2026 Türkiye Capital Markets Fund Crisis and Manipulation Investigations

2026 Türkiye Sermaye Piyasası Fon Krizi ve Manipülasyon Soruşturmaları, following public disclosure in September 2026 of findings that certain investment funds had artificially inflated stock prices through manipulative means, constitutes a series of events affecting Borsa İstanbul and the fund market. During the process, the Capital Markets Board (CMB) decided to suspend and liquidate seven investment funds managed by portfolio management companies, the circuit breaker system at Borsa İstanbul was activated, and various measures were implemented by public institutions.

In addition, during the process, the Ministry of Justice and the Bakırköy Chief Public Prosecutor’s Office carried out investigations resulting in arrests and detentions; public institutions, ministries and related companies issued various statements regarding the matter.

According to the CMB’s announcement dated 18 September 2026, during the last quarter of 2025, certain funds managed by portfolio management companies (PMCs) were observed to cause price movements in shares with low actual trading volumes that could not be explained by the companies’ fundamental financial metrics and economic indicators.^【1】 The issue was brought to the agenda at the Financial Stability Committee (FSC) meeting chaired by Minister of Treasury and Finance Mehmet Şimşek on 2 December 2025, and the CMB was advised to consider possible macroprudential measures. Subsequently, a Working Group was established within the CMB on 3 December 2025.

On 18 December 2025, the CMB raised the minimum financial asset requirement for qualified investors from 1 million TL to 10 million TL. On 15 December 2025, opinions were sought from Borsa İstanbul AŞ and İstanbul Takas ve Saklama Bankası AŞ (Takasbank), and the revised draft was submitted to the Ministry of Treasury and Finance on 28 January 2026. Following the Ministry’s consultation with the sector on 11 February 2026, a notification was issued regarding the draft’s entry into force.^【2】

The draft was sent to the Turkish Capital Markets Association (TCMA) on 13 February 2026 to solicit sector feedback, and a request for opinion was made to the Central Registry Agency (CRA) on 18 February 2026. In response to modification requests from TCMA and Takasbank regarding TEFAS operations, a joint study on the platform’s clearing structure was prepared and submitted to the CMB. Following a change in the CMB Chairmanship in May 2026, work on the Guideline Draft continued.^【3】

On 17 June 2026, the CMB approved the TEFAS Implementation Principles, and Takasbank implemented the regulation on 20 July 2026. Additionally, pursuant to the CMB’s 23 July 2026 decision, the valuation of participation units of real estate investment funds (REIFs) and venture capital investment funds (VCIFs) traded on the exchange shifted from market price to net asset value as of 31 July 2026. The CMB explained that this change aimed to prevent certain funds from using fictitious calculations based on net asset value.^【4】

In August 2026, the final version of the Guideline Draft was determined through meetings with Borsa İstanbul, Takasbank and CRA, and feedback gathered from public institutions, sector representatives and investors.^【5】 The amendments to the Investment Funds Guideline were announced to the public on 28 August 2026. The CMB stated that the regulation aimed to prevent systemic risk to financial stability arising from unsecured borrowing among related parties in money market funds and free equity funds, and from abnormal price movements on the exchange. Transition periods were granted for compliance.^【6】

In the CMB’s 29 August 2026 announcement, it was stated that the Board’s decision dated 28 August 2026 had amended the Definitions section and several articles of the Guideline and added new articles. The same announcement also specified that for 2027, the minimum capital requirements for portfolio management companies would be 500 million TL for fully authorized companies and 250 million TL for limited activity companies.^【7】

Under the regulation, restrictions were imposed on share sales conducted outside the exchange based on thresholds determined by actual trading ratios. When shares exceeding the established ratios are to be transferred via special orders, BİAŞ Wholesale Market or assignment/transfer methods, a share sale information form must be prepared and submitted for CMB approval. It was also clarified that sales conducted outside the exchange before 29 August 2026 would not be included in the calculation of sales ratios over the 12-month period.^【8】

Following a surge in redemption requests, certain funds of Pusula Portföy and Tera Portföy declared default and announced they were unable to make payments to investors.^【9】 Regarding the managers of the depreciating funds, Muhammed Yarız, Chairman of the Board of Pusula Portföy was detained on 15 September 2026.^【10】 The manager of Info Yatırım and Hedef Holding, Namık Kemal Gökalp, the Chairman of the Board of Destek Yatırım Bankası, Altunç Kumova, and the Deputy General Manager of Tera Holding, İbrahim Bekci, were placed under arrest.^【11】

