Know-Your-Client (KYC) and AML
Before any engagement we complete a documented KYC check on every individual client and on the beneficial owners of every corporate client. We retain copies of passport, proof of address, occupation, and beneficial-ownership chain in line with the Turkish Financial Crimes Investigation Board (MASAK) requirements and international FATF standards. We do not accept anonymous engagements and we do not work with shell structures whose beneficial ownership we cannot verify.
Source of funds and source of wealth
For investment-related engagements (CBI, real estate, fund subscriptions, M&A), we verify the source of the funds being invested and, where relevant, the source of wealth that produced those funds. Acceptable documentation typically includes recent bank statements, tax returns, employment records, business sale agreements, inheritance documentation, or audited financial statements. We will tell you in advance exactly what we need so the verification step does not delay your transaction.
Politically Exposed Persons (PEPs)
We can advise PEPs and their close associates provided full and timely disclosure is made at engagement onboarding. Engagements involving PEPs are subject to enhanced due diligence, additional approval steps, and stricter documentation requirements. We reserve the right to decline or terminate any engagement where the disclosure obligations are not met.
Cross-border tax reporting — CRS / FATCA
Turkey participates in the OECD Common Reporting Standard (CRS) and exchanges financial-account information with more than 100 jurisdictions, including all major Greater China jurisdictions. Where we open Turkish bank accounts, real-estate holdings, or other financial accounts for foreign clients, the relevant Turkish institutions report the account to the client's tax residence. We brief every client on these obligations and recommend appropriate tax counsel where needed. We do not advise on schemes designed to evade CRS or FATCA reporting.
China nationality and dual-citizenship considerations
The People's Republic of China does not recognise dual nationality. Acquiring a foreign passport may be treated by Chinese authorities as termination of Chinese nationality, which can affect children's schooling, social insurance, and inheritance rights in China. We brief CBI clients on these considerations before any application and recommend specialist Chinese counsel for the China-side declarations.
Confidentiality
Information you share with us is held in strict confidence. We share client information only as required by Turkish law, applicable regulatory authorities, or with your written consent. Our internal team is bound by confidentiality undertakings and our IT systems are configured to limit access on a need-to-know basis.
Conflict of interest
We do not accept developer, broker, or third-party commissions. Our fees come exclusively from our clients. Where a potential conflict exists (for example, multiple clients interested in the same opportunity), we disclose the conflict in writing and seek consent before proceeding. We reserve the right to decline engagements where a material conflict cannot be managed.
Sanctions
We screen clients and counterparties against the United Nations Security Council Consolidated List, EU restrictive measures, and applicable US OFAC lists. We do not work with sanctioned individuals, sanctioned entities, or transactions that breach applicable sanctions regimes.
Concerns or complaints
If you have a concern about our compliance practices, an engagement, or the conduct of a team member, please write to us at compliance@turchinagroup.com. We acknowledge concerns within one business day and respond substantively within ten business days.
This page outlines our internal compliance practice; it does not create a contractual obligation independent of an executed engagement letter. The detailed obligations of each engagement are set out in the engagement letter signed by you and us.