HIGH RISK GROUP 

CUSTOMERS 

The high risk group customers stated in risk management chapter in detail is; 

Non-residents 

Residents in Offshore Regions and special purpose vehicles (SPVs) 

Persons Residing and Transactions Carried out in Countries Which Do Not Act in 

Accordance with the Recommendations of FATF 

PEP-Politically Exposed Persons 

Companies with Bearer Share 

35

Not-profit organizations 

Persons with high amount of funds (Ex. Private Banking Customers) 

Non-Face-to-Face Transactions 

Risky sectors and profession groups 

Cash transactions 

Correspondent Banking Relationship 

Trusts 

Opening accounts for High Risk Group Customers is performed with the approval of the 

branch managers. The branch manager signs the Customer Assessment Form. Base/account 

openings cannot be carried out with a form that has not been signed by the branch manager. 

Opening accounts for private banking customers is performed with the approval of Head 

Office Private Banking or Head of Private Banking Center. 

Prior to opening accounts for customers in high risk group, their reason for working with our 

bank, reason for opening an account, working principles, information and documents about 

their commercial or non-commercial business are obtained. 

Apart from the regular inspections, on-going monitoring is conducted for accounts and 

transactions of high risk customers, either through a relative information system, or by 

employees of the Bank. 

B-1-1 CONTROLS CONDUCTED BY AML UNIT RELATED TO HIGH RISK GROUP 

CUSTOMERS: 

Exchange Offices (Authorized Institutions) 

Accounts opened for exchange offices whose activities are limited to cash transactions, where 

small bills are changed with larger ones, which do not require professionalism, can be 

founded with a poor technical equipment, are relatively less costly to establish and manage 

than other financial institutions are mostly used as instruments for money laundering in the 

world and in our country without drawing attention in terms of bringing cash money into the 

financial system. Therefore, control of the accounts of exchange offices are conducted 

monthly. 

Control of the Exchange Office Accounts 

The aim is to detect sent and received transfers (money transfers, EFT, SWIFT) by the third 

parties or the exchange office. Information is requested from branches regarding the 

exchange office and transactions as a result of the evaluations made in accordance with these 

criteria. In the light of the information obtained from the branch and the opinions of the AML 

Unit, a suspicious transaction report is made to Financial Crimes Investigation Board if there 

are any suspicions. 

Control of the Real Persons Accounts Whose Address are Exchange Offices 

Transactions of drawing accounts of such persons are inspected. After the inspections 

conducted by paying attention to cash transactions, buying/sale of F/X, sent and received 

transactions, principals/beneficiaries of transfers, information is requested from branches on 

detected real person customers. Suspicious transaction report is made to Financial Crimes 

Investigation Board if it is detected that these persons are partners/employees of exchange 

offices and transactions of the offices are made through their accounts. 

36

Controls conducted in the event that the customers are non-profit 

organizations, private banking customers, or customers of risky sectors and 

occupational groups 

Within the frame of daily monitoring and control activities made through MANTAS AML 

system, account activities of high risk customers are analyzed. In the event that there are 

suspicious transactions, branches are consulted for further information and AML Officer 

reports suspicious customers to MASAK. 

B-2 MONITORING AND CONTROL OF THE TRANSACTIONS PERFORMED IN RISKY 

COUNTRIES 

The below listed criteria are taken into consideration in determining whether the countries are 

risky or not: 

Whether FATF recommendations are being implemented or not 

Whether they are in the list of non-cooperative countries declared by FATF 

Whether they are in OFAC, EU (European Union) and UN (United Nations) lists 

Whether they comply with EU directives 

The nature of the national regulations 

Regime (Dictatorship, military government etc.) 

Qualification of the banking sector 

B-2-1 CONTROLS CONDUCTED BY AML UNIT RELATED TO RISKY COUNTRIES: 

Control of the transfers made through Western Union 

Western Union is a widely used system preferred by Turkish or Foreign walk-in 

customers since it enables fast money transfer. WU transactions are highly risky 

because originators/beneficiaries of the transfers are usually unknown and the senders 

are mostly walk-in customers who are in Turkey for a short period of time. Controls 

are conducted in every three months. Transactions are controlled according to certain 

criteria (amount, risky countries, frequency of transaction, Structuring and Smurfing 

method etc.) on the basis of beneficiary/originator. ID Documents, Senders’ and 

receivers’ occupation, address, telephone number, relation with the risky country and 

the parties of the WU Transaction, their reasons for working with our bank, purpose of 

the WU transaction are asked to the branch. According to the answer of the branch 

and the assessments of the AML Unit, AML Officer prepares a suspicious transaction 

report to be submitted to MASAK. 

Control of the Alerts Generated By ISS System. 

In the electronic transfers the information in our Banking Core System on sender, 

receiver, receiver bank, receiver country, a.k.a.’s (also known as) and other related 

information are cross checked by the KOMTAŞ ISS System with the data obtained from 

OFAC SDN list, EU Sanctions List, Banned/Sanctioned Countries List, Western Union list 

and Finansbank Alert List The user is notified on the basis of a certain ratio of matching 

before completing the transaction, and details are provided in the related menu on Alert 

lists and matching records. 

If there is a logical matching; the user consults the AML Unit immediately. Having 

completed all necessary controls both on AML Unit’s and the user’s side ; the transaction is 

approved or , rejected by the user. 

37

Furthermore, on a daily basis, AML Unit conducts certain controls and checks the previous 

days’ customer base opening and electronic transfers to detect whether either of the 

transactions has been approved without consulting AML Unit although the match rate is equal 

or more than 85% for base opening, %75 for electronic transfers or there is a logical 

similarity with the information provided in the KOMTAŞ ISS system. 

B-3 MONITORING AND CONTROL OF COMPLEX AND UNUSUAL TRANSACTIONS 

Complex and unusual transactions are monitored within the frame of below stated controls: 

B-3-1 CONTROL OF SAFE DEPOSIT BOXES 

In order to detect risky transactions such as hiring a safe box for common use with those 

other than family, relatives and business related persons, or giving power of attorney to such 

persons; busy transaction traffic showing that the safe box is being used by many people as 

safe deposit box; frequent use of safe boxes by those who do not have remarkable account 

transactions and transaction volume; hiring the safe box under different names before and 

after performing remarkable transactions; hiring a safe box on behalf of a commercial 

company even though the transactions do not require one, the list of hired safe boxes are 

taken at the end of every month. Suspicious transactions are reported to Financial Crimes 

Investigation Board depending on the information obtained from the branches. 

B-3-2 ANALYSIS OF CASH AND TRANSFER TRANSACTIONS: 


system, cash and transfer transactions are analyzed. In the event that there are suspicious 

transactions, branches are consulted for further information and AML Officer reports 

suspicious transactions to MASAK. 

B-4 CROSS CHECK OF THE TRANSACTIONS ABOVE A CERTAIN AMOUNT WITH THE 

CUSTOMER PROFILE BY THE SAMPLING METHOD 

Where in the evaluation phase made during account opening it is decided that the 

transactions of the account shall be monitored for a specific period although there is no risk 

involved in opening an account for that customer or where it is determined that the customer 

carries out transactions that are inconsistent with his profile after the account has been 

opened, the employee who has opened the account or made these designations shall inform 

Compliance Department AML Unit in writing to allow customer-based monitoring and review 

that will be conducted specifically. 


system, customers whose accounts are inconsistent with their profiles are detected. Branches 

are consulted for further information and after assessment of the information received from 

the Branch, Compliance Officer submits suspicious transaction report to MASAK. 

B-5 MONITORING AND CONTROL OF THE TRANSACTIONS WHICH EXCEED 

IDENTIFICATION LIMIT AND SUBSEQUENT TRANSACTIONS 

Report on cash transactions and transfers which exceed identification limit are obtained by 

Internal Audit Department Central Monitoring Unit. This report is sent to auditors who inspect 

the branches detected in the report. Auditors, then, inspect sample transactions among the 

cash and transfer transactions listed in the report in order to check whether identification has 

been conducted, signature has been taken, and power of attorney has been taken if there is a 

transaction performed by third parties. The findings are sent to Internal Audit Department 

Central Monitoring Unit. Every six months, this unit informs the AML Unit about suspicious 

transactions who report them to the Financial Crimes Investigation Board. 

38

B-6 CONTROL OF THE INFORMATION AND DOCUMENTS RELATED TO CUSTOMERS 

THAT ARE KEPT IN WRITING OR AN ELECTRONIC MEDIUM; CONTROL OF THE 

INFORMATION THAT HAS TO BE STATED IN ELECTRONIC TRANSFER MESSAGES; 

COMPLETION AND UPDATING OF THESE INFORMATION 

Taking and keeping of the ID card for transactions requiring permanent business relationship 

and exceeding identification limit has been explained in the “Risk Management” section. 

