Short answer: Turkey country risk depends on which list you mean. As of 6 November 2026 Türkiye is on neither FATF list (it left increased monitoring on 28 June 2024), is not on the EU's AML high-risk list and does not trigger the UK's mandatory enhanced due diligence rule, while it sits in category 5 on the OECD's 0 to 7 export credit scale and in Annex II of the EU's tax list. None of these decides whether a given counterparty is acceptable: that falls to your own compliance policy and regulator.
Compliance and procurement staff often get one question: is Turkey high risk? Several unrelated lists answer different versions of it, each on its own schedule. This guide gives Türkiye's status on each list with its date, then what it means for a payment or a contract.
It is general information and not legal advice. It makes no statement that Turkey is safe or unsafe to invest in, and it does not cover how to deal with any sanctioned party. FATF's site refused scripted requests on 5 and 6 November 2026 but opened in a normal browser, so the FATF facts below were read on FATF's own pages on 6 November 2026 and cross-checked with FinCEN and with Turkish official statements.
Turkey high risk country list: seven checks, seven answers
Türkiye is absent from the AML lists that trigger mandatory action, while two other lists with different purposes do include it.
| List | Purpose | Türkiye | Date of the list |
|---|---|---|---|
| FATF High-Risk Jurisdictions subject to a Call for Action | AML, terrorist and proliferation financing; countermeasures or enhanced due diligence | Not listed. The list names Iran, North Korea and Myanmar | 30 October 2026 |
| FATF Jurisdictions under Increased Monitoring | Countries working through an agreed action plan | Not listed; removed 28 June 2024 | 30 October 2026 |
| EU high-risk third countries (Delegated Regulation 2016/1675) | AML; EU obliged entities apply Article 18a measures | Not among the 26 listed | Commission page updated 9 January 2026, when amendments 2026/46 and 2026/83 were published |
| UK regulation 33 of the 2017 Money Laundering Regulations | Mandatory enhanced due diligence for a FATF call for action country | Not such a country | Wording in force from 30 June 2026 |
| EU tax list | Tax good governance, not AML | Annex II, not Annex I (the non-cooperative list) | 9 October 2026 |
| OECD country risk classification | Export credit premium rules, not AML | Category 5, previous 5, on a scale of 0 to 7 | Valid as of 16 October 2026 |
| FATF mutual evaluation | Peer review of laws and effectiveness | Report published; enhanced follow-up | 23 September 2026 |
Two other measures get quoted beside these. A sovereign rating is an opinion on repayment, covered in Turkey credit rating, and a CDS spread is a market price of credit protection, covered in Turkey CDS. Neither is an AML list.
Turkey high risk country FATF: grey list history and the 2026 report
Türkiye spent October 2021 to June 2024 on the grey list, left it, and received a new mutual evaluation report in September 2026 that places it in enhanced follow-up.
| Date | Step | Source |
|---|---|---|
| October 2021 | FATF identifies strategic deficiencies | FATF statement of June 2024 |
| 28 June 2024 | Removed from increased monitoring, with Jamaica | FATF statement of 28 June 2024; FinCEN release of 3 July 2024 |
| November 2025 | On-site visit for the new evaluation | FATF report page |
| 17 to 19 June 2026 | Plenary adopts the report | FATF plenary outcomes, 19 June 2026 |
| 23 September 2026 | Report published | MASAK statement; FATF report page |
| 30 October 2026 | Bulgaria, Côte d'Ivoire, the Democratic Republic of the Congo and Monaco removed from increased monitoring, none named as added; Türkiye on neither list | FATF statement; FinCEN release |
FATF's ratings table, read on 6 November 2026, gives Türkiye 15 compliant, 23 largely compliant and 2 partially compliant ratings on the 40 Recommendations; the partial ones are Recommendation 7 (proliferation financing sanctions) and 8 (non-profit organisations). On effectiveness, 3 of 11 Immediate Outcomes are rated substantial (IO.1 risk and coordination, IO.2 international cooperation, IO.6 financial intelligence) and 8 moderate, with none high or low. MASAK, Türkiye's financial intelligence unit, sums this up as compliance with 38 of 40 Recommendations.
Read two statements side by side, because they answer different questions:
- MASAK says FATF has recorded that there is no strategic deficiency and so no grey list risk. FATF's report page does not say this, and the report PDF refused scripted download, so we could not check the wording in the report.
- FATF's report page says Türkiye is placed in enhanced follow-up and will report back on progress, with a roadmap of Key Recommended Actions to complete within three years.