On 16 September 2026, following a decline in the BIST 100 index exceeding 6 percent, Borsa İstanbul’s Index-Linked Circuit Breaker System (ILCBS) was activated. According to Borsa İstanbul’s announcement via KAP, at 16:04:32, all trading orders on the Equity Market, contracts based on shares and share indices on the Derivatives Market, and transactions on the Debt Instruments Market Share Repo Market were temporarily suspended.^【12】

On the equity market, single-price order collection was conducted at 16:14:32, matching at 16:19:32, and trading resumed from 16:24:32. Warrants, certificates, orders traded at weighted average prices, and contracts based on shares and share indices on the Derivatives Market, as well as transactions on the Share Repo Market, also resumed at 16:24:32.^【13】

On 17 September 2026, the CMB adopted new measures in line with developments on the Borsa İstanbul markets and to protect the rights and interests of investors.^【14】 Accordingly, it was decided to suspend all investment funds established by Tera Portföy Yönetimi AŞ, Pusula Portföy Yönetimi AŞ, Hedef Portföy Yönetimi AŞ, Atlas Portföy Yönetimi AŞ, A1 Portföy Yönetimi AŞ, Pardus Portföy Yönetimi AŞ and Bulls Portföy Yönetimi AŞ whose participation units are traded on TEFAS.^【15】

According to CMB Bulletin No. 2026/60, the decision was taken under Article 128/1-(a) of Law No. 6362 on the Capital Markets to ensure the proper functioning of capital markets and protect the rights and interests of investors.^【16】 The same bulletin stated that the minimum equity protection ratio applicable to credit-based capital market instruments could be maintained at 20 percent until a further announcement and until the close of trading on 2 October 2026.

It was decided to liquidate a total of 130 investment funds managed by the seven portfolio management companies. The distribution of funds under liquidation is as follows: 5 funds under Tera Portföy, 12 under Pusula Portföy, 31 under Hedef Portföy, 16 under Atlas Portföy, 9 under A1 Portföy, 15 under Bulls Portföy, and 42 under Pardus Portföy.^【17】

The CMB authorized Türkiye İş Bankası and Ziraat Bankası to carry out the liquidation procedures for the investment funds under liquidation. Accordingly, Türkiye İş Bankası was appointed as the custodian for funds established by Tera Portföy Yönetimi AŞ, while Ziraat Bankası was appointed as the custodian for funds established by A1 Capital Portföy Yönetimi AŞ, Atlas Portföy Yönetimi AŞ, Bulls Portföy Yönetimi AŞ, Hedef Portföy Yönetimi AŞ, Pardus Portföy Yönetimi AŞ and Pusula Portföy Yönetimi AŞ.^【18】

Within two business days after the decision, mutual agreement was to be reached between the CRA and the banks regarding the total outstanding participation units of the funds and the individual holdings of investors in their custody accounts, as well as any pledges, seizures, precautionary measures or other encumbrances. The financial assets held in the fund portfolios were to be deposited in the relevant bank accounts at Takasbank, and mutual agreements regarding the funds’ receivables and payables were to be conducted between the previous custodian, the bank and Takasbank. It was determined that mutual agreements regarding fund expenses were to be completed within 10 business days following the Board’s decision. The fund management fee was to be accrued to the funds at intervals determined by the banks during the liquidation process.^【19】

The financial assets in the fund portfolios were to be sold at frequencies determined by the banks, taking into account investor interests, market depth and liquidity conditions, with proceeds transferred to the funds in cash. Cash generated from maturing money market instruments and proceeds from the sale of other financial assets were permitted to be reinvested in money market instruments and transactions according to the payment schedule. It was decided that the cash proceeds would be transferred to investors’ individual custody accounts in proportion to their participation unit ownership.^【20】

After 13:30 on 17 September 2026, redemption instructions for specific participation units in money market funds submitted after the relevant value date were to be considered under the liquidation process. Amounts arising from redemption instructions previously submitted via TEFAS but not yet executed were to be recorded as liabilities against the fund and paid first from the available cash.^【21】

It was decided that liquidation procedures were to be completed within a maximum of three months from the date of the liquidation announcement, and that this period could be extended if deemed appropriate by the Board. As of 17 September 2026, new subscription or redemption instructions for the liquidated funds were prohibited through distribution channels outside TEFAS; instructions submitted before this date but not yet settled were to be completed under normal procedures.^【22】

The Financial Stability Committee (FSC) convened at 08:00 on 17 September 2026 under the chairmanship of Treasury and Finance Minister Mehmet Şimşek. In its subsequent statement, the FSC assessed that the developments in the capital markets originated from credit and liquidity problems in a limited number of funds managed by a small number of portfolio management companies.