For the control, completion and updating of the obligatory information in the electronic 

messages, in line with the European Union directives, special attention is paid to fully provide 

the principal’s information that is making the overseas transfer (name/surname, address and 

reference number or passport number or account number). In the event that there is missing 

information, extra time is given to the bank making the overseas transfer. If the required 

information is not provided, transfer fee is returned. 

B-7 ON-GOING MONITORING OF THE TRANSACTIONS IN ORDER TO CHECK THEIR 

CONSISTENCE WITH THE CUSTOMER’S OCCUPATION, RISK PROFILE AND SOURCES 

OF FUNDS 

In the event that the same customer has different accounts at different branches, these 

accounts shall be monitored on a consolidated basis. 

Customers; 

Attempting to carry out any transaction with no apparent legal or economic purpose; 

Who ask transactions which are not proportionate to their income or job are made; 

Who avoid or are reluctant in supplying documents and information required to be 

supplied by law; 

Who give the impression of avoiding reporting and record keeping procedures; 

Who supply misleading and unverifiable information; 

Who ask for non-economical credit or credit with no explained purpose; 

Who say that they are expecting or want to send high amount wire transfers from or 

to risky geographical regions and countries; 

Shall be monitored carefully. 

Where in the evaluation phase made during account opening it is decided that the 

transactions of the account shall be monitored for a specific period although there is no risk 

involved in opening an account for that customer, where it is determined that the customer 

carries out transactions that are inconsistent with his profile after the account has been 

opened, or if the customer demands some transactions like the ones listed above, the 

employee who has opened the account or made these designations shall inform Compliance 

Department AML Unit in writing to allow customer-based monitoring and review that will be 

conducted specifically. 


system, customers whose accounts are inconsistent with their profiles are detected. Branches 

are consulted for further information and after assessment of the information received from 

the Branch, AML Officer submits suspicious transaction report to MASAK. 

39

B-8 CONTROLS OF THE NON FACE-TO-FACE TRANSACTIONS 

Our bank is obliged to devote special attention to and take necessary measures against risks 

of using advantages of new and developing technology for laundering proceeds of crime and 

terrorist financing. 

Therefore, transactions like cash transactions and money transfers carried out via alternative 

distribution channels such as internet, telephone banking and ATMs are controlled within the 

frame of monitoring and control activities made through MANTAS AML system. 

In addition, at the beginning of the business relationship, before establishing a business 

relation with the customer, a customer should be physically present in our branches for ID 

verification and other related actions such as signing the banking transactions agreement or 

other legal documents. Therefore, such transactions cannot be executed by walk-in 

customers via internet banking, call center, etc. 

B-9 RISK BASED CONTROL OF NEW PRODUCTS AND SERVICES THAT MAY BECOME 

VULNERABLE TO MISUSE DUE TO TECHNOLOGICAL DEVELOPMENTS 

Before a new product of our bank is put on the market, it is submitted to Legal Compliance 

Department, Internal Audit Department, Internal Control Center and Risk Management for 

approval. After the subject is evaluated in a risk-based approach and in accordance with the 

legislation, the new product is approved and presented to customers. 

B-10 SUSPICIOUS OR UNUSUAL TRANSACTION REPORTING 

A suspicious transaction is an event where there is information, suspicion or any matter that 

may evoke the suspicion that a possession which is part of a transaction made within or over 

our bank or which is part of an attempted-transaction, is gained by illegal means or used for 

illegal aims, terrorist attacks or that the possession is used by terrorist organizations, 

terrorists or people who finance terror. 

An unusual transaction or transactions or activities incompatible with the customer’s or 

beneficial owner’s economic/transacting profile (transactional, professional or business 

behavior, financial condition) or have no apparent purpose or motive of a financial, 

professional or personal nature. 

Suspicious or unusual transactions are – regardless of the amount of the transaction – 

reported to The Financial Crimes Investigation Board (MASAK) operating within the body of 

Ministry of Finance. While evaluating the suspiciousness of the transaction, matters like the 

profile and scale of the activities of the client, nature of the transaction and whether the 

transaction is found within the normal activities of the client or is proportional with the 

activity of the client and to whom the transaction provides benefits, characteristics of the 

sector and previous experiences shall be taken into consideration. In case of an international 

transaction, it must be checked that whether the transaction is part of the business of the 

client. 

The term “transaction” in the concept of “suspicious transaction” is not limited to only one 

transaction. When necessary, more than one transactions may be handled together to find 

out whether there is suspicion or a reasonable cause for suspicion. For example, a series of 

transactions which do not evoke suspicion as single transactions may evoke suspicion when 

evaluated together. 

In case of a suspicious or unusual transaction, customer identification shall be made for 

reporting. In case of an attempted-transaction, the obligation for customer identification is 

carried out in the possible extent. 

40

The reporting of a transaction within continuous reports does not render the transaction 

exempt from suspicious transaction reporting. 

Compliance Officers are responsible for reporting suspicious or unusual transactions to 

MASAK. In our bank, Mr. Ahmet Erzengin and Ms. Başak Yılmaz from Compliance Department 

are authorized for this duty. 

Suspicious Transaction Forms shall be filled in and sent to the above mentioned Compliance 

Officers. It is compulsory to report these transactions to MASAK in 10 working days time 

after the suspicion occurred. 

When new information or findings are acquired about a previously reported transaction, a 

new Suspicious Transaction Reporting Form is filled in and sent to the Compliance 

Department stating that the new report is an addition to the previously reported transaction. 

Those who report suspicious or unusual transactions and other bank personnel, who are 

informed of the transaction, shall not reveal the reporting to anyone other than auditors who 

are in charge of audit of obligations and courts in course of a trial. Internal reports are also 

confidential. Compliance Officers carrying out suspicious transactions in the electronic media 

shall not share instruments – cards, passwords, etc. - that enable accessing the system with 

anyone. 

Central offices of the bank found in foreign countries, branches, agencies, commercial agents 

and/or other similar units shall not be informed about the reporting. 

Bank employees - Compliance Officers, legal agents, managers and bank personnel - who 

carry out their obligations to report suspicious transactions shall not be held responsible for 

any legal and criminal results about fulfilling this duty. 

B-10-1 LAUNDERING PROCEEDS OF CRIME 

Wealth gained by predicate offenses such as human trafficking, drug and arms smuggling, 

corruption and bribery, fraud, forgery and hijacking are tried to be laundered in the financial 

system through various stages, such as segmentation. Proceeds of crime that are placed into 

the financial system through various methods pass through numerous operations in order to 

make it difficult to track its source (money transfers to many people in the country or abroad, 

purchase and sale of foreign currencies, etc.). 

After placement and layering stages, proceeds of crime again pass through many transactions 

– called the integration stage – in order to bring it back to the source. The purpose is to make 

it harder both for those who perform the transactions and for auditors to reach the launderer. 

Throughout their work to prevent money laundering, our employees shall be careful for 

transactions; 

Which do not have legal and economic purposes in appearance, 

Which are not related and proportional with the income and job of the client, 

In which the client is unwilling to present the documents and information that are 

stated as compulsory by the Law, 

In which the client tries to avoid reporting and preserving of records, 

In which the information given by the client is misleading and impossible to attest, 

Of high-scale sent to risky countries or geographical areas and extraordinary transfers, 

and for loan applications which do not have economic purposes and purposes of which are not 

described by the client. 

Possible suspicious transaction types are described below: 

41

B-10-2 SUSPICIOUS OR UNSUAL TRANSACTION TYPES DESCRIBED IN GENERAL 

COMMUNIQUE NO. 6 OF THE FINANCIAL CRIMES INVESTIGATION BOARD 

SUSPICIOUS OR UNUSUAL TRANSACTIONS IN THE GENERAL NATURE 

1. Types regarding the customer profile 

1.1. Insufficient or contradictory information on the documents presented to bank personnel 

or reluctance in presenting documents. 

1.2. Existence of concrete suspicious behaviors such as offering remuneration or various 

gifts in exchange for the transaction or situations such as existence of unfavorable news 

about the customer in the press that the customer is involved in financing of terror. 

1.3. Customer is engaged in deliberate urge to establish friendly relations with the bank 

personnel or is in a threatening attitude to prevent the reporting of the suspicious 

transaction. 

1.4. Inconsistency among customer’s job/occupation, financial situation and type of 

transactions. 

1.5. Commercial or other type of relations of the customer with risky persons or institutions. 

1.6. When compared with other companies in the sector; unusual capital, partnership, 

management and employment structure of the company. 

2. Types regarding the transactions 

2.1. A single transaction of a person or an institution engaged in commercial activities that 

should normally be a routine and continuous transaction within the commercial activities or 

on the contrary, continuous repetition of transactions that are relatively rare in the 

commercial life. 

2.2. In order to evade detection and reporting, without a reasonable explanation, separation 

of transactions that should normally be made as a whole. 

2.3. Absence of a reasonable legal or economic reason of the requested transaction. 

2.4. Unusual use of payment instruments such as high amount of payments of the customer 

in small denominations or payment using a rare foreign currency. 