Enhanced follow-up is a reporting track after an evaluation, while increased monitoring is a public list with an action plan, so the first does not place a country on the second. FATF's page names areas for work, including money laundering prosecutions linked to high-risk offences, recovery of assets held abroad and accurate beneficial ownership data. It also says a regulatory framework for virtual asset service providers was still being implemented at the time of the visit. A compliance reader should use the report itself for these points.
Turkey national risk assessment: what the public summary says
Türkiye publishes a summary of its national risk assessment, not the full report, and the latest is dated 1 July 2025.
MASAK says the report was first adopted in 2023 and updated in 2025; FATF's 2019 evaluation page (opens in a new tab) says Türkiye completed a national risk assessment in 2018. The summary says the update draws mainly on 2021 to 2024 data and was approved by the Minister of Treasury and Finance on 27 June 2025. A separate 2025 summary covers proliferation financing. We did not find the full report on the pages checked.
| Level | Money laundering threats | Sectors |
|---|---|---|
| High | Fraud | Banks; crypto-asset service providers |
| Medium-high | Illegal betting and gambling; drug trafficking; theft and robbery | Payment and e-money institutions; jewellers; exchange offices; real estate agents |
| Medium | Smuggling; forgery; corruption; tax evasion; migrant smuggling and human trafficking | Car dealers; brokerage firms; factoring; accountants |
| Medium-low | Usury | Precious metal intermediaries; insurance; cargo; financing and leasing; lawyers; portfolio managers; lottery and betting; independent auditors |
| Low | Investment partnerships; asset management; savings finance; notaries |
These are Türkiye's own domestic ratings of its sectors, so they are not comparable across countries. The summary also rates terrorist financing threats, which this guide does not reproduce. Software companies are not among the 23 sectors, so the document gives no sector level for a software vendor. E-commerce intermediary service providers, made obliged parties on 25 December 2024, were assessed separately, at a minimum of medium-low. Crypto rules are in is crypto legal in Turkey.
Turkey high risk country AML: what each list requires of you
Each list binds only the people its own law covers, and your own regulator and compliance policy decide whether enhanced due diligence applies to a Turkish counterparty.
| You are | Rule | Effect of Türkiye's status | What still applies |
|---|---|---|---|
| EU obliged entity | Directive 2015/849 Article 18a and the EU list | No list-based measures for Türkiye | Your risk assessment and national law |
| UK relevant person | Regulation 33(1)(b) | Not triggered, since the test is now a FATF call for action country | Regulation 33(1)(a) and (g), and the risk factors in 33(6), which include credible reports such as FATF evaluations |
| US financial institution | FinCEN statements | FinCEN said on 3 July 2024 that institutions should weigh FATF's delisting decisions and reasons when assessing risk | Your own AML program |
| Business with no AML duties of its own | No list applies directly | Your bank or auditor may still ask questions | Sanctions law and contract terms |
The UK change is worth noting. Until 29 June 2026, regulation 33(1)(b) applied to a high-risk third country, defined as a country on either FATF list, increased monitoring included; from 30 June 2026, S.I. 2026/621 limits it to FATF's call for action list. An internal policy written before that date may need updating.
Paying or hiring a Turkish firm: a checklist
- Record the list status above with the date you checked it, in your own file.
- Identify the company: tax ID, trade registry entry and who owns it. See Turkey VAT number check and how to verify a software company in Turkey.
- Screen the company and its owners against the sanctions lists your own law applies. That is a separate exercise from every list on this page.
- Match the sector: payments or crypto work reads differently from ordinary software work, as the table above shows.
- Keep contract, invoice and payment routes consistent, because your bank may ask for them. What a contract should require is in outsource software development compliance; bank onboarding is in bank account in Turkey.
For a real transaction, take advice from your compliance officer or a lawyer in your own jurisdiction.
Turkey country risk rating: OECD category 5 and what it measures
The OECD category is an export credit tool: Türkiye was in category 5 both before and after the list valid from 16 October 2026, on a scale of 0 to 7.
The list is titled Country Risk Classifications of the Participants to the Arrangement on Officially Supported Export Credits. The Arrangement sorts countries into eight categories and uses them, with the time at risk and the buyer's risk, to derive minimum premium rates for officially supported export credits. Under Article 23 the sovereign's own risk is also assessed, to find sovereigns riskier than the country itself; note 9, which refers to this, appears on some rows of the list but not on Türkiye's.
So it measures country credit risk as Article 22 of the Arrangement defines it: the likelihood that a country services its external debts, including transfer stoppages and force majeure. It does not assess money laundering, a company or the safety of an investment, and no AML rule above refers to it. A category number also gives no reason for a change; the list shows only previous and current values.
