|Coat of Arms of the Ottoman Empire|
Turkey has a number of major AML/CFT problems that are NOT being addressed, and I simply do not buy the premise that an action plan, if it has even been developed, will ever be effective. Here are but a few of the issues that I see:
(1) Turkey allows Iraqi truckers to purchase oil from ISIS/ISIL, and sell it on the black market, in Turkey; we call this terrorist financing in my book.
(2) Turkish ministers, and their sons, are deeply embroiled in a major scandal involving the sale of sanctioned Iranian "Gas for Gold," in a $13bn program. Turkish companies and banks are also believed to have facilitated $130bn in illicit transactions with Iran.
(3) Turkey financially supports Hamas, a Specially-Designated Global Terrorist group (SDGT). It also allows Hamas to maintain offices there, and provides safe haven to some of its most senior leaders.
(4) Remember our earlier article, dealing with five Turkish banks, with branches in Iraq, that are believed to be assisting in Iran sanctions evasion. if you did not see it, look for Are Five Turkish banks in Iraq Assisting in Iran Sanctions Evasion ? December 2, 2013.
Do not lower your Country Risk assessment on Turkey, based upon the FATF decision, as it is deeply flawed.