SUSPICIOUS OR UNUSUAL TRANSACTIONS ACCORDING TO THE SECTOR 

3. Types regarding the banking sector 

Suspicious or Unusual Customer Behaviors and Indications Regarding the 

Presentation of Insufficient-Misleading-False Information and Documents 

3.1. Before carrying out a transaction, customer tries to acquire information and asks 

questions about the customer identification and obligation of suspicious transaction reporting, 

transaction limits and bank’s control methods in the fight against money laundering 

3.2. Hardships are experienced during the receipt of the customer’s personal information 

such as his occupation, identity, address and telephone number. 

3.3. The customer has difficulty to explain or refrains from giving information about the 

42

purpose of the transaction and the source of the funds subject to the transaction. 

3.4. The customer tries to persuade the bank official for not filling a document which is 

legally or administratively required to be filled or submitted to the official authorities. 

3.5. The customer requests to open account by power of attorney in the name of many 

persons located inside or outside the country without a valid reason or without substantiating 

its justification or he constantly deposits or draws cash for transactions carried out through 

the accounts opened in the name of third persons. 

3.6. The account holders do not have sufficient knowledge of the funds deposited or existing 

in their accounts. 

3.7. Customers, which are apparently independent from each other, giving the same 

address, telephone number and other contact information, transferring fund to the same 

beneficiaries, receiving transfers from same applicants and entitling same person(s) with the 

authority to sign. 

3.8. The customer rents safe deposit boxes together with persons who are not members of 

his family or with whom he has no business partnership or he gives power of attorney to such 

persons in order to allow them use his safe deposit boxes, intensive use of the safe deposit 

box by many persons showing that the deposit box is used as a cash box, customers whose 

account relationship and transactions with the bank are not at considerable amounts use the 

safe deposit boxes intensely, customer rents safe deposit boxes in the name of third persons 

just before or just after a remarkable transaction, and though its commercial activities do not 

require, commercial institution rents safe deposit boxes. 

3.9. Persons understood to be having no family or business relations with each other open 

joint deposit accounts; they perform collective transactions on such accounts and it is 

observed that the domestic or international cash or electronic funds transfer traffic through 

such accounts is considerably higher than reasonably deemed appropriate for the profile of 

the saving deposit in question. 

3.10. It is understood that the real or legal entities shown as the partners and managers of 

the legal entity customers are indeed not genuine shareholders of such companies and there 

is a suspicion that the capital and the management of the company are under control of third 

persons who have bad reputation or against whom legal actions have been instigated by 

official authorities. 

3.11. The new controlling partner and/or partners of legal entities evade providing 

information regarding his personal and business background and the new partner has no 

previous interest, educational background and work experience regarding the field of activity 

of the company. 

Customer Identification, Record Keeping and Indications of Avoiding Reporting 

Procedures 

3.12. Customer tries to open accounts, carry out transactions or perform transactions in the 

name or over the accounts of others without presenting their identity cards or by presenting 

false or imaginary identities. 

3.13. Customer tries to persuade bank officials not to report the suspicious transaction by 

different offers, oppression or by threatening. 

3.14. In order to evade the procedure of reporting, customer segments or attempts to 

segment the money that is subject to transaction by depositing or transferring into different 

accounts or as cash. 

3.15. Customer holds many accounts by which he operates on his behalf or on behalf of 

others in different branches of the same bank or persons understood to have opened similar 

43

accounts in other banks. 

3.16. Many people depositing money into the same account or drawing money from the 

same account without any clear or practical reason. 

Types regarding transactions with cash character 

3.17. The cash brought by the customer is in small denominations and dirty; there are stains 

on it or it smells indicating that it has been carried as covered inside various articles; it has 

been packed precariously and in a hurried way; it often turns out to be less or more than the 

value stated by the customer once it is counted; there are counterfeit money in it; the 

customer gives this in pack or covered by an article in a way that can not be deemed 

appropriate for the customer. 

3.18. It is observed in the customer’s accounts that cash draw or deposit transactions in 

many small amounts which total a high amount, or in a single transaction in a high amount 

which can not be deemed congruent with the living standards, occupation and income level of 

the customer. 

3.19. The cash deposited to the accounts is constantly transferred abroad or to other 

domestic accounts without providing sufficient explanation, or such accounts are left idle for a 

long time after such transactions are carried out for a period. 

3.20. The amounts transferred to the accounts which are understood to have been opened 

for the sole purpose of collecting the transfers from abroad are constantly drawn in cash 

without being subject to any transaction, or such accounts are left idle for a long time after 

such transactions are carried out for a period. 

3.21. The customer keeps idle accounts with small balances in several branches of the same 

bank, and he draws the incoming transfers to such accounts through maximum limit cash 

drawings from ATMs. 

3.22. People, who do not have a clear relationship with the company, deposit cash into 

accounts or draw cash from accounts opened in the name of the company and from the sum 

of these transactions it is evident that the transaction is not carried out within commercial 

purposes. 

3.23. The customer often deposits or draws significant amounts of cash in a single 

transaction without considering the risks of security, theft and abuse that may arise out of 

transport of cash money, except for appropriate reasons. 

3.24. Without any clear economic purposes, accounts opened with high amounts of cash by 

legal persons or entities about whom no sufficient information is acquired. 

3.25. By frequently putting in cash equivalents, the customer requests the issuance of quasi 

money instruments such as certified check, letter of guarantee, and payment order over 

sums that are not related or which can not be associated with his business. 

3.26. Depositing small pieces of denominations into the same account by different persons 

through the same or different branches. 

3.27. Depositing a high amount of cash into an account of a small balance and drawing this 

sum or transferring into one or more than accounts just after the transaction. 

Indications Regarding Electronic Transfers 

3.28. Transfers in high amounts and at a single transaction without any reasonable 

explanation to or from risky countries or offshore centers, or such transfers in small amounts 

but many in number during a certain period of time. 

44

3.29. There are no explanations regarding the purpose of the electronic fund transfers at 

considerably high amounts and frequencies from high-risk regions; the spaces for the full 

names and addresses of the payees and payers in transfer messages are not filled or 

pseudonyms, codes or abbreviations are written instead of specifying the full names of the 

genuine payers. 

3.30. A considerably high traffic of domestic and international electronic fund transfers at 

considerably high frequencies is observed at the customer’s accounts and which are 

incongruent with the declared occupation, activities, income sources and income level of the 


3.31. The incoming funds transferred from abroad to the accounts or the names of the 

customers with registered addresses inside or outside the country are transferred back to 

abroad after a brief period, or the customer requests from the bank clerk realizing the 

transaction that the transfer amounts he expects from abroad and not registered to his 

accounts yet to be transferred to abroad; similar amounts of funds enter and exit the country 

at similar dates through such accounts used as transitory accounts. 

3.32. The customer opens more than one account in the same currency without any specific 

cause, and transfers the cash deposited to these accounts or the cash funds transferred to 

these accounts to persons or entities located in free trade zones or offshore geographical 

areas with which the customer has no apparent business relation. 

3.33. Accounts opened only for transfers outside the country and there is no sufficient 

information regarding the relationship between payees and payers of these transfers. 

3.34. Customer carrying out indirect electronic fund transfers that are not related to the 

personal or economic situation of the customer. 

3.35. High amounts are transferred into an account right after it is opened and the account 

is left idle for a long period of time. 

3.36. Transfers carried out by a person acting in the name of the customer, over foreign 

currencies between people or countries which have no commercial relationship with the 


Indications Regarding Loan and Credit Transactions 

3.37. Real persons and entities, about whom there is not much, request cash credits or letter 

of guarantee for commodity purchases, in a way not caring for the commissions, charges or 

interest rates of the bank. 

3.38. The customer presents a check of high amount which is drawn on a foreign bank, as 

his guarantee for credit, to the bank granting the credit, but the information about the 

commercial activity that the check stems from is contradictor, the customer can not present 

supporting document, apparently a commercial relationship can not be observed among the 

drawer and the endorsers and the endorsers have an association with risky territories in 

terms of swindling and smuggling. 

3.39. Credit utilization from banks found in risky countries or applying for credit in regard of 

letter of guarantees provided from these banks. 

3.40. The customer applies for a loan by showing the assets of third persons or of the 

companies registered in risky countries as guarantee without a reasonable and practical 

cause. 

3.41. Although the customer has a remarkable amount of wealth, he applies for a credit that 

is not rational for him by showing his assets as guarantee. 

45

3.42. The customer applies for a credit by showing as guarantee bearer instruments or other 

instruments the sources of which are unknown. 

3.43. The potential credit customer is either reluctant to state the reasons of applying for 

credit, refuses to state such reasons and states a doubtful reason. 

3.44. Without a clear reason, third persons who are unknown to the bank and who does not 

have close relationship with the customer provide guarantees. 

3.45. Credit card customer perpetually draws a remarkable amount of cash, or uses the 

credit card continuously and/or extraordinarily for the purchase of valuables that are easy to 

change such as gold. 