The FSC stated that there were no fundamental or structural risks affecting the overall functioning of Borsa İstanbul and the Turkish capital markets and that the issue was concentrated in a specific segment of the fund market. The Committee evaluated the situation as temporary and manageable.

Treasury and Finance Minister Mehmet Şimşek made statements regarding the developments in the capital markets during an NTV special broadcast on 18 September 2026. Şimşek stated that the problems arose from credit and liquidity issues in a limited number of funds and that there was no systemic or structural risk affecting the broader Borsa İstanbul and fund markets.^【23】

Şimşek explained that free funds in Türkiye are subject to more flexible regulations and that since their trading began on TEFAS in 2019, the number of funds in this category has grown significantly. He noted that there are a total of 2,038 funds in Türkiye, of which 131 are under liquidation. Şimşek also stated that after the FSC meeting at the end of 2025, regulatory work on free funds was initiated and that the new Investment Funds Guideline was published in August 2026.

Şimşek stated that the funds under liquidation represent approximately 10 percent of total fund assets, while approximately 90 percent of the fund market continues operations. He affirmed that liquidation procedures would be conducted in accordance with the procedures and principles established by the CMB and that fund assets would be transferred to investors. Şimşek also noted that the necessary measures have been taken by the Central Bank, the Banking Regulation and Supervision Agency and the CMB and that the general functioning of the market continues.

Şimşek stated that the developments had caused temporary selling pressure on Treasury bonds, with interest rates on 2.5-year and 10-year bonds exhibiting liquidity-driven movements on 16 September, followed by a decline the next day. Regarding market-distorting activities, he confirmed that the CMB has taken necessary actions including license revocations and criminal complaints and that subsequent proceedings will be handled by judicial authorities.^【24】

Minister of Justice Akın Gürlek announced on 18 September 2026 that four individuals had been detained under the investigation into manipulative activities in the capital markets. The Istanbul Chief Public Prosecutor’s Office, following investigations conducted by the CMB under Article 107 of Law No. 6362 on the Capital Markets, filed criminal complaints, leading to the initiation of judicial proceedings.

Under the investigation, travel bans were imposed on 51 individuals, and precautionary measures were taken regarding suspects’ bank accounts and other assets. Gürlek also confirmed that four suspects, including chairpersons and members of fund boards, had been detained.

In a separate investigation conducted by the Bakırköy Chief Public Prosecutor’s Office, 16 suspects were detained. The investigation focused on social media posts aimed at manipulating the capital markets. It was also reported that the Istanbul Chief Public Prosecutor’s Office had prepared indictments against 41 suspects in a separate investigation into abnormal trading volumes and share price movements.

Gürlek stated that investigations into the capital markets are being conducted by judicial authorities and that measures to protect investor rights continue. In accordance with a decision by the 1st Civil Court of Peace in Istanbul, access to 246 social media accounts deemed to have generated fear and panic among investors through speculative posts was restricted.

Of the seven portfolio management companies whose funds were suspended by the CMB, six issued statements regarding the matter.^【25】

Bulls Portföy Yönetimi AŞ stated that it had not engaged in any risky transactions similar to those recently in the news and that no liquidity issues had arisen in its funds. The company indicated that it had largely complied with the 28 August 2026 amendments to the Investment Funds Guideline and that no share repo transactions had been conducted in its funds. Bulls Portföy also stated that if necessary permissions are granted, trading suspensions on TEFAS can be reversed to meet investor redemption requests.

Hedef Portföy Yönetim Şirketi stated that the CMB’s decision was not related to the company’s ability to meet its financial obligations or any default situation and that no liquidity problems exist that would affect the continuity of its operations or the payment capacity of its funds.

Atlas Portföy stated that the 16 funds under liquidation will act in accordance with CMB directives and that measures to protect investor rights will continue.

A1 Capital Portföy stated that subscription and redemption activities for its TEFAS-traded funds have been suspended, that it has no liquidity issues, and that investor requests will be addressed if necessary permissions are granted.

Pardus Portföy stated that operations regarding the funds under liquidation will be conducted in accordance with the procedures and principles established by the CMB and that the company has initiated all necessary actions to comply with the liquidation process.

