If you are intending to raise Country Risk on Turkey, due to its increasingly close relationship with Russia, and therefore the raised risk of sanctions evasion activity through Turkey, you might want to scale that back to a point where the risk is highest. Five major Turkish banks have now agreed to accept the Russian Mir payments system, which is supposed to facilitate tourism, but could be used artfully and cleverly by experienced money launderers for sanctions evasion. For some reason, all the articles on the subject failed to name the specific banks, so we will now pass that information on to you here.
Our suggestion: make these banks high-risk, allowing your international clients to trade with Turkey, whilst protecting your bank from sanctions evasion.
The banks named are:
1. HALKBANK
2. ISBANK
3. ZIRAAT BANK
4. VIKIFBANK
5. DENIZBANK
In any event, should you see ANY increased or unusual traffic from Turkey, involving large purchases of Western goods, institute enhanced due diligence procedures forthwith, and notify bank counsel accordingly.
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