3.46. Without a logical reason and surprisingly, the customer all of a sudden pays back a 

non-performing or an undue credit. 

4. Types Regarding the Insurance Sector 

4.1. The customer applies to insure a risk that that is not associated with his personality, his 

business or capital. 

4.2. The customer requests a single premium draft of high amount that is not associated with 

his general and financial situation. 

4.3. The customer declares or the bank finds out that he has bills from other companies as 

well, and this shows incongruity with the financial situation of the customer. 

4.4. The customer offers to buy insurance policy in the name of a third party which has 

clearly no connection with him, or requests the insurance indemnity to be transferred into the 

account of the party in question or again in the name of a third party, requests the changing 

of the beneficiary. 

4.5. The customer overpays in cash the premiums of insurance or pension plans. 

4.6. A customer who owns a regular payment draft of small amount all of a sudden pays the 

remaining premiums of the draft in cash, offers a remarkable increase or buys a new draft of 

high amount. 

4.7. Without a logical reason and aware of the remarkable loss the transaction would bring, 

the customer requests the draft to be paid back before its expiry or to be paid in favor of a 

third party. 

4.8. The customer pays the premiums of an insurance contract via electronic transfer over a 

financial institution found in a risky country. 

4.9. The customer applies for a pension plan or life insurance, which can not be deemed 

congruent with his age or health. 

5. Types Regarding the Capital Markets 

5.1. It can be understood that the customer do not seek profit in his transactions, does not 

care the cost and risk of his investments and gives unreasonable orders that usually end up 

with loss. 

5.2. The customer borrows a loan of remarkable amount that is incongruent with his 

business or the guarantee for the credit is given by a third person that is seemed to have no 

relationship with the customer. 

5.3. Without a situation regarding the market conditions or any other logical reason, the 

46

customer, all of a sudden, pays back the security loan before its expiry. 

5.4. Without a logical reason, the customer continuously transfers securities and/or cash into 

to the accounts of others – found in different intermediary institutions. 

5.5. Inconsistent with his common activities, the customer buys securities or other capital 

market instruments in remarkable amounts by cash. 

5.6. The financial investments and/or the proceeds of these investments are immediately 

transferred to third parties who are seemed to have no connection with the customer. 

5.7. There is a transaction ban imposed by the Capital Markets Board for the shareholders or 

founders of the legal entity customer. 

5.8. There is a suspicion that the customer is carrying out transactions on behalf of persons 

who are banned by the Capital Markets Board. 

6. Types Regarding the Competent Authorities 

6.1. In a short period of time, requests regarding foreign currency purchase and sale - 

through a competent authority – in amounts below the limit that requires customer 

identification are constantly repeated. 

6.2. Constant repetition of foreign exchange purchase or sale transactions and the change of 

a foreign currency with another. 

6.3. The change of small denominations in uncountable amounts with large denominations. 

6.4. The cash brought by the customer is in small denominations and dirty; there are stains 

on it or it smells indicating that it has been carried as covered inside various articles; it has 

been packed precariously and in a hurried way; it often turns out to be less or more than the 

value stated by the customer once it is counted; there are counterfeit money in it; the 

customer gives this in pack or covered by an article in a way that can not be deemed 

appropriate for the customer. 

6.5. The request to change non-convertible or a rarely used foreign currency with another 

foreign currency or with Turkish Liras. 

7. Types Regarding the Lenders 

7.1. The debtor requests a loan in exchange for a property the source of which is suspicious 

(or unknown). 

7.2. Despite the remarkable wealth of the debtor, he requests to carry out uneconomic loan 

transactions. 

7.3. The debtor pays back by checks to the bearer, by checks that belong to third parties, by 

checks that are frequently endorsed or by cash in high amounts. 

7.4. Surprisingly and all of a sudden, an unexpired or a non-performing credit is paid back. 

8. Types Regarding the Factoring Companies 

8.1. The company which transfers its claims of a forward sale to a factoring company 

(vendor), continuously carries out the sale of goods or services at costs higher than the 

conditions of the market to its legal person or legal entity customers (purchaser). 

8.2. The purchaser company pays or guarantees to pay on time its forward debts, which 

over exceed its financial situation, or in a similar situation the vendor company gives the 

47

guarantee that the purchaser will pay its debts on time. 

8.3. There is a suspicion that the purchaser or vendor company may be a shell company or 

that there may be a fictitious transaction established between them. 

8.4. There is a suspicion about the genuinity of the invoices presented to the factoring 

company. 

9. Types Regarding Leasing Companies 

9.1. An attempt to rent a machine or equipment by leasing method at inappropriate prices 

when compared with current market or estimated value. 

9.2. Leasing payments that are much higher than normally requested and that are not based 

on a reason. 

9.3. The payment of leasing debts from an unknown source before its expiry. 

9.4. Without a logical reason, the performing of obligations or payments that incur from the 

leasing contract by third persons or by persons who supply the goods in question. 

10. Types Regarding Consumer Finance Companies 

10.1. Without a clear reason and despite the financial loss it will cause, the customer all of a 

sudden pays back the credit. 

10.2. The customer carries out unprofitable credit transactions in exchange for the 

remarkable wealth he possesses. 

10.3. There are indications that the customers do not care the costs and term of the credit. 

11. Types Regarding Mail and Transportation Services and Courier Companies 

11.1. It is clear that the goods that are sent via mail or courier are different than the ones 

declared by the sender. 

11.2. Sending valuables such as gemstones, mines, etc. to certain addresses other than 

those dealing with trade or production in the sector. 

12. Types Regarding the Real Estate Sector 

12.1. Without a logical reason such as business or family relation, the customer purchases 

real estate in the name of third persons. 

12.2. Inconsistently with his financial situation, the customer buys real estates at high 

values or without making any research about the location and conditions of the real estate, 

the customer buys properties that require a remarkable cost of repair. 

12.3. Customers who sell their real estates, and demand the sale value to be recorded 

higher than the actual value. 

12.4. After carrying out the first payment in cash; for the rest of the leasing, the customer 

uses an extraordinary payment method or a high amount of cash. 

13. Types regarding people who are supposed to have connection with terrorist 

organizations and transactions carried out in risky countries 

13.1. Opening accounts, transferring funds or carrying out electronic fund transfer in the 

48

name of legal persons of legal entities that are known to have relations with a terrorist 

organization. 

13.2. Electronic fund transfers that have no commercial explanation or economic reason, 

into commercial accounts found in risky countries and/or drawing these amounts out of the 

account. 

13.3. Transferring funds into risky countries or receiving funds from these countries, 

opening accounts in financial institutions found in these countries or using credit cards of 

banks found in these countries. 

13.4. Funds are transferred by third persons to countries associated with terrorism and 

smuggling or named as tax heavens, or to regions, which have no open business connections 

with the customer, in the name of the customer after exchanging the currency of such funds. 

13.5. Transferring the deposits that are gained by transfers from risky countries or over 

risky countries to third persons. 

13.6. Collection of funds particularly from risky countries or transferring funds into these 

countries, by use of many individual and commercial accounts, and transferring such funds to 

a limited number of payees. 

13.7. Without a commercial reason that would render the transaction reasonable, use of 

commercial financial transactions in fund transfers to/from risky countries. 

14. The Types Regarding Non-Profit Organizations 

14.1. Inconsistency between the pattern and size of financial transactions or amount of 

funds raised or moved, and the apparent sources, stated purpose and activities of the Non- 

Profit Organizations. For example, a cultural association that, after organizing a music 

festival, deposits disproportionate amounts on its bank account. 

14.2. Appearing of a sudden increase in the frequency and amounts of financial transactions 

in the account of a non-profit organization. 

14.3. Keeping funds in the accounts of a non-profit organization for a very long period. 

14.4. Where non-profit organizations receive contributions only from donors located abroad 

or the origin of which is mostly from abroad. 

14.5. The existence of foreign directors in non-profit organizations, and particularly 

existence of large outgoing transactions to the country of origin of such directors and 

especially if destination is a high-risk jurisdiction. 

14.6. The existence of a large number of non-profit organizations with unexplained links: for 

example, several non-profit organizations transfer money to each other or share the same 

address, same managers or personnel. 

14.7. The existence of account movements which makes an impression that non-profit 

organizations holding little or no staff, no suitable offices or telephone numbers have 

intensive activities. 

14.8. Receiving funds by using many personal and commercial accounts or accounts of nonprofit 

organizations and later transferring these funds to foreign beneficiaries in a short period 

of time. 

49

B-10-3 TERRORIST FINANCING 

Characteristics of Terrorist Financing 

The primary objective of terrorism is to compel a government or an international organization 

to do or to abstain from doing any act by intimidating a people or arousing indignation in a 

people. All terrorist organizations need financial resources in order to carry out their financial 

activities regardless of what the aimed target is. Therefore, terrorist organizations seek to 

have adequate financial resources and to use these resources without attracting the attention 

of concerned public authorities. For this reason, it is of great importance in the fight against 

terrorism to deprive terrorist organizations of financial resources. 