Tera Portföy stated that under the CMB decision, trading of five investment funds on TEFAS has been suspended, that the decision is limited to these funds, and that the operations of the company’s other funds and other financial institutions within the Tera Group have not been directly affected. The company also confirmed that its operational and portfolio management activities continue.^【26】

On 16 September 2026, Emre Tezmen, Chairman of the Board of Tera Holding, described the situation in certain Pusula Portföy funds as “a temporary liquidity shortage”. Tezmen claimed that the developments resulted from a planned and organized speculative campaign. A travel ban was imposed on Tezmen on 17 September 2026.^【27】

Tuna Portföy Yönetimi AŞ stated in its 18 September 2026 announcement that its Tuna Portföy ÖPY Para Piyasası Özel Fonu (TNR) was established solely for managing the company’s own assets and liquidity processes. The company clarified that the fund was never intended for public offering or opening to external investors and that false information disseminated under its name will be subject to legal action.^【28】

Turkish Capital Markets Association (TCMA) stated in its 17 September 2026 announcement that it supports the regulatory measures adopted by the CMB under the Investment Funds Guideline. TCMA stated that these measures will contribute to the secure functioning of capital markets, strengthen market confidence and preserve stability.^【29】

According to CMB Bulletin No. 2026/60, the titles of the investment funds under liquidation, along with their respective portfolio management company sponsors, are as follows:^【30】

● Bulls Portföy Money Market (TL) Fund

● Bulls Portföy First Free Equity Fund (TL) (Equity-Intensive Fund)

● Bulls Portföy Non-Banking Sector Free Equity Fund (Equity-Intensive Fund)

● Bulls Portföy Fourth Free Equity Fund (Equity-Intensive Fund)

● Bulls Portföy BIST 50 Excluded Companies Free Equity Fund (Equity-Intensive Fund)

● Bulls Portföy Second Free Equity Fund (TL) (Equity-Intensive Fund)

● Bulls Portföy Algorithmic Free Equity Fund (TL) (Equity-Intensive Fund)

● Bulls Portföy Absolute Return Target Free Equity Fund (Equity-Intensive Fund)

● Bulls Portföy BIST 30 Excluded Companies Free Equity Fund (Equity-Intensive Fund)

● Bulls Portföy Sixth Free Equity Fund (Equity-Intensive Fund)

● Bulls Portföy Fifth Free Equity Fund (Equity-Intensive Fund)

● Bulls Portföy Industrial Companies Free Equity Fund (Equity-Intensive Fund)

● Bulls Portföy Third Free Equity Fund (TL) (Equity-Intensive Fund)

● Bulls Portföy GMS Free Equity Special Fund (Equity-Intensive Fund)

● Bulls Portföy Star Market Companies Free Equity Fund (Equity-Intensive Fund)

● Tera Portföy First Free Fund

● Tera Portföy Fourth Free Equity Fund (TL) (Equity-Intensive Fund)

● Tera Portföy Third Free Equity Fund (TL) (Equity-Intensive)

● Tera Portföy Money Market Participation (TL) Fund

● Tera Portföy Money Market (TL) Fund

● Pusula Portföy First Free Equity Fund (TL) (Equity-Intensive Fund)

● Pusula Portföy Third Free Equity Fund (Equity-Intensive Fund)

● Pusula Portföy Fourth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pusula Portföy East Free Equity Fund (TL) (Equity-Intensive Fund)

● Pusula Portföy South Free Equity Fund (TL) (Equity-Intensive Fund)

● Pusula Portföy Fifth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pusula Portföy Second Free Equity Fund (Equity-Intensive Fund)

● Pusula Portföy Second Participation Free Equity Fund (Equity-Intensive Fund)

● Pusula Portföy Money Market Participation (TL) Fund

● Pusula Portföy North Free Equity Fund (TL) (Equity-Intensive Fund)

● Pusula Portföy Second Money Market (TL) Fund

● Pusula Portföy Money Market (TL) Fund

● Atlas Portföy Fourth Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Fifth Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy First Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Banking Sector Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Statistical Arbitrage Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Ufuk Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Second Participation Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Participation Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Second Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Algo Toros Free Equity Fund (TL) (Equity-Intensive Fund)

● Atlas Portföy Fourth Free Fund (TL)

● Atlas Portföy Free Fund

● Atlas Portföy Money Market (TL) Fund

● Atlas Portföy Money Market Free Fund

● Atlas Portföy Industrial Sector Free Equity Fund (Equity-Intensive Fund)

● Atlas Portföy Third Free Equity Fund (Equity-Intensive Fund)

● Hedef Portföy Ufuk Free Equity Fund (Equity-Intensive Fund)

● Hedef Portföy Model Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Atlas Statistical Arbitrage Free Equity Fund (Equity-Intensive Fund)

● Hedef Portföy Doruk Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Fourth Statistical Arbitrage Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy East Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Vega Statistical Arbitrage Free Equity Fund (Equity-Intensive Fund)

● Hedef Portföy Algo Everest Statistical Arbitrage Free Equity Fund (Equity-Intensive Fund)

● Hedef Portföy Second Participation Free Equity Fund (Equity-Intensive Fund)