Hypothetical example. An exporter's insurer quotes a premium for a Turkish buyer and cites the category. A compliance officer sees a 5 and asks whether the buyer is high risk. These are separate questions: the first concerns the premium floor for export credit, and the second needs the counterparty checks in the section above.
How to keep these country risk checks current
Date every check, because each list moves on its own schedule and old screenshots mislead.
| List | When it changes | Where to look |
|---|---|---|
| FATF lists | After each FATF plenary, three a year; the latest ended on 30 October 2026 | FATF's lists page; FinCEN summarizes the changes (on 30 October 2026, the same day) |
| EU AML list | By delegated regulation, in force later than publication | Commission's list page, which shows entry-into-force dates |
| UK | Uses FATF's call for action list "as such list has effect from time to time" (regulation 33(3)(a)) | Legislation.gov.uk and FATF |
| EU tax list | Twice a year, per the Commission | Commission's and Council's pages |
| OECD | Reviewed at least annually (Article 22(d) of the Arrangement); the validity date is printed on the list | OECD's country risk PDF |
| National risk assessment | No fixed date found | Treasury's and MASAK's risk assessment pages |
If you automate this, plan for failure. FATF's site returned HTTP 403 to scripted requests on 5 and 6 November 2026 while a browser loaded the same pages, so a script needs a fallback and a human check. An empty result must never read as not listed.
Frequently asked questions
Is Turkey on the FATF grey list?
No. FATF removed Türkiye from increased monitoring on 28 June 2024, and it is not on the list of 30 October 2026. A new mutual evaluation report published on 23 September 2026 places it in enhanced follow-up, which is a reporting track and not the grey list.
Is Turkey on the EU high-risk third country list?
No. It is not among the 26 jurisdictions on the Commission's page as read on 6 November 2026. That list is separate from the EU's tax list, where Türkiye is in Annex II.
Is Turkey on the EU tax blacklist?
No. The blacklist is Annex I, which named eight jurisdictions after the revision of 9 October 2026. Türkiye is in Annex II, which the Commission's note on that revision calls the list of cooperative jurisdictions, reflecting ongoing cooperation.
What is Turkey's OECD country risk category?
Category 5 on a scale of 0 to 7, unchanged from the previous list, valid as of 16 October 2026. It feeds export credit premium rules and is not an AML rating.
Does Turkey publish a national risk assessment?
Yes, as a summary. The latest money laundering and terrorist financing summary is dated 1 July 2025, and a separate summary covers proliferation financing. We did not find the full report on the pages checked.
Do I need enhanced due diligence for a Turkish supplier?
No list above requires it for Türkiye as such, as of 6 November 2026. Your own risk assessment, your regulator and your bank may still call for it in a particular case, so ask your compliance officer.
Sources
- FATF: Jurisdictions under Increased Monitoring, 30 October 2026 (read in a browser on 6 November 2026; scripted requests get HTTP 403) (opens in a new tab)
- FATF: Jurisdictions under Increased Monitoring, 28 June 2024 (opens in a new tab)
- FATF: Mutual Evaluation Report of Türkiye 2026, publication page with ratings, 23 September 2026 (opens in a new tab)
- FATF: Outcomes of the Plenary of 17 to 19 June 2026 (adoption of Türkiye's report) (opens in a new tab)
- FinCEN: FATF identifies jurisdictions with deficiencies, release of 30 October 2026 (opens in a new tab)
- FinCEN: FATF identifies jurisdictions with deficiencies, release of 3 July 2024 (opens in a new tab)
- MASAK: Statement on publication of the FATF mutual evaluation report, 23 September 2026 (Turkish) (opens in a new tab)
- MASAK: National risk assessment page (Turkish) (opens in a new tab)
- Ministry of Treasury and Finance: ML/TF/PF National Risk Assessment page (opens in a new tab)
- Ministry of Treasury and Finance (MASAK): National Risk Assessment summary in English, 1 July 2025 (opens in a new tab)
- European Commission: EU list of high-risk third countries (opens in a new tab)
- European Commission: Council updates the EU list of non-cooperative tax jurisdictions, 9 October 2026 (opens in a new tab)
- UK legislation: Money Laundering Regulations 2017, regulation 33, as amended by S.I. 2026/621 from 30 June 2026 (opens in a new tab)
- OECD: Country Risk Classifications, valid as of 16 October 2026 (opens in a new tab)
- OECD: Arrangement on Officially Supported Export Credits, July 2023 version (Articles 22 and 23) (opens in a new tab)
This guide is general information, not investment, legal or tax advice. Amounts, rates and rules in Turkey change often: check the date given for each figure and the official source before you rely on it, and ask a licensed adviser about your own situation. Sources, checks and corrections: see the editorial policy.