A good-knowledge regarding the characteristics of terrorist financing is the primary 

requirement for an effective fight against terrorist financing. One of the most important 

characteristic of terrorist financing is to necessitate carrying out it without attracting the 

attention of law enforcement authorities. Therefore, by concealing terrorist acts, the reveal of 

the connection between terrorist financiers and the original offence is avoided and the seizure 

or confiscation of the funds allocated to terrorist financing is precluded. In this regard, 

terrorist financiers usually apply methods similar to those used by launderers when they are 

operating these funds for terrorist organizations or conveying them to terrorists or terrorist 

organizations. 

Obliged parties should be more careful about the detection of suspicious situations related 

with terrorist financing as terrorism can be financed from funds acquired through not only 

illegal means but also legal means. For example a terrorist organization can be financially 

supported through legally acquired incomes of an enterprise running business in 

manufacturing of service sector. In this respect, it is necessary to closely monitor and know 

not only the origin of the fund but also where it is used. 

The fact that even small amount of funds are enough for performing some terrorist acts 

makes it necessary for obliged parties to be more careful in detection of acts related with 

terrorist financing, which is different from that of laundering acts. 

Financial Resources of Terrorism 

Terrorist organizations meet the financial needs necessary for their activities from various 

sources. 

Resources acquired through illegal activities 

Terrorist organizations obtain significant amounts of resource through illegal activities 

committed by criminal organizations as well. The major activities include drug trafficking and 

arms smuggling, human trafficking, migrant smuggling, threat, blackmail, racketing, 

extortion, robbery and kidnapping. 

Narcotics smuggling is one of the leading illegal financial resources of terrorism, and “narco- 

terrorism” concept is recently being used in defining the close connection between terrorist 

organizations and drug smugglers. 

Likewise, there is a direct relation between arms smuggling and terrorism. Terrorist 

organizations both meet their need of arm and obtain income through arms smuggling. 

Collecting money through racketing by applying pressure, threat and blackmail is another 

illegal financial method. 

Terrorist organizations also engage in human trafficking and migrant smuggling in 

cooperation with networks conducting activities abroad and share the profits of the crime 

networks involved in these fields. 

50

Extortion and robbery are methods applied by small terrorist organizations or used for the 

purpose of raising necessary funds to embark on activities. 

Kidnapping for ransom is a financing method which is commonly used by terrorist 

organizations. Once the organization proves to be successful in these activities, it keeps on 

procuring funds without kidnapping, only by way of intimidation and threat. 

Gathering funds by coercion from firms and persons participating in tenders is another 

method that the organizations prefer for financing. 

Sources Acquired through Ostensibly Legal Activities 

Terrorist organizations acquire considerable amount of their funds through ostensibly legal 

activities. The followings are the major ostensibly legal activities: 

Use of Non-profit Organizations 

Non-profit organizations such as associations and foundations are very often used in acquiring 

ostensibly legal sources for terrorist organizations. Funds raised under titles of dues, 

donations or aids for these organizations are funneled to terrorist organizations or terrorists 

through various methods. Some people usually do not know that the money they give will be 

transferred to terrorist organizations, but they donate believing that it will be used for the 

legal purpose stated by the non-profit organization. On the other hand, some people finance 

terrorist organizations intentionally and willingly in ostensibly legal ways, for example by 

seemingly donating for a charity association, and therefore they do not attract the attention 

of public authorities. 

Use of Business Entities 

Income derived from legal activities of entities established by persons who apparently do not 

have any relations with the organization may be used for financing of terrorism. In most 

cases, fields of activity of these entities are also fields through which logistic support may be 

supplied to the terrorist organization. Establishment of a transport company for the purpose 

of transporting necessary goods for the terrorist organization or for using in drug trafficking 

or establishment of a travel agency to make it easy for members of the terrorist organization 

to go abroad may be given an example. In this respect, it is important that the obliged 

parties know owners of their legal person customers and report it to MASAK after carrying out 

necessary research where there is a suspicious case. 

Use of Visual and Printed Media 

Media firms are among the means of propaganda and financing used by terrorist 

organizations. Particularly sympathizers of terrorist organization provide funds through paying 

high amounts of money to visual and printed media firms under the name of advertisement 

cost. Members of the organization, as well, are supported financially by demonstrating as 

employees of those media firms. 

Use of social activities 

Terrorist organizations organize concerts, festivals, exhibitions, charity fairs and 

demonstrations for raising funds through receiving participation fees. 

Sources Supplied by Other Countries 

Beside sources of finance cited above, countries willing to use terrorism as an international 

51

means of policy provide support to terrorist organizations by granting right of asylum to the 

members, permitting the organizations use its territory as a base as well as financing them in 

a covered or uncovered manner. These covered financial supports are particularly made 

through donations in kind or in cash provided for associations and foundations that have close 

relations with the terrorist organizations. These contributions are then funneled to the 

terrorist organization or used by those associations and foundations to gain sympathizers for 

the organization, to make the propaganda of the organization or in a way to help the 

organization gain sympathy within the society. 

Definition of the Suspicious or Unusual Transaction Regarding Terrorist 

Financing 

The definition of suspicious or unusual transaction covers “use of the asset subject to 

transaction for illegal purposes” in addition to acquirement of it through illegal ways, which 

demonstrates that it aims essentially to prevent financing of terrorism. In this scope, cases 

where there is any information, suspicion or reasonable grounds to suspect that the funds are 

used for terrorist activities or by terrorist organizations, terrorists or those who finance 

terrorism, or that the funds are related or linked to terrorist organizations, terrorists or those 

who finance terrorism shall be subject to suspicious transaction reporting. 

Suspicious or Unusual Transaction Types Regarding the Detection of 

Terrorist Financing 

Suspicious or unusual transaction types regarding the detection of terrorist financing are set 

out in the General Communiqué No. 6 of Financial Crimes Investigation Board (MASAK) and 

detailed in the 13 th and 14 th suspicious transaction types above. Regardless of the sum of the 

transaction, in cases where there is information, suspicion or situation causing suspicion that 

the wealth subject to the transaction – carried out or attempted transaction made by/over 

our bank – is used for terrorist actions or by terrorists, those financing terror or is associated 

with these and even if the transaction in question do not match any of the mentioned types, 

it is compulsory to report the situation as a suspicious transaction of terrorist financing. 

B-10-4 HOW TO FILL-IN, SIGN AND SEND THE SUSPICIOUS TRANSACTION 

REPORTING FORM TO COMPLIANCE DEPARTMENT 

When there is a suspicious or unusual transaction, regardless of the sum of the transaction, 

our branches and units that are related with remote transactions (Telephone Banking, 

Internet Banking) make a research within their authorities and taking the information and 

findings acquired into consideration, prepare a Suspicious Transaction Reporting Form. 

While filling-in the Suspicious Transaction Reporting Form, following points are taken into 

account: 

Suspicious Transaction Reporting Form (Appendix 4) is issued in the electronic media. 

In section A, the name of branch, “The Bank” (in the line saying Liable Group), 

address, telephone and Taxpayer Identification Number are written. 

In section B, the date of reporting, explanation whether it is a new report or not and if 

it is an additional report, the date of the previous report and the urgency level of the 

report are written. 

In section C, information regarding the identity of the person requesting the 

transaction and information whether the person is requesting this transaction on his 

behalf or on behalf of others is specified. Identity information shall be specified in full. 

In case where the person is requesting the transaction on behalf of someone else, the 

name of the person on whose behalf the transaction is carried out is specified in 

section D. 

In case where the person is requesting the transaction on behalf of a legal entity, the 

name of legal entity or the organization which does not have a legal personality are 

52

specified in full in section E. 

In section F, the date and type of the suspicious transaction, information whether the 

transaction is carried out within an account, city/district and the name of the branch, 

name of the unit, sum of the transaction and through which channel the transaction is 

carried out are specified in full. 

In cases where the transaction is carried out within an account, information regarding 

the account are specified in full in section G. 

In part (H) of the form, suspicious transaction types are classified. In case, suspicious 

transactions to be reported are marked at that part. 

Whichever classification is appropriate, suspicious transaction to be reported is marked 

with an (X). Then, at the “suspicious transaction typology” part, the code number of 

the type of suspicious transaction is written down as stated in the General 

Communiqué No. 6 of MASAK. 

For example, if the customer do not seek profit in his transactions, does not care the cost and 

risk of his investments and gives unreasonable orders that usually end up with loss; the 

empty box in the line “Types Regarding the Capital Markets” in section H is marked with an X 

and the number of the type of the transaction which is 5.1 in this example, is written down. 

It is possible that the transaction is included in more than one type (transactions with general 

nature, transactions regarding the sector and terrorist financing). In this case, all of the 

relevant transaction types are marked and necessary points are specified in “EXPLANATIONS” 

part. 