● Hedef Portföy Güneş Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy South Free Equity Fund (Equity-Intensive Fund)

● Hedef Portföy First Statistical Arbitrage Free Equity Fund (Equity-Intensive Fund)

● Hedef Portföy İnci Free Equity Special Fund (Equity-Intensive Fund)

● Hedef Portföy Money Market Free Fund

● Hedef Portföy Başak Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Participation Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Ada Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Ege Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Mavi Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy North Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy İdeal Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Çınar Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Second Money Market (TL) Fund

● Hedef Portföy Zen Free Equity Fund (TL) (Equity-Intensive)

● Hedef Portföy Ece Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Pusula Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Rota Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Money Market (TL) Fund

● Hedef Portföy Money Market Participation Fund

● Hedef Portföy Nehir Free Equity Fund (TL) (Equity-Intensive Fund)

● Hedef Portföy Short-Term Free Fund

● A1 Capital Portföy Statistical Arbitrage Free Equity Fund (Equity-Intensive Fund)

● A1 Capital Portföy Non-Banking Sector Free Equity Fund (TL) (Equity-Intensive Fund)

● A1 Capital Portföy BIST 100 Excluded Companies Free Equity Fund (TL) (Equity-Intensive Fund)

● A1 Capital Portföy Free Equity Fund (Equity-Intensive Fund)

● A1 Capital Portföy BIST 30 Excluded Companies Free Equity Fund (Equity-Intensive Fund)

● A1 Capital Portföy Second Free Equity Fund (TL) (Equity-Intensive Fund)

● A1 Capital Portföy Industrial Sector Free Equity Fund (TL) (Equity-Intensive Fund)

● A1 Capital Portföy Money Market (TL) Free Fund

● A1 Capital Portföy Money Market (TL) Fund

● Pardus Portföy Statistical Arbitrage Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy First Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Second Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Second Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Sixth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy BIST 50 Excluded Companies Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Fifth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Bereket Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy BIST 30 Excluded Companies Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Non-Banking Sector Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Third Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Ninth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Fourth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Second Statistical Arbitrage Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Kartal Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Absolute Return Target Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Tenth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Anadolu Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy BIST 100 Excluded Companies Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Capital Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy East Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy South Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy West Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy North Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Marmara Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Model Portfolio Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Seventeenth Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Eighteenth Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Nineteenth Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Eleventh Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Sixteenth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Twelfth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Fifteenth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Thirteenth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Fourteenth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Industrial Companies Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Non-Industrial Sector Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Twenty-First Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Twenty-Second Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Twentieth Free Equity Fund (Equity-Intensive Fund)

● Pardus Portföy Eighth Free Equity Fund (TL) (Equity-Intensive Fund)

● Pardus Portföy Money Market (TL) Fund

The Istanbul Public Prosecutor’s Office Office for the Investigation of Terrorist Financing and Money Laundering, in a memorandum dated 17 September 2026 addressed to the Presidency of the Financial Crimes Investigation Board (MASAK), requested the acquisition of financial data concerning Pusula Finans Holding AŞ, Tera Yatırım Menkul Değerler AŞ, Hedef Holding AŞ and Bulls Yatırım Menkul Değerler AŞ, as well as their subsidiary management personnel. The memorandum requested the identification of the full identity details of the aforementioned company executives, the transmission of raw data regarding their foreign currency and cryptocurrency transfers since 2024, and all incoming and outgoing financial transactions to be sent directly to the Public Prosecutor’s Office.

The financial investigation was stated to encompass not only the four fund managers named but also the financial and cryptocurrency movements of their first-degree relatives. The purpose of the investigation is to determine whether funds or cryptocurrency assets were transferred abroad through these individuals or their close relatives.

It was reported that the investigation is being conducted under file number 2026/149004, which carries a confidentiality order. The authorities requested that the data requested from MASAK be sent to the Public Prosecutor’s Office without delay.

During the initial financial review under the investigation, it was determined that two fund managers transferred $15 million and €25 million respectively from their bank accounts to accounts in Switzerland.

According to the MASAK report, a transfer of approximately 2 billion 889 million Turkish Lira was made on 1 September 2026 between the account of Muhammed Yarız, Chairman of the Portfolio Management Board of Pusula Portföy, and an account at the Edmond de Rothschild Bank in Switzerland. The same report recorded a transfer of approximately 1 billion 198 million Turkish Lira on 24 August 2026 from the account of Serdar Turhan, Chairman of the Management Board of Pusula Holding, to the same bank.

It was determined that these financial movements occurred prior to the default of fund redemption payments scheduled for 15–16 September 2026.

