Foreign Company Accused of Bribery in Turkey: Criminal Investigation and Compliance Guide 2026

Foreign company facing a bribery investigation in Turkey? Learn about criminal liability, Turkish Criminal Code Article 252, directors and employees, intermediaries, corporate security measures, searches, financial evidence, internal investigations and anti-bribery compliance in 2026.

A foreign-owned company operating in Turkey may face a serious criminal and compliance crisis when allegations arise that a director, employee, consultant, distributor, customs intermediary, procurement representative or other third party offered or provided an improper benefit connected with a public official’s duties.

The allegation may emerge from a whistleblower complaint, internal audit, suspicious payment, procurement investigation, intermediary invoice, accounting review, banking transaction, public-sector tender or investigation involving another company.

Turkish Criminal Code Article 252 establishes the central bribery offence. The statutory framework covers both the person providing the improper benefit and the public official receiving it, and also contains rules concerning intermediaries and certain foreign or international public officials.

For a foreign company, the immediate objective should not be simply to identify a suspicious payment and dismiss the employee involved. A defensible response generally requires:

Preserve evidence → Stop questionable payments → Identify the exact allegation → Protect accounting and digital records → Trace the transaction → Separate individual conduct from corporate conduct → Conduct a privileged and structured internal investigation where appropriate → Assess Turkish criminal exposure → Coordinate cross-border issues → Remediate compliance weaknesses.

What Constitutes Bribery Under Turkish Criminal Law?

Article 252 of the Turkish Criminal Code is the primary bribery provision.

At its core, the provision concerns providing an improper benefit to a public official, or another person indicated by that official, in order for the official to perform or refrain from performing something connected with official duties. The statutory framework criminalizes both sides of the bribery arrangement.

For foreign companies, this means an investigation may focus on questions such as:

• What benefit was offered or provided?
• Who authorized it?
• Who received or was intended to receive it?
• Was a public official involved?
• What official act or omission was sought?
• Was an intermediary used?
• Was there an agreement concerning the improper benefit?
• Did company management know?
• How was the payment recorded?
• Did the company obtain an economic or regulatory advantage?

The answers should be established through evidence rather than assumptions based solely on a suspicious accounting description.

Does the Bribe Have to Be Cash?

A bribery investigation should not be approached as though only an envelope of cash can create risk.

The relevant issue is whether an improper benefit was allegedly provided or agreed upon in connection with official duties.

A suspicious benefit may potentially take different forms, depending on the facts, such as:

• Money
• Gifts
• Travel
• Accommodation
• Valuable services
• Benefits directed to another person
• Artificial consultancy arrangements
• Other economic advantages

The transaction must be examined in context.

Example: Foreign Company Seeking a Government Approval

Assume a foreign-owned company needs a regulatory approval.

A local consultant tells the company’s regional director:

“I can make sure the approval is issued quickly, but I need an additional €100,000 special payment.”

The company transfers €100,000 to the consultant.

The consultant later transfers part of the money to another person connected with the approval process.

The investigation should not stop at:

Company → Consultant: €100,000.

Instead reconstruct:

Company → Consultant → Subsequent recipient → Public official or connected person → Regulatory action.

The central questions include what company personnel knew, what the consultant represented, who authorized the payment, how it was documented and where the funds ultimately went.

Use of an Intermediary Does Not Automatically Eliminate Risk

Bribery allegations frequently involve third parties rather than direct company-to-official payments.

Potential intermediaries include:

• Consultants
• Agents
• Distributors
• Customs representatives
• Procurement advisers
• Local business partners
• Subcontractors
• Lobbying or government-relations consultants

Article 252 expressly addresses persons acting as intermediaries in transmitting a bribery offer, demand, agreement or benefit.

Accordingly, a company should not assume:

“We paid a consultant, not the official, so there cannot be a bribery problem.”

The actual payment chain and knowledge of the individuals involved must be investigated.

A Consultant’s Misconduct Does Not Automatically Make Every Company Executive Guilty

The opposite conclusion is equally dangerous.

Suppose a consultant independently makes an unlawful payment without the knowledge of company management.

That fact does not automatically establish the personal criminal responsibility of:

• Foreign shareholder
• CEO
• Country manager
• Board member
• CFO
• Compliance officer
• Parent-company director

Individual conduct must be examined separately.