If a transaction matches clearly with the types found in “Suspicious or Unusual Transaction 

Types Regarding Terrorist Financing”, this type is marked in the form. But, if the transaction 

matches with the types specified in transactions with general nature or transactions regarding 

the sector, and thus evokes the suspicion that it is related with terrorist financing, the 

relevant transaction type is marked and the situation is specified in “EXPLANATIONS” part. 

If the suspicious or unusual transaction does not match with any of the 3 general types, the 

suspicion and information regarding the character of the transaction is specified in 

“EXPLANATIONS” part. 

Legible copy of the identity card of the customer, abstract of the account in which the 

suspicious transactions are found, receipt and other related documents are attached to 

the form. 

B-10-5 REPORTING SUSPICIOUS OR UNUSUAL TRANSACTIONS TO MASAK 

The information found in Suspicious Transaction Reporting Forms that are sent to AML Unit is 

evaluated considering the relevant laws, regulations and communiqués by the AML Officer. 

Then, AML Officer decides whether to send the report to MASAK or not. 

In cases where it is not deemed necessary to send the report to Financial Crimes 

Investigation Board, the form together with the written statement about the reason for not 

sending the report are kept by the Compliance Officer for 8 years to present to authorities 

when necessary. 

Transactions which are deemed necessary to report, are submitted to electronic MASAK portal 

with e-signature in 10 working days at the latest. However, in very urgent cases, the 

suspicious transaction and the parties of the transaction are reported both to the Financial 

Crimes Investigation Board and to the competent and authorized Chief Public Prosecutors 

Office. 

As the reports sent to the Compliance Officer are confidential documents, the form and other 

correspondences are kept for 8 years away from the access of third parties. 

53

If a suspicious transaction is not reported, the institution and the Officer neglecting his 

obligation will be imposed an administrative penalty. 

Those who report suspicious transactions and other bank personnel, who are informed of the 

transaction, shall not reveal the reporting to anyone other than auditors who are in charge of 

audit of obligations and courts in course of a trial. Those who do not obey this confidentiality 

are charged with one to three years of imprisonment and administrative penalty up to five 

thousand days. 

C- TRAINING ACTIVITIES 

C-1 CONTENT AND SCOPE OF TRAINING ACTIVITIES 

It is a legal liability for our bank to arrange training activities regarding prevention of 

laundering proceeds of crime and financing terror. These training activities are organized by 

the coordination and cooperation of AML and Training units. The authority and responsibility 

of effective implementation of training activities lie on Compliance Department. 

C-1-1 METHODS OF TRAINING ACTIVITIES 

In-class training: New employees and promoted personnel attend in-class trainings 

which last a day. At the end of the day, attendants are evaluated and those who get 

70 or a higher grade complete the training with success. 

E-Learning: AML Unit specifies the personnel groups who should take this type of 

training and informs the Training Unit of these groups. The training is held accessible 

for 3 weeks for the attendants to complete this training. At the end of the training, 

attendants take an evaluation test and those who get 70 or a higher grade, complete 

the training with success. 

Seminars: Seminars are organized in cities or regions where AML Unit finds out that 

there are deficiencies or breakdowns. Personnel working in the branches of the city, 

neighbor cities and Regional Offices attend these seminars. The duration of seminars – 

a half-day or a day – is decided by taking the number of attendants into consideration. 

C-1-2 CONTENT OF TRAINING ACTIVITIES 

Trainings, at the minimum level, include the following: 

The terms “Laundering proceeds of crime” and “terrorist financing” 

Stages and methods of laundering proceeds of crime and examples (real examples 

from Turkey and abroad) 

Legal legislation about laundering proceeds of crime and terrorist financing 

Risk areas 

Institutional policy and procedures 

Principles regarding the identification of the customer 

Principles regarding suspicious transaction reporting 

Liability to keep and present 

Liability to present document and give information 

Sanctions to be imposed for the breach of liabilities 

International regulations on prevention of money laundering and terrorist financing 

In order to help the attendants to follow the subjects, both training documents and overhead 

projectors are used. The training is strengthened by Examples regarding laundering proceeds 

of crime and terrorist financing and case studies. 

54

C-1-3 TARGET GROUPS 

The following are the target groups of the training activities: 

For Branches: All staff (except for security staff members and personal assistants.) 

For Headquarters: All staff (except for security staff members, IT staff members, 

Construction and Real Estate staff members and personal assistants.) 

C-1-4 TRAINING DOCUMENTS 

All of the training documents are prepared by AML Unit. 

Training notes are prepared and distributed to the attendants of in-class trainings and 

overhead projector is used in order to make easier for the attendants to follow the 

subjects. The documents used with overhead projectors shall include subject titles and 

summarized notes. The training is strengthened by the help of examples and case 

studies which are determined by the educator. 

E-trainings are prepared in cooperation with Training Unit. 

The duration of seminars, content and documents to be used are determined and 

prepared by AML Unit by considering the lack of knowledge and problems 

encountered. Training documents are distributed to the attendants. 

In accordance with the amendments in national or international practice and with the 

new legislation, AML Unit updates training documents. 

C-1-5 TRAINERS 

Trainers are determined by AML and Training Units. Trainers should be experienced and 

should have completed the training of trainers arranged by Financial Crimes Investigation 

Board. Before the training, trainers should attend national and international trainings, 

seminars or conferences. 

C-1-6 EVALUATION OF TRAINING RESULTS 

The test results of e-training and in-class trainings are sent to AML Unit by Training Unit at 

the end of each month. 

Training Unit is informed about those who fail or who do not complete e-training. These 

personnel retake this training. Those who fail for the second time, take in-class training. 

Personnel who fail in-class training retake this training in the next semester. 

Those who complete in-class training with success are included in e-training every year to see 

the latest updates. 

C-1-7 REPORTING TRAINING RESULTS TO FINANCIAL CRIMES INVESTIGATION 

BOARD 

Every year until the end of March, a notification about the training activities carried out in the 

previous year is prepared and sent to Financial Crimes Investigation Board. 

Training dates 

Place of trainings (cities or regions) 

Type of training 

55

Duration of the training 

The number of attendants and the ratio of this number to the total number of 

employees 

Ratio of the personnel attending the training according to units and titles 

Content of the training 

The title and area of expertise of trainers 

The above mentioned information is prepared by Training Unit and sent to AML Unit, who 

sends this information to Financial Crimes Investigation Board until the 15 th of March at the 

latest. 

D- INTERNAL AUDIT ACTIVITIES 

The effectiveness and efficiency of institutional policy and procedures, risk management, 

follow and control activities, effectiveness of risk policy, accordance of the transactions with 

law, regulations and communiqués are annually examined and monitored in a risk-based 

approach. 

Internal Audit Department carries out internal auditing activities regarding Prevention of 

Laundering Proceeds of Crime and Terrorist Financing. Internal Audit Department determines 

the scope of this type of internal auditing in accordance with the views and recommendations 

of Compliance Department. 

In this context; 

Views and recommendations about the deficiencies, faults and misuses that are found 

out within internal auditing activities are presented to Compliance Department in order 

to prevent the repetition of these matters and Compliance Department prepares a 

report in the light of these findings and sends the report to the Executive Board. 

Customers, services and transactions bearing risks and deficiencies are included in the 

audit. 

Size and transaction volume of our bank are taken into account while determining the 

units and transactions to be included in the audit. Within this scope, it is aimed to 

audit the units and transactions having the quality and quantity that would represent 

all of the transactions carried out. 

Reporting internal audit results 

Regarding the work carried out within the scope of internal auditing; annual transaction 

volume of our bank, total number of personnel and total number of branches, agencies and 

other similar units, the number of audited units, agencies and other similar units, audit dates, 

total duration of audit, personnel working in internal audit and total number of transactions 

audited are annually presented to Compliance Department until the end of February. 

Compliance Officer presents this report to Financial Crimes Investigation Board until the end 

of March. 

E- RELATIONS WITH NBG GROUP COMPLIANCE DIVISION 

Unless there is a contradiction with the laws prevailing in Turkey, Finansbank A.Ş shall act in 

accordance with the legislation that NBG is subject to. 

Finansbank A.Ş. Compliance Department; 

56

Submits quarterly reports of regular activities to NBG Group Compliance Division. 

Submits annual activity report and a detailed compliance plan for the following year to 

the NBG Group Compliance Division. 

Reports penalties imposed to our bank by public authorities to NBG Group Compliance 

division in 48 hours. 

Submits the drafts of the in-house regulations to NBG Group Compliance Division in 

order to assure compliance of these regulations with the legal regulations that NBG 

Group is subject to, and publishes these regulations upon taking consent from NBG 

Group Compliance division and making revisions if necessary. 

Informs NBG Group Compliance Division about the practices which are detected by the 

regulatory and supervisory authorities to be in contradiction with the legal regulations. 

