i-law

Money Laundering Bulletin

A well-roasted Turkey

The location of the opening sequence of a Bond film is traditionally a good indication of troubled jurisdictions, writes Sue Grossey. In “Dr No” (1962), Sean Connery tracked baddies and Ursula Andress around Jamaica. Roger Moore tackled space in “Moonraker” (1979). In “Die Another Day” (2002), Timothy Dalton surfed onto a beach in North Korea. Pierce Brosnan in “GoldenEye” (1995) infiltrated a Russian chemical weapons facility. And in “Skyfall” (2012), Daniel Craig rides a motorbike over the rooftops of the Grand Bazaar in Istanbul. Yes: Turkey has been promoted to the Bond list of dodgy countries.

Perhaps the Broccoli influence is greater than we thought, as at the end of its plenary meeting in Paris in mid-October 2012 [1], the Financial Action Task Force (FATF) issued one of its sternest warnings yet – to Turkey. This cannot have come as a surprise to Ankara, as Turkey has been working its way steadily up the FATF’s list of “jurisdictions with strategic anti-money laundering (AML/CFT) deficiencies” since its first appearance on that list in February 2010. Listing the jurisdiction for the first time [2], FATF said of Turkey that “[it] has demonstrated progress in improving its AML/CFT regime; however, the FATF has determined that certain strategic AML/ CFT deficiencies remain. Turkey has made a high-level political commitment to work with the FATF to address these deficiencies, including by: (1) adequately criminalising terrorist financing (Special Recommendation II); and (2) implementing an adequate legal framework for identifying and freezing terrorist assets (Special Recommendation III).” From the outset, then, it was clear that FATF’s beef with Turkey (I do apologise – that will keep happening) was around CFT rather than AML.

The rest of this document is only available to i-law.com online subscribers.

If you are already a subscriber, click Log In button.

Copyright © 2025 Maritime Insights & Intelligence Limited. Maritime Insights & Intelligence Limited is registered in England and Wales with company number 13831625 and address 5th Floor, 10 St Bride Street, London, EC4A 4AD, United Kingdom. Lloyd's List Intelligence is a trading name of Maritime Insights & Intelligence Limited.

Lloyd's is the registered trademark of the Society Incorporated by the Lloyd's Act 1871 by the name of Lloyd's.