The investigation should determine:

Who selected the intermediary?

Who approved the engagement?

Who approved payment?

What was the stated purpose?

Were warning signs communicated internally?

Who knew the ultimate destination of the money?

Company Liability and Individual Criminal Liability Must Be Distinguished

Turkish criminal law does not simply treat a legal entity and its directors as the same person.

However, bribery can still create serious consequences for a company.

Article 253 of the Turkish Criminal Code provides that legal-entity-specific security measures may be imposed on legal entities that obtain an unlawful benefit through commission of the bribery offence. Article 60 contains the general framework for legal-entity security measures, including confiscation and, in specified circumstances, cancellation of an authorization granted by a public institution.

Accordingly, the investigation should separately analyze:

Individual criminal responsibility

and

Consequences for the legal entity.

Foreign Ownership Does Not Create Automatic Liability

A foreign parent company or shareholder should not automatically be treated as criminally responsible merely because misconduct allegedly occurred within a Turkish subsidiary.

Relevant questions include:

• Who employed the suspected individual?
• Which entity signed the intermediary contract?
• Which entity made the payment?
• Which management team approved it?
• Who benefited?
• Did parent-company personnel participate?
• What information was reported to headquarters?
• What compliance controls existed?

Corporate-group structure matters.

Foreign Public Officials Can Also Be Relevant

Foreign companies should not assume Turkish bribery law concerns only Turkish public officials.

Article 252 contains provisions extending the bribery framework to specified foreign public officials and persons performing certain international public functions. Turkey is also a party to the OECD Anti-Bribery Convention.

The OECD continued its monitoring of Türkiye’s implementation of the Convention in 2026, publishing a Phase 4 follow-up report on 9 July 2026.

This makes cross-border anti-bribery compliance particularly important for multinational businesses.

Foreign Company Investigation: First 24 Hours

When a credible bribery allegation reaches management, the first day can materially affect the investigation.

The company should consider immediately:

1. Preserving relevant evidence.
2. Suspending questionable payments where legally appropriate.
3. Identifying the people potentially involved.
4. Preserving email and messaging accounts.
5. Preserving accounting and ERP records.
6. Securing intermediary contracts.
7. Preserving banking documentation.
8. Identifying relevant government interactions.
9. Preventing routine deletion of potentially relevant records.
10. Obtaining Turkish criminal-law advice before making irreversible decisions.

Do not destroy evidence in an attempt to “clean up” the company.

Never Delete Emails After Learning of an Investigation

Potentially relevant evidence may include:

• Corporate email
• WhatsApp communications
• Internal messaging platforms
• Accounting records
• Expense reports
• Bank instructions
• Invoices
• Contracts
• Calendar entries
• Meeting notes
• Procurement records

Deletion after an investigation becomes foreseeable can create additional evidentiary problems and seriously damage the credibility of the company’s defense.

Preserve Data Before Suspending or Dismissing Employees

A company may decide that an employee should be suspended or dismissed, but evidence preservation should be considered first.

Before access is terminated, preserve lawfully accessible:

• Corporate mailbox
• Company laptop
• Corporate phone data
• Shared-drive files
• Expense records
• ERP activity
• Procurement approvals

Do not instruct employees to delete or “clean” their devices.

Conduct a Transaction-by-Transaction Review

A bribery investigation becomes much easier to understand when suspicious transactions are placed into a table.

Date	Payment	Recipient	Stated Purpose	Approver	Government Connection
10.03.2026	€25,000	Consultant A	Advisory fee	Manager X	Licence process
28.03.2026	€40,000	Consultant A	Success fee	Manager X	Licence process
04.04.2026	€15,000	Company B	Expenses	CFO Y	Under review

Then examine each payment individually.

Consultancy Fees Are a Major Risk Area

A legitimate consultancy arrangement may involve substantial fees without any criminal conduct.

The important questions are:

• Was there a genuine service?
• Was the consultant qualified?
• Was the fee commercially reasonable?
• Were deliverables produced?
• Was the consultant selected through normal procedures?
• Was payment made to the contracting party?
• Was the consultant connected with a public official?
• Was there an unusual success fee?
• Was cash requested?

A consultancy agreement alone does not prove legitimacy.

Fake Consultancy Agreements

An agreement may be created to make a suspicious payment appear legitimate.