Informs NBG Group Compliance Division about the scope of the investigations carried 

out by the regulatory and supervisory authorities. 

Submits relevant reports to the NBG Group Compliance Division, in order to 

incorporate the relevant information in the report submitted by the Group to the BoG. 

Submits the necessary information to the NBG Group Compliance Division at least two 

(2) months prior the submission deadline to the BoG. 

Notifies the NBG Group Compliance Division for all changes in the internal procedures 

as well for possible upgrades of systems. 

57

Appendix 1 

Customer’s Name, Last 

Name/Title 

Occupation/Commercial 

activity/Main type of 

business 

FINANSBANK A.S. 

..................BRANCH 

CUSTOMER ASSESSMENT FORM 

Address 

Country of 

residence 

The reason for preferring and opening account with our bank: 

Recommendation 

Adverts or Promotion 

Branch Solicitation 

Necessity (Use of accounts with our banks 

in payments to be made to customer) 

Use of Credit 

Other 

Terms of working with our bank, types of transactions to be carried out: 

Deposit Accounts and Other Investment 

Products 

Domestic Wire Transfers and EFT 

International Wire Transfers 

Use of Cheque Books 

TRY/Forex Cheque Collection 

Use of Credit 

Credit Card 

POS Device 

International Trade Transactions 

Insurance Products 

Other 

Customers who work with us, from whom we can get reference information: 

Information about the financial situation of the customer and other matters to 

be stated: 

Customer is in the High Risk Group. Customer is not in the High Risk Group. 

Necessary assessments were made regarding Know Your Customer Principles and 

Procedures of Prevention of Laundering Proceeds of Crime of our Bank and customer is 

appropriate for opening an account. 

Customer Representative’s Name- Signature Date 

Surname 

58

Appendix 2 

Messrs. 

SOLEMN DECLARATION BY THE LEGAL REPRESENTATIVE(s) TO OPEN A 

CORPORATE ACCOUNT 

(OFFSHORE COMPANIES AND COMPANIES WITH BEARER SHARES) 

Finansbank A.Ş. 

Dear Sirs, 

A. I (We) the undersigned …………………………………………………..…………….……… 

…………………………………………………..……………………………………………………….………, 

in our capacity as the Legal Representative(s) of 

………………………………………………… ………………………………… (name of company) which 

wishes to apply for the opening of an account with your Bank, hereby declare 

the following: 

1. We are fully aware of the provisions of Law 5549 for the Prevention of 

Laundering the Proceeds of Crime and Terrorist Financing and of the relevant 

regulations. 

In respect of the above Company we have applied our client acceptance procedures, 

which, inter alia, include identification of the ultimate beneficial owners of the 

Company and have conducted full enquiries regarding the nature and extent of its 

business. 

On the basis of the above procedures and enquires and to the best of our knowledge 

and belief we hereby confirm that: 

(a) At present the ultimate beneficial owner(s) of the above Company is (are) the 

individual(s) listed below: 

Name (1) 

....................……………………………………………………....................................... 

Full residential address 

59

..……………………………………………………......................................................... 

Nationality 

………………………………………………............................................................. 

Id Card No./ Passport No. 

...................……………………………………………….......................................... 

Profession / occupation 

.............................................…………………………………………………............. 

Name (2) 

....................……………………………………………………....................................... 


..……………………………………………………......................................................... 

Nationality 

………………………………………………............................................................. 


...................……………………………………………….......................................... 


.............................................…………………………………………………............. 

Name (3) 

....................……………………………………………………....................................... 


..……………………………………………………......................................................... 

Nationality 

………………………………………………............................................................. 


...................……………………………………………….......................................... 


.............................................…………………………………………………............. 

(b) The above mentioned ultimate beneficial owner(s) is (are) not directly and/or 

60

indirectly involved in any criminal conduct or money laundering activity. 

(c) The main business activity of the company is: 

………………………………………………………………………………………………….………………… 

……………………………………………………………………………………………………………………. 

(d) The anticipated annual level of the business activity is: 

……………………………………………………………………………………………………………………. 

(e) The purpose/reason for applying for the opening of the account is: 

………………………………………………………………………………………………………………..…… 

………………………………………………………………………………………………….………………… 

……………………………………………………………………………………………………………………. 

(f) The anticipated credit turnover in connection with all of the above 

mentioned company’s accounts is: 

………………………………………………………………………………………………………………..…… 

(g) The expected origin of the funds to be credited is: 

………………………………………………………………………………………………………………..…… 

………………………………………………………………………………………………….………………… 

……………………………………………………………………………………………………………………. 

(h) The expected destination of outgoing payments is: 

………………………………………………………………………………………………………………..…… 

………………………………………………………………………………………………….………………… 

……………………………………………………………………………………………………………………. 

2. In the event that there is any change in the above-mentioned information 

and/or in the ultimate beneficial owner(s) of the above Company, I (we) 

undertake to advise you immediately of any such change in writing as I (we) 

will be liable for any damage towards the Finansbank A.Ş. resulting from my 

(our) omission to submit the above-mentioned changes. 

3. The following documentation (or equivalent for entities registered abroad) is 

enclosed in relation to the company concerned: 

(a) Abstract of Companies Registrar/ 

Certificate of registration by the Relevant Authorities 

(b) Memorandum and articles of association 

(c) Certificate of directors and secretary 

(d) Certificate of shareholders 

61

(e) Board resolution for the opening of an account 

(f) Board resolution appointing authorised signatories 

( 

g 

) True copies of identity cards/passports of all 

authorised signatories of the company 

(h) True copies of identity cards/passports of at least 

two directors (including the managing director) 

of the company 

(i) True copies of identity cards/passports of 

ultimate beneficial owner(s), if different from persons 

covered by (g) or (h) 

(j) Copy of the Trust Deed of Appointment of 

Nominees 

(k) Written confirmation by the Legal Representative(s) 

regarding the ownership structure leading to the 

ultimate beneficial owner (diagrammatical or otherwise) 

Signed by the said Legal Representative(s) 

…………………………………………………………………………………………………………………………… 

…….. 

…………………………………………………………………………………………………………………………… 

…….. 

Name(s) (in print) and position 

…………………………………………………………………………………………………………………………… 

………… 

………………………………………………………………………………………………………………………………… 

……. 

Date …………….………………………………………………… 

In witness of Officer / employee of Bank: 

S 

i 

g 

n 

e 

d …………………………………………………………………………..…….. 

Name /position ………………………………………………………………… 

Bank Unit 

……………………………………………..…..………… Date …………………………… 

62

Appendix 3 

Financial Institutions: 

Other banks, 

Institutions other than banks which are authorized to issue bank 

cards and credit cards, 

Authorized institutions stated in foreign exchange legislation, 

Those who give loans within the frame of legislation on lending 

money, Financing institutions, 

Factoring companies, 

Capital Market brokers and portfolio management 

companies, Investment funds, 

Investment partnerships, 

Insurance, reinsurance and pension 

companies, Financial leasing companies, 

Companies offering clearance and keeping services within the frame 

of Capital Market legislation, 

General Directorate of Turkish Posts and Telegraph Organization as 

limited to banking transactions.. 

