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Turkey is a signatory to the OECD Anti-Bribery Convention.  See here for more information on Turkey’s implementation of the OECD Convention.

However, in Transparency International’s recent Progress Report on enforcement of the OECD Convention (here), Turkey was one of 21 countries with “little or no enforcement.”  Turkey was found to have “significant inadequacies in the legal framework for prohibiting foreign bribery” including “insufficient definition of the foreign bribery offense,” “lack of criminal liability for corporations,” and “inadequate sanctions in law and/or practice.”  Turkey was also found to have “significant inadequacies in the enforcement system to punish foreign bribery” including “inadequate resources,” and “lack of specialized training.”  Turkey was also found to have “inadequate criminal and corporate laws to hold parent companies responsible for bribery in foreign countries by subsidiaries, agents and other intermediaries.”

Turkey is making progress though.

The recent OECD Working Group on Bribery Annual Report (here) states as follows regarding Turkey.  “In March [2010], the Working Group found Turkey had made significant progress in its efforts to combat foreign bribery and had implemented all of the Working Group’s recommendations from its Phase 2 and Phase 2bis evaluations except for one on broadening the scope of company audits, which was partially implemented as a draft provision for this purpose was before Parliament and was expected to be adopted in late 2010 or early 2011. In its review of Turkey’s efforts to implement the Group’s recommendations, the Working Group identified several important improvements in Turkey’s legislative and institutional framework for combating foreign bribery, including: significant awareness-raising and training, including with the private sector; important legislative reforms, including the introduction of whistleblower protections for private- and public-sector employees; the express denial of tax deductions for bribe payments; the repeal of a defence for bribers who report their crime to law enforcement authorities; and, most importantly, the re-establishment of corporate liability for foreign bribery. Moreover, the Group noted the increased law enforcement activity in Turkey, where there are three ongoing investigations.”  The OECD’s Phase 3 Review of Turkey is to occur in March 2014.


Thanks for reading, safe travels, and may your turkey be golden brown!

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