Warning signs can include:

“Government facilitation services”

“Special administrative expenses”

“Confidential success payment”

or vague invoices without identifiable deliverables.

But unusual language is a risk indicator, not automatic proof of bribery.

The underlying facts must still be established.

Success Fees

Success fees deserve careful review where payment is directly linked to:

• Government licence
• Public tender
• Customs release
• Tax decision
• Regulatory approval
• Inspection result

A success fee is not automatically a bribe.

However, the company should understand exactly what lawful service generated the fee.

Gifts and Hospitality

Foreign companies should maintain clear controls around gifts and hospitality involving public officials.

Review:

• Recipient
• Value
• Frequency
• Business purpose
• Timing
• Approval
• Applicable internal policy
• Connection with pending official action

A lavish benefit immediately before a critical public decision presents a different risk profile from ordinary, appropriately controlled business hospitality.

Travel Expenses for Public Officials

Where a company pays travel or accommodation expenses involving a public official, examine:

• Why travel was necessary
• Who attended
• Destination
• Duration
• Hotel category
• Family members
• Entertainment
• Business agenda
• Internal approval

Compliance review should focus on substance rather than the expense label.

Charitable Donations

A charitable contribution can create compliance concerns if it is allegedly used to benefit a public official indirectly.

Questions include:

Who requested the donation?

Who controls the recipient organization?

Was government action pending?

Did the company conduct due diligence?

Was the donation properly recorded?

Again, a charitable donation is not inherently unlawful.

Sponsorships

Sponsorships should also be documented carefully where there is government interaction.

Preserve:

• Sponsorship agreement
• Recipient ownership
• Event information
• Deliverables
• Payment records
• Internal approvals

Public Procurement Investigations

Foreign companies participating in public procurement should maintain particularly strong documentation concerning:

• Tender communications
• Agents
• Bid preparation
• Pricing
• Gifts
• Hospitality
• Competitor contacts
• Consultant payments
• Government contacts

If a bribery allegation arises, reconstruct the procurement chronology before drawing conclusions.

Customs-Related Bribery Allegations

A foreign company may face an allegation that money was paid to accelerate:

• Customs clearance
• Inspection
• Release of goods
• Classification decision
• Administrative process

The company should determine whether the payment was:

Official fee

or

Payment to an intermediary

or

Alleged unofficial payment to a public official.

Do not describe every payment associated with customs as a bribe without establishing the recipient and purpose.

Regulatory Approvals

Energy, pharmaceutical, construction, mining, telecommunications and other regulated sectors can create heightened interaction with public institutions.

The compliance file should document:

Application → Official fee → Consultant → Government meeting → Decision.

Unexplained payments appearing between critical stages should be reviewed.

Accounting Evidence

Bribery investigations frequently depend heavily on how transactions were recorded.

Search for entries such as:

• Consultancy
• Commission
• Marketing
• Representation
• Travel
• Miscellaneous expenses
• Cash advance
• Success fee

The accounting label is not conclusive.

The investigation must identify the actual transaction.

Cash Payments

Cash can create substantial evidentiary difficulty.

For each withdrawal, determine:

Who requested it?

Who withdrew it?

Who received it?

What supporting documents exist?

How was it accounted for?

Do not assume that a cash withdrawal itself proves bribery.

Round-Number Payments

Payments such as €50,000 or €100,000 may attract attention, but the amount alone proves nothing.

Analyze:

Contract → Invoice → Approval → Payment → Service → Recipient → Subsequent movement.

Personal Bank Accounts

Payments involving personal accounts can create additional questions.

Example:

Foreign company → Consultant’s personal account → Third party → Public-official-related recipient.

Preserve the company’s payment instructions and investigate why a personal account was used.

Bank Records Can Also Exonerate

Financial evidence is not only prosecution evidence.

Suppose an allegation claims:

“The company paid €200,000 to an official.”

But banking records show:

Company → Genuine engineering supplier → Equipment purchase → Delivery.

The banking and commercial trail may materially undermine the allegation.

Search and Seizure at Company Premises

If Turkish authorities search company premises, management should not physically obstruct the search.

The company should document:

• Authority conducting the search
• Legal documentation presented
• Time search began
• Areas searched
• Documents taken
• Devices taken
• Copies made
• Inventory or record of seized material
• Time search ended

Obtain legal advice immediately.