Capital Markets Board (SPK) amended its guidelines on fund liquidation procedures on 21 September 2026, following an announcement made on 17 September 2026. Under the new principles, the previously maximum three-month liquidation period for funds under liquidation has been extended to six months, taking into account portfolio structures and market developments.

Under the 17 September amendments, Türkiye İş Bankası and Ziraat Bankası were authorized to oversee the liquidation process. With the new regulation, the maximum time allowed for completing transactions related to funds under liquidation belonging to seven portfolio management companies has been extended to six months.

The Istanbul Public Prosecutor’s Office Office for the Investigation of Terrorist Financing and Money Laundering is conducting a separate investigation into transactions in the capital markets. On 19 September 2026, the following individuals were detained: Emre Tezmen, Chairman of the Management Board of Tera Yatırım Holding; Emre Alkın, Member of the Management Board of Tera Yatırım Holding; Kerem Alkın, Independent Member of the Management Board of Tera Yatırım; Alper Öztürk, General Manager of Tera Portföy; and Serdar Turhan, Chairman of the Management Board of Pusula Holding. Police teams conducted searches in the offices of Emre Tezmen and Alper Öztürk. The detainees’ proceedings are ongoing at the Financial Crimes Prevention Branch Directorate of the Istanbul Police Directorate.

On 20 September 2026, Nihat Kırmızı, Chairman of the Management Board of Doğa Sigorta, and Tera Yatırım Management Board members Bülent Uygun and Abdulkadir Özkan were also detained. This brings the total number of suspects detained under the investigation to eight. Detention measures have also been applied to other suspects, including holding chairpersons and executives, alongside Nihat Kırmızı.

Following the analysis of financial data requested from the Presidency of the Financial Crimes Investigation Board (MASAK), the Istanbul Public Prosecutor’s Office Office for the Investigation of Terrorist Financing and Money Laundering initiated an investigation into KTLEV shares on suspicion of market fraud. As a result, 15 suspects were apprehended by the Financial Crimes Branch Directorate of the Istanbul Police Directorate under detention orders.

Justice Minister Akın Gürlek announced that judicial proceedings have been initiated against 25 suspects in connection with the KTLEV shares investigation, of whom 15 have been detained and efforts are ongoing to apprehend 10 fugitive suspects.

In the financial dimension of the investigation, measures have been initiated to freeze the assets and financial movements of executives and officials linked to Pusula Finans Holding, Pusula Yatırım Menkul Değerler, Tera Yatırım Menkul Değerler, Tera Portföy Yönetimi, Hedef Holding, Hedef Portföy Yönetimi, Bulls Yatırım Menkul Değerler, Bulls Portföy Yönetimi and Ufuk Yatırım Yönetim ve Gayrimenkul. In this context, memoranda have been sent to the Turkish Banks Association, the Turkish Participation Banks Association, the Turkish Notaries Association, the General Directorate of Land Registry and Cadastre, the General Directorate of Maritime Affairs, the General Directorate of Civil Aviation and MASAK, instructing them to implement the relevant measures.

Furthermore, the relevant institutions have been notified that no asset-reducing transactions involving the chairpersons and members of the management boards, authorized signatories, spouses and first-degree blood relatives of the named companies may be carried out without the knowledge and approval of the Istanbul Public Prosecutor’s Office. The investigation continues on all other fronts.

Among the 15 detained suspects are Berkan Gülen, Celal Yarız, Furkan Baki, Halil İbrahim Ege, İlhan Aygün, İsmail Ege, Lütfi Çetinel, Mehmet Erbey, Mehmet Yıldırım, Murat Keçeci, Salih Can Bülbül, Samet Çetinel, Uğur Akkafa, Ramazan Erbey and Selçuk Kahya. It was indicated that the suspects held positions as managers, officials or employees in various companies.

As part of the investigation conducted by the Istanbul Public Prosecutor’s Office for Terrorism Financing and Money Laundering Crimes, Selim Dağbaşı and Hamza Kablan were taken into custody on 21 September 2026. It was reported that the suspects’ financial transactions were being examined by the Financial Crimes Unit of the Istanbul Police Directorate.

With these two new arrests, the total number of individuals taken into custody in the fund investigation has risen to 17. Following an analysis of the financial movements of detained suspect Muhammed Yarız, it was determined that Selim Dağbaşı transferred 14.5 million US dollars to Yarız’s account in Switzerland on 25 May 2026. The same review established that Hamza Kablan transferred a total of 970 million 360 thousand Turkish liras in two transactions on 4 September 2026.

On 22 September 2026, following two days in custody, Serdar Turhan, Chairman of the Board of Pusula Holding, Emre Tezmen, Chairman of the Board of Tera Investment Holding, and executives Alper Öztürk, Emre Alkın and Kerem Alkın were referred to court. It was reported that investigations into the activities of Nihat Kırmızı, who was taken into custody on 19 September 2026, are still ongoing at the police station.

