Turkey Anti-corruption Guide 2022

1. Is your country a member of the OECD Anti-Bribery Convention?


2. Is your country a member of any other bilateral or multilateral conventions on anti-corruption?

Yes. Turkey is also a member of

  • The Group of States Against Corruption (GRECO);
  • UN Convention Against Corruption;
  • UN Convention Against Transnational Organized Crime;
  • Council of Europe Criminal Law Convention on Corruption;
  • Council of Europe Civil Law Convention on Corruption; and
  • Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism.

3. Are there local anti-corruption laws in your country focusing on corporations, not individuals? If yes, what sanctions can be imposed?

No. According to Article 20 of Turkish Criminal Law ("TCL"), criminal liability is only for individuals. However, security measures regulated in Article 60 of the TCL can be applied to corporations.

4. Can companies be held liable for acts of corruption under civil or administrative law?

Yes. Companies can be held liable for acts of corruption under civil and administrative law. Article 43/A of the Misdemeanors Law states that if bribery is committed for the benefit of a legal entity, the legal entity is also liable with an administrative fine.

6. Is corruption of individuals punishable?


7. Are facilitation payments allowed?


8. Is there a legal regulation/maximum limit for accepting or giving gifts, invitations, etc.?

No. The Law on Civil Servants and Regulation on Ethical Behaviour Principles of Public Officers and Application Procedures and Principles ("Regulation") introduces a prohibition without a maximum limit to accept gifts or to obtain any kind of benefit in connection with their duties. Article 15 of the Regulation specifies the type of gifts and benefits excluded from this prohibition.

9. Are bribes to foreign government officials prohibited?


10. Does your legislation have any extraterritorial reach?


11. Is it possible to confiscate assets from the company?

Yes. According to Article 60 of Turkish Criminal Law, confiscating assets from a company is possible when a crime is committed for the company's benefit.

12. Does your legislation rely on deferred prosecution or non-prosecution agreements or any other type of non-trial resolution for corruption?


13. Can a company be liable for the acts of its intermediaries or third parties?

A company cannot be held liable in criminal law, but security measures can be applied. Based on Article 60 of the TCL, the crime must be committed through the body or representatives of the company. "Representative" is not clearly defined in the TCL, but the doctrine states that these people should possess the capacity to act on behalf of the company.

15. Can a parent company be liable for the acts of its subsidiaries?

No, not for criminal liabilities.

14. Are there any affirmative defenses or exceptions for those accused of corruption acts?

No. Leniency procedures are available for bribery.

15. Does your jurisdiction require domestic entities to implement anti-corruption internal programs?


16. Is having a compliance program a defense or mitigating factor, while reviewing sanctions?

No, there is no legal regulation on this matter. However, such a compliance program may be effective in the judge's discretionary decision-making during the case trial.

17. Could the cooperation with the authorities or an internal investigation be a defense or mitigating factor?

Leniency provisions are available, and cooperation may have a mitigating effect at the discretion of the judge.

18. Is there any publicly available guideline issued by the authorities in charge of enforcing anti-corruption laws? For example, manuals on compliance programs, leniency agreements, etc. If so, please provide the link.



Hergüner Bilgen Özeke
Kayra Üçer, kucer@herguner.av.tr