Seized Computers and Phones

A bribery investigation may involve company:

• Laptops
• Phones
• Servers
• Drives
• Accounting systems

Do not remotely wipe or alter seized or potentially relevant devices.

At the same time, the company should preserve its lawful business-continuity copies and document who used each device.

A physical device is not automatically evidence that every file on it was created or known by the person to whom the device was assigned.

Emails Containing Code Words

Investigators may focus on expressions such as:

“special payment”

“government fee”

“VIP expense”

“facilitation”

“commission”

Context matters.

Preserve the complete email thread rather than attempting to explain one isolated phrase.

Foreign-Language Communications

Multinational companies often communicate in English, German, French, Arabic or other languages.

Preserve original-language material.

Translation should accompany, not replace, the original evidence.

A poor translation can materially distort the meaning of a compliance communication.

Interview Employees Carefully

Internal interviews may be necessary.

Before interviewing, determine:

• Purpose
• Interviewer
• Legal privilege considerations
• Relevant documents
• Whether the employee is individually exposed
• Whether external counsel should participate

Do not coach employees to give a predetermined account.

The purpose of an internal investigation is to determine what happened.

Avoid Group Interviews

Interviewing several potentially involved employees together can contaminate evidence.

Individual interviews generally provide a clearer record of:

Who knew what, and when?

Do Not Promise Employees Immunity

A private company cannot guarantee how public prosecutors will exercise their statutory powers.

Avoid promises that cannot legally be delivered.

Individualize Responsibility

Prepare a responsibility matrix.

Person	Role	Consultant Selection	Payment Approval	Government Contact	Evidence of Knowledge
CEO	Executive	No	Final approval	No	Under review
Country Manager	Operations	Yes	Requested	Yes	Emails
CFO	Finance	No	Processed	No	Invoice
Consultant	Third party	—	Recipient	Yes	Messages

This prevents an investigation from becoming an unsupported accusation against every senior executive.

Board Members Are Not Automatically Guilty

Board membership alone does not prove participation in bribery.

Determine:

• Whether the board knew of the payment
• What information it received
• Whether it approved the transaction
• Whether approval was routine or specific
• Whether warning signs were disclosed

CEO Liability Is Not Automatic

A CEO may have overall managerial responsibility without knowing every individual transaction.

Conversely, a CEO who personally directs a suspicious payment presents a materially different factual situation.

Title alone should never replace evidence.

CFO and Finance Personnel

Finance personnel may process a payment without knowing its alleged unlawful purpose.

Relevant questions include:

• What documents did finance receive?
• Was the invoice approved?
• Were compliance warnings raised?
• Was finance instructed to bypass controls?
• Was the payment description changed?

Compliance Officer

The discovery of misconduct does not automatically establish failure by the compliance officer.

Examine whether:

• Policy existed
• Training occurred
• Red flags were reported
• Management overrode controls
• Compliance advice was ignored
• The transaction was concealed from compliance

Whistleblower Complaint

Treat credible whistleblower allegations seriously.

Preserve:

• Original complaint
• Attachments
• Date received
• Persons notified
• Response actions

Do not retaliate against a whistleblower merely because an allegation creates difficulty for management.

Anonymous Complaint

An anonymous allegation does not prove bribery.

But it should not automatically be ignored.

Test the allegations against objective:

• Banking
• Accounting
• Email
• Procurement
• Corporate
• Government-interaction records

Suspicious Transaction Reporting and MASAK

For entities subject to Turkey’s anti-money-laundering reporting framework, suspicious-transaction obligations may become relevant depending on the entity and circumstances. MASAK states that obliged parties must report suspicious transactions without a monetary threshold and that applicable internal reporting procedures should be documented.

MASAK updated its sectoral suspicious-transaction reporting guides in September 2025, taking into account sectoral risks and the updated 2025 National Risk Assessment. Those materials remain relevant to compliance programs in 2026.

Not every commercial company is subject to identical MASAK obligations, so the company’s actual status under the applicable rules must be determined.

Bribery and Money-Laundering Risk Are Not Identical

A bribery allegation does not automatically prove money laundering.

If investigators allege that criminal proceeds were subsequently transferred, concealed or converted, additional analysis may become necessary.

Keep separate:

Underlying alleged bribery

from

Subsequent movement or concealment of alleged criminal proceeds.