Justice Minister Akın Gürlek announced on 22 September 2026 via his social media account that, under the coordination of the Istanbul Public Prosecutor’s Office and the Istanbul Provincial Police Directorate, a new wave of operations was carried out based on market manipulation findings related to shares held by the Capital Markets Board’s Katılımevim Tasarruf Finansman (KTLEV), Destek Holding and Hedef Holding. According to Gürlek’s statement, during simultaneous operations in Istanbul and Aydın, 14 of the 15 suspects subject to arrest warrants were apprehended and taken into custody, while one suspect was found to be abroad.

Gürlek stated that with this latest operation, judicial proceedings have been initiated against 60 suspects so far in the investigation, four suspects have been detained, 44 suspects remain in custody, and efforts to apprehend 12 additional suspects are ongoing. Gürlek added: “Investigations into manipulative transactions in the capital markets continue with determination to uncover wrongdoing, protect the rights of our affected citizens, ensure accountability under the law, and uphold justice. [...] The financial dimension of the investigation is being thoroughly examined; all legal and financial measures are being effectively implemented to identify illicit gains, prevent asset concealment, and safeguard the rights of our affected citizens. Whoever is found legally responsible will be held accountable before the law; the trail of illicit profits will be followed to its end, and all necessary legal measures will be firmly applied to protect the rights of our affected citizens.”

On 22 September 2026, the Capital Markets Board issued a principle decision regarding share buybacks. According to the decision, the upper limit on the total value of shares repurchased will not be applied until a further announcement is made.

In his statement titled “Our Citizen’s Savings Are Not Ownerless; No One Is Above the Law”, Gürlek stated that under the leadership of President Recep Tayyip Erdoğan, state institutions are working in coordination, and the “fund investigation” being conducted by the Istanbul Public Prosecutor’s Office Special Investigation Unit for Money Laundering, with the support of MASAK and the Istanbul Provincial Security Directorate’s Financial Crimes Prevention Branch, is being carried out comprehensively.

According to Gürlek’s statement, as of 25 September 2026, judicial proceedings have been initiated against a total of 76 suspects, 45 suspects have been arrested, judicial supervision orders have been issued for 5 suspects, and arrest operations have been launched against 12 suspects. Judicial proceedings against the 14 suspects in custody are ongoing.

Gürlek also stated that assets belonging to fund owners and suspects in management positions have been seized, the assets of their first-degree relatives have been frozen, and the chain of responsibility has been traced in accordance with evidence gathered during the investigation.

In his statement on 26 September 2026 under the title “We Stand by Our Citizen’s Rights”, Gürlek emphasized that under the close supervision of President Erdoğan, the priorities of the fund investigation are to protect citizens’ rights and ensure that grievances are addressed within the legal framework.

Gürlek noted that the investigation is being conducted under charges of “forming an organization for criminal purposes – membership”, “qualified fraud”, “money laundering of proceeds from crime”, and “violation of the Capital Markets Law”. He added: “Today, another step has been taken in this context. Based on an analysis of fund outflows between 1 July and 16 September, starting with the highest amounts, asset freezes have been imposed on 46 legal entities, 18 funds, and 42 individuals. Judicial supervision measures in the form of travel bans have been applied to 37 suspects who had no prior restrictions. To prevent transfers, assignments, sales, donations, mortgages, pledges, account closures, large cash withdrawals, EFT/telegraphic transfers, and other asset-reducing transactions; to freeze capital market instruments; and to ensure immediate reporting of suspicious transactions to judicial authorities, official notices have been issued to all relevant institutions and organizations.”

Gürlek further stated: “No matter which account the money was transferred to or whose name the assets were transferred to, we will trace the trail to its end. We will never allow the decades-long savings of our well-intentioned citizens to be exploited by certain individuals and structures.” He added: “We will fight to the very end using every legal means available to protect our citizens’ rights, labor, and savings”.

In the 26 September 2026 notice issued by the Public Prosecutor’s Office, it was requested that capital market instruments be frozen and large monetary transfers and asset-reducing transactions be blocked for a total of 106 individuals and entities: 46 legal persons, 18 funds, and 42 individuals. The freeze was to extend to the spouses, children, and designated close family members of those listed. Prior approval from the Public Prosecutor’s Office was required for any transfers, assignments, sales, donations, mortgages, pledges, account closures, large cash withdrawals, EFT, or telegraphic transfers. Additionally, it was requested that immovable property, ships, and aircraft registered in the names of the individuals and their spouses be identified and that any unusual transactions be reported immediately to the Public Prosecutor’s Office and MASAK. The notice was sent to the Turkish Banks Association, the Turkish Participation Banks Association, the Turkish Notaries Association, the General Directorate of Land Registry and Cadastre, the General Directorate of Maritime Affairs, the General Directorate of Civil Aviation, MASAK, MKK, SPK, Takasbank, and Borsa Istanbul. The notice also stated that, pursuant to the SPK’s decision of 17 September, trading activities for 131 funds on TEFAS had been suspended.

