“The bank has classified me as a politically exposed person” — a phrase entrepreneurs usually run into without warning: when opening an account, making a transfer or during a routine review of their client file. The status is not an accusation and does not bar the bank from serving you, but it changes the scope of the checks. Here is who falls under it according to Turkish rules and where the bank gets its information.
Who counts as a politically exposed person
The Turkish rules are set out in MASAK General Communiqué No. 21, published in November 2022, and in the agency's implementation guidance. The definition covers persons entrusted, by election or appointment, with a prominent public function in Türkiye or abroad, as well as board members, senior managers and holders of equivalent positions in international organisations. The three categories — domestic, foreign and international-organisation PEPs — differ in risk level: foreign PEPs are treated as higher risk by default.
The key detail that is often misunderstood: the category is determined by the country that entrusted the function, not by citizenship or place of residence. Citizenship and residence affect the risk assessment, but not the category itself. A person living in Türkiye on a Turkish passport who holds office in another state is assessed as a foreign PEP.
Family and close associates — the case nobody expects
Enhanced measures apply not only to the office-holder but also to their spouse, first-degree relatives — parents and children — and close associates. The notion of a close associate is deliberately broad: the international standard on which the Turkish rules are based includes relatives beyond the first degree, engagement, business partnership and employment in a company — any social, cultural or economic tie indicating shared interests. For our readers this is the typical scenario: they hold no public office themselves, but come under enhanced scrutiny as a business partner or relative.
What exactly the bank does
- Determines whether the client or the beneficial owner is a politically exposed person;
- for foreign PEPs, obtains senior management approval to establish or continue the business relationship;
- takes reasonable measures to establish the source of funds and the source of wealth;
- conducts enhanced ongoing monitoring of the relationship and transactions.
For domestic PEPs and staff of international organisations the procedure is different: a risk assessment comes first, and if the risk is found to be low, the standard measures applied to any client are used. For beneficiaries of life insurance payouts, the check is carried out before the payout or at the latest when it is made.
Where the bank gets its information
There is no single official list of such persons. The bank gathers the information itself: from occupation and employer details obtained during identification, from open sources and media, and from commercial databases. This creates two practical problems. The first is false matches: someone with the same surname, or an inaccurate transliteration. The second is outdated data: occupation details must be kept current, and while the obligation to update the file lies with the bank, the initiative usually comes from the client.
The status does not end with the office
After leaving office, enhanced measures continue to apply for at least one year, and the exact period is set by a risk assessment. Factors include whether informal influence persists, whether the former position is connected to current activities, and whether the person still deals with the same matters. If the risk persists, the period is extended.
What to do if the status has been assigned
Challenging the status itself is usually pointless: it is a classification under the risk-based approach, not a sanction. What works better is building an explainable, documented picture of the source of funds, putting employment and ownership information in order, and clearing any false matches. The enhanced measures remain, but they stop being an obstacle to transactions.