Cross-Border Investigations

A multinational bribery investigation may involve:

Turkey → Foreign parent company → Overseas intermediary → Foreign bank → Public official.

Turkish authorities may use international judicial cooperation mechanisms to obtain evidence abroad where legal requirements are satisfied.

The Ministry of Justice identifies international cooperation mechanisms for obtaining banking records, accounting documents, company files and commercial records, as well as tracing assets and carrying out search or seizure requests. Turkey’s international criminal cooperation framework is also governed by Law No. 6706.

Parallel Foreign Investigations

A multinational company should consider whether the same conduct may attract attention in other jurisdictions.

The legal team should coordinate:

• Document preservation
• Employee interviews
• Internal reports
• Regulatory disclosures
• Privilege questions
• Public statements

An explanation prepared exclusively for one jurisdiction can create problems elsewhere if cross-border consequences are ignored.

Self-Reporting Requires Careful Legal Analysis

Do not automatically assume:

“If we report immediately, nobody can be prosecuted.”

Article 254 contains an effective-remorse framework for bribery, but its operation is highly fact-specific and includes an express limitation concerning persons who bribe foreign public officials.

Whether, when and how to approach authorities should therefore be evaluated under the exact facts before irreversible steps are taken.

Never Fabricate an Internal Investigation

Do not:

• Backdate compliance approvals
• Create fake due-diligence files
• Rewrite old invoices
• Manufacture employee training records
• Delete problematic emails
• Create fictitious consultancy deliverables

Evidence manipulation can seriously worsen the company’s position.

Preserve Exculpatory Evidence

Do not focus exclusively on suspicious material.

Preserve evidence showing legitimate conduct, including:

• Genuine consultant deliverables
• Competitive procurement
• Market-rate fees
• Government fee schedules
• Internal compliance approvals
• Legal advice
• Due-diligence reports
• Rejected payment requests
• Employee objections
• Compliance escalation

A balanced internal investigation should search for facts, not merely evidence supporting the accusation.

2026 Anti-Bribery Compliance Program for Foreign Companies in Turkey

An effective compliance system should be risk-based rather than a policy document that nobody uses.

Key components include:

1. Anti-Bribery Policy

Clearly prohibit improper benefits connected with public duties.

2. Third-Party Due Diligence

Screen consultants, agents, distributors and other intermediaries before engagement.

3. Government-Interaction Controls

Maintain records of significant meetings and interactions with public authorities.

4. Payment Controls

Require documented business purpose and appropriate approval.

5. Gifts and Hospitality Rules

Set clear approval and documentation requirements.

6. Cash Controls

Restrict and monitor significant cash transactions.

7. Accounting Accuracy

Require truthful transaction descriptions and supporting documents.

8. Whistleblower Channel

Provide a credible mechanism for reporting concerns.

9. Training

Train employees exposed to government and third-party risk.

10. Investigation Protocol

Establish who will respond when allegations arise.

Third-Party Due Diligence Checklist

Before hiring a government-facing intermediary, examine:

• Corporate existence
• Ownership
• Management
• Qualifications
• Relevant experience
• Public-official relationships
• Bank-account ownership
• Scope of services
• Fee structure
• Subcontractors
• Reputation
• Conflicts of interest

Enhanced review may be appropriate where risk indicators exist.

High-Risk Intermediary Warning Signs

Examples include:

• No relevant experience
• Unusually high commission
• Cash request
• Offshore payment request without clear commercial reason
• Payment to unrelated third party
• Refusal to disclose ownership
• Vague service description
• Claims of special government influence
• Request to hide the payment description
• No identifiable deliverables

A red flag does not automatically establish criminal conduct. It means additional verification may be appropriate.

Compliance Clauses in Contracts

Government-facing third-party agreements can include provisions concerning:

• Anti-bribery obligations
• Accurate records
• Subcontracting
• Audit rights
• Compliance certifications
• Termination rights
• Reporting obligations

Contract language alone, however, does not replace actual monitoring.

2026 Current Developments

Turkey’s anti-bribery framework continues in 2026 to operate within both domestic criminal law and the international anti-foreign-bribery framework. The OECD published its Phase 4 follow-up report on Türkiye on 9 July 2026, reflecting continuing international monitoring of enforcement and implementation of the OECD Anti-Bribery Convention.

For corporate compliance, MASAK’s updated suspicious-transaction reporting guidance issued in September 2025 also remains relevant in 2026 for entities that fall within the applicable reporting regime.