Public Administrations within the scope of Law No.5018 against which 

simplified measures can be taken 

PUBLIC ADMINISTRATIONS WITHIN THE SCOPE OF GENERAL 

GOVERNMENT 

1-Public Administrations Within the Scope of General Budget 

1. Turkish Grand National Assembly 

2. Presidency 

3. Prime Ministry and Ministries 

4. Constitutional Court 

5. Supreme Court 

6. Council of State 

7. Court of Accounts 

8. Secretariat General of the National Security Council 

9. National Intelligence Organization 

10. General Command of Gendarmerie 

11. Turkish Coast Guard Command 

12. General Directorate of Security 

13. The Presidency of Religious Affairs 

14. Prime Ministry State Planning Organization 

15. Undersecretariat of Treasury 

16. Undersecretariat of Foreign Trade 

17. Undersecretariat of Customs 

18. Undersecretariat of Maritime Affairs 

19. Secretariat General for EU Affairs 

20. Prime Ministry State Auditing Board 

21. Prime Ministry State Personnel Ministry 

22. Administration for Disabled People 

23. Turkish Statistical Institute 

24. Revenue Administration 

63

25. General Directorate of State Hydraulic Works 

26. General Directorate of Highways 

27. General Directorate of Land Registry and Cadastre 

28. Turkish State Meteorological Service 

29. General Directorate of Agrarian Reform 

30. General Directorate of Petroleum Affairs 

31. General Directorate of Press and Information 

32. General Directorate of Social Help and Solidarity 

33. General Directorate of Social Services and Children Protection 

34. General Directorate of Family and Social Researches 

35. General Directorate on the Status of Women 

2.Special Budgeted Administration 

A)Board of Higher Education, Universities and Institutes of Technology 

1. Board of Higher Education 

2. Student Selection and Placement Center 

3. Universities and Institutes of Technology 

B)Other Special Budgeted Administrations 

1. Undersecretariat for Defense Industries 

2. Atatürk Culture, Language and History Agency 

3. Public Administration Institute for Turkey & the Middle East 

4. The Scientific and Technological Research Council of Turkey 

5. The Turkish Academy of Sciences 

6. The Turkish Academy of Justice 

7. General Directorate of Higher Education Credit and Dormitories Institution 

8. General Directorate of Youth and Sports 

9. General Directorate of State Theatres 

10. General Directorate of State Operate and Ballet 

11. General Directorate of Forestry 

12. General Directorate of Foundations 

13. General Directorate of Health for Borders and Coasts 

14. General Directorate of Electrical Power Resources Survey and Development 

Administration 

15. General Directorate of Mineral Research and Exploration 

16. Directorate General of Civil Aviation 

17. Turkish Accreditation Agency 

18. Turkish Standards Institution 

19. National Productivity Center 

20. Turkish Patent Institute 

21. National Boron Research Institute 

22. Turkish Atomic Energy Agency 

23. Presidency of Development and Support of Small and Medium-Sized Enterprises 

Administration 

24. Export Promotion Center 

25. Turkish International Cooperation and Development Agency 

26. Environmental Protection Agency for Special Areas 

27. Southeastern Anatolia Project Regional Development Administration 

28. Privatization Administration 

29. Agency for Workshops in Punishment and Correction Institutions and Prisons 

30. Government Auditors Agency 

31. Agency for Professional Competence 

64

C)Regulatory and Supervisory Administrations 

1. Radio and Television Supreme Council 

2. Telecommunication Institution 

3. Capital Market Board 

4. Banking Regulation and Supervision Agency 

5. Energy Market Supervisory Authority 

6. Public Procurement Agency 

7. Turkish Competition Authority 

8. Tobacco, Tobacco Products and Alcoholic Beverages Market Regulation Agency 

Occupational Institutes Having Specification of Public Administrations 

These institutions that are nominated by secret vote are public legal entities 

established in accordance with the laws with the aim of meeting the common 

needs of members of an occupation, facilitating their occupational activities, 

helping the occupation develop in line with general advantages, and making 

honesty and trust dominant in their relationships with each other and public. The 

units of these institutes are under judicial supervision of their members in line 

with the principles stated in laws. 

Some of these institutes are: 

1. Cooperatives and senior organizations, 

2. Chambers of Commerce and Industry, Chambers of Commerce, Chambers of 

Industry, Chambers of Maritime Trade, Chambers of Commodity Exchange 

and senior organizations, 

3. Craftsmen’s Associations and senior organizations, 

4. Chambers of Architects and Engineers and senior organizations, 

5. Chamber of Medical Doctors and senior organizations, 

6. Bar Associations and senior organizations. 

65

Appendix 4 

Mali Suçları Araştırma Kurulu 

Başkanlığı 

SUSPICIOUS TRANSACTION Maliye Bakanlığı, N Blok 

REPORTING FORM Dikmen Cad. 06100 

Dikmen/ANKARA 

Tel: +90 (312) 415 37 67 

Fax: +90 (312) 415 25 35 - 36 

A- INFORMATION ABOUT THE LIABLE ISSUING THE FORM 

Name, Surname - Title i : 

Liable Group ii : 

Address : 

Tel : Identity Number iii : 

B- INFORMATION ABOUT THE REPORTING 

Date of Reporting 

Document 

New or Addition New Date of the previous reporting: .../.../…. 

Urgency level Normal Urgent Very urgent 

C- INFORMATION ABOUT THE LEGAL PERSON CARRYING OUT THE 

SUSPICIOUS TRANSACTION 

The customer is carrying out On his behalf On behalf of someone 

the transaction Else 

Is the identity card fake? Yes No 

Name 

Surname 

Date and place of birth 

Mother’s Name 

Father’s Name 

Gender Male Female 

Nationality 

Identity Number 

Type and Number of the Birth Certificate No: 

Identity Card Driving License No: 

Passport No: 

Residence Permit No: 

Other (Type and Number): 

Address Home: 

Work: 

Telephone Number Home : 

GSM : 

Work : 

Fax Number 

E-mail address 

Occupation 

Additional information (if 

necessary) 

66

D- INFORMATION ABOUT THE LEGAL PERSON ON WHOSE BEHALF 

THE TRANSACTION IS CARRIED OUT v 

Is the identity card fake? Yes No 

Name 

Surname 

Place and date of birth 

Mother’s Name 

Father’s Name 

Gender Male Female 

Nationality 

Identity Number 

Type and Number of the Birth Certificate No: 

Identity Card Driving License No: 

Passport No: 

Residence Permit No: 

Other (Type and Number): 

Address Home: 

Work: 

Telephone Number Home : 

GSM : 

Work : 

Fax 

E-mail address 

Occupation: 

Additional Information (if 

necessary) 

E- INFORMATION ABOUT THE LEGAL ENTITY/ORGANISATION WHICH 

DOES NOT HAVE A LEGAL PERSONALITY IN WHOSE NAME THE 

TRANSACTION IS CARRIED OUT vi 

Are the documents used for Yes No 

identification fake? 

Title vii 

Name of Business 

Taxpayer Identification Number 

Register Number viii 

Country of Founding 

Place of Founding 

Year of Founding 

Address 

Telephone Number GSM : 

Work : 

Fax 

E-mail Address 

Web Site 

Additional Information(if 

necessary) 

67

F- INFORMATION ABOUT THE SUSPICIOUS TRANSACTION 

Date of Transaction 

Is there a monetary 

value/Activity in the 

transaction?? 

The transaction is 

Place of Transaction ix 

Type of Transaction 

Sum of Transaction x 

Place or Method of Transaction 

Single transaction :/../…. 

Linked transactions :/../…. - ../../…. 

Yes No 

linked to an account (If you mark this 

box, please also fill in Section G) 

nor linked to an account 

Branch aATM İnternet 

banking 

Telephone banking Other 

G- ACCOUNT INFORMATION RELEVANT WITH THE TRANSACTION xi 

Type of account Cheque Safe deposit box Forward 

exchange 

Check exchange Current account 

Investment 

Other 

Financial institution in which the 

account is found 

Account No 

IBAN 

Account Holder 

Date of opening of the account ../../…. 

Date of closure of the account 

Latest account balance 

Branch in which the account is 

found 

Type of currency of the account 

Is there a legal limitation on the Yes No 

account? 

Explanation of legal limitation 

68

H- TYPE OF SUSPICIOUS TRANSACTION 

SUSPICIOUS TRANSACTION TYPES NUMBER OF SUSPICIOUS 

SUSPICIOUS TRANSACTIONS IN THE GENERAL NATURE 

Types Regarding the Customer Profile 

Types Regarding the Transactions 

SUSPICIOUS TRANSACTIONS ACCORDING TO THE SECTOR 

Types Regarding the Banking Sector 

Types Regarding the Insurance Sector 

Types Regarding the Capital Markets 

Types Regarding the Competent Authorities 

Types Regarding the Lenders 

Types Regarding the Factoring Companies 

Types Regarding the Leasing Companies 

Types Regarding the Consumer Finance 

Types Regarding Mail Services and Courrier 

Types Regarding the Real Estate Sector 

SUSPICIOUS TRANSACTION TYPES REGARDING TERRORIST FINANCING 

Types Regarding People who are Supposed to 

Have Connection with Terrorist Organizations 

The Types Regarding Non-Profit Organizations 

EXPLANATION 

Name-Surname and 

Signature of the 

Compliance Officer xiii 

69

i Name and surname for legal person liable, commercial name for legal entities, name of 

organisation which liables which do not have a legal personality 

ii The relevant group in found in 4 th article of Measures Regulation 

iii Identity Number for legal person liable, Taxpayer Identification Number for other liables 

iv Information of each legal person in transactions which are carried out by more than one 

person 

v Information of each legal person in whose name the transaction is carried out in 

transactions that are carried out in the name of more than one legal person 

vi Information of each legal entity in whose name the transaction is carried out in 

transactions that are carried out in the name of more than one legal entity 

vii Commercial name for legal entities who are registered in the Commercial Register; 

name of organisation for associations, syndicates, confederations and others which do not have 

a legal personality, name of the relevant branch for political parties. 

viii Trade register number for legal entities registered in the Commercial Register, generation 

number for associations, central register number for foundations, register number for syndicates 

and confederations 

ix Information about the city/district and branch, agency or units in the transaction is carried 

out 

x Specify the currency 

xi Fill in by taking into consideration sub-clauses (a) to (h) of the 1 st clause of the 4 th article of 

Measures Regulation. 

xii Number of one or more suspicious transaction types found in Annex 1 

xiii In liables where it is not necessary to appoint Compliance Officer, the form is signed by 

the person detecting or carrying out the transaction and if there is, by someone who is 

authorized with the finalization of the transaction 

70

finansbank anti-money laundering / know your customer procedure

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