Among the legal entities listed are Tera Investment Securities Inc., Pusula Investment Securities Inc., Tera Investment Bank Inc., Pusula Finans Holding Inc., Ulusoy Grain Industry and Trade Inc., Astor Energy Inc., Tatilbudur, Enuygun, Türkiye Insurance, Türkiye Life and Pension, Doğa Insurance, Eker Dairy Products, Yayla Agro Foods, Katılımevim, and Alfa Solar Energy.

The funds include Tera Portfolio Equity Fund, Tera Portfolio First Free Fund, Pusula Portfolio Equity Fund, Pusula Portfolio First Variable Fund, Pusula Portfolio Third Equity Free Fund, Tera Portfolio Fourth Equity Free Fund, Hedef Portfolio Eastern Equity Free Fund, and Atlas Portfolio Free Fund.

The individuals listed are Muhammed Yarız, Serdar Turhan, Erdin Özel, Abdullah Ercan, Melis Sandal, Emrullah Ercan, Ömer Bedir Çetinel, Mustafa Dedik, Hakan Yıldız, Enver Geçgel, İsmet Öğüt, Tarık Sarvan, Tolga Aydın, Ezgi Kaya, Burhan Tunç Özkan, Mehmet Selçuk Aksoy, Turgay Ceylani, Rıza Kandemir, Cengiz Avcı, and Furkan Talay.

It was claimed that a travel ban has been imposed on Melis Sandal listed in the report, and that more than 11 billion 126 million TL had been withdrawn from her account.

The Istanbul Public Prosecutor’s Office Special Investigation Unit for Money Laundering issued arrest warrants for Emir Münir Sarpyener, previously subject to a travel ban, and Erdin Özel, Chairman of the Board of Tera Portfolio. Both suspects were taken into custody on 27 September 2026.

According to the 27 September 2026 statement by the Public Prosecutor’s Office, the notice issued on 26 September under investigation number 2026/149004 requested the freezing of capital market instruments held by certain individuals and institutions. Following a new assessment and reports from the SPK, it was decided to lift the asset and fund freezes.

As of 28 September, asset freezes have been lifted on 45 companies and 19 funds, while measures against 42 individuals remain in effect.

Bakırköy Public Prosecutor’s Office has launched an investigation into the owners of social media accounts that have shared false, misleading, or deceptive information intended to influence the prices or values of capital market instruments or investor decisions. The investigation was first made public on 14 September 2026.

According to the prosecutor’s office, six suspects were identified as having undermined public confidence through misleading social media posts regarding stock market activities, and detention orders were issued against them. Work has also begun to identify the owners of 11 additional accounts.

After police procedures, the suspects were referred to local courts in their respective cities. Following statements to prosecutors, they were brought before peace criminal courts.

On 17 September, the court decided to impose judicial supervision in the form of travel bans on five of the six suspects, and no measures were applied to the suspect held in custody.

On 18 September, judicial proceedings were initiated against account owners assessed to have made posts on social media intended to manipulate capital markets, and 16 suspects were arrested.

This investigation is being conducted separately from the main fund investigation, under a different prosecutor’s office and a separate case file.

According to Justice Minister Yılmaz Gürlek’s statement on 18 September, a separate investigation initiated ex officio by the Istanbul Public Prosecutor’s Office led the Istanbul 1st Peace Criminal Court to order the blocking of access to 246 social media accounts that posted speculative content likely to cause fear and panic among investors. The decision was sent to the Presidency of Cyber Security for implementation.

AK Party Deputy General Chairman Fatma Betül Sayan Kaya stated on her social media account on 26 September 2026 that various allegations and assessments concerning her had been brought to public attention in connection with the issue that has occupied public discourse in recent days.

Kaya said: “Our President and Party Chairman, Mr. Recep Tayyip Erdoğan, has clearly and firmly stated in recent days that all allegations must be thoroughly investigated and the process must be conducted with utmost care.” She added: “Our duty to the nation requires us to assume political and moral responsibility when necessary. Therefore, in this process where allegations concerning me will be clarified, I believe it is essential to assume political responsibility