Foreign companies should therefore treat anti-bribery compliance as an active governance function rather than a one-time policy exercise.

20 Immediate Steps When a Foreign Company Is Accused of Bribery in Turkey

1. Identify the exact allegation.
2. Preserve relevant documents.
3. Stop routine destruction of relevant data.
4. Preserve employee email accounts.
5. Preserve corporate devices where appropriate.
6. Identify every suspicious payment.
7. Identify all intermediaries.
8. Trace each payment.
9. Preserve contracts and invoices.
10. Preserve government communications.
11. Identify payment approvers.
12. Build an individual responsibility matrix.
13. Preserve exculpatory evidence.
14. Review third-party due diligence.
15. Review gifts and hospitality.
16. Assess cross-border exposure.
17. Do not fabricate or backdate records.
18. Obtain Turkish criminal-law advice.
19. Determine whether an internal investigation is appropriate.
20. Prepare remediation based on verified findings.

Frequently Asked Questions

1. Can a foreign company be investigated for bribery in Turkey?

Yes. Conduct involving a foreign-owned company can trigger a Turkish criminal investigation where Turkish criminal jurisdiction and the applicable statutory elements are present. The individual conduct and consequences for the legal entity should be analyzed separately.

2. Is paying a consultant automatically bribery?

No. Legitimate consultants may be paid for genuine services. Risk increases where the consultant allegedly acts as a conduit for an improper benefit connected with a public official’s duties.

3. Can a company director be convicted merely because they approved the payment?

Approval is relevant evidence but does not by itself answer every element of criminal responsibility. The purpose of the payment, the director’s knowledge and the surrounding evidence must be examined.

4. Can an intermediary be criminally liable?

Potentially. Article 252 expressly addresses persons who act as intermediaries in transmitting bribery-related offers, demands, agreements or benefits.

5. Can bribery involving foreign public officials create Turkish criminal risk?

Potentially. Article 252 includes specified foreign and international public officials, and Turkey is a party to the OECD Anti-Bribery Convention.

6. Can the company itself face consequences?

Yes. Article 253 provides for legal-entity-specific security measures where a legal entity obtains an unlawful benefit through bribery, subject to the applicable statutory framework.

7. Should the company delete suspicious employee emails after dismissal?

No. Potentially relevant evidence should be preserved. Destroying or altering evidence can seriously complicate the investigation.

8. Should the company immediately report itself to the authorities?

That decision requires case-specific legal analysis. Article 254 contains an effective-remorse framework, but its conditions and exclusions must be examined carefully, particularly in cross-border foreign-public-official cases.

9. Can Turkish authorities obtain evidence from another country?

Potentially. International judicial cooperation can be used for specified evidence and asset-tracing requests, subject to applicable treaties, Law No. 6706 and the requested state’s law and procedures.

10. What is the most important defense step when a bribery investigation begins?

Preserve evidence and reconstruct the alleged transaction objectively. Determine who authorized the payment, why it was made, who received it, what services were actually performed, where the money went and what each individual knew.

Legal Assistance for Foreign Companies Facing Bribery Investigations in Turkey

Bribery allegations can expose a foreign company to simultaneous criminal, financial, regulatory, employment, corporate-governance and reputational risks. The investigation may also extend beyond Turkey where a foreign parent company, overseas bank account, international intermediary or foreign public official is involved.

Fırat Fesih Kaya Law Office provides legal assistance to foreign companies, foreign investors, executives and directors facing bribery allegations and corporate criminal investigations in Turkey.

Lawyer Fırat Fesih Kaya assists foreign clients with bribery investigations, internal investigations, evidence preservation, director and employee defense, intermediary-payment analysis, corporate records, banking evidence, government-interaction reviews, cross-border criminal matters and anti-bribery compliance programs.

Early intervention can be particularly important before employees leave the company, electronic evidence disappears, third-party relationships are terminated or statements are provided to investigating authorities without a complete understanding of the transaction.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower No:148, 06520 Balgat, Çankaya, Ankara, Turkey

This publication is provided for general informational purposes and does not constitute legal advice. Bribery investigations are highly fact-specific. Individual criminal responsibility, consequences for a company, protective measures, international jurisdiction and compliance obligations must be assessed under the current legislation and the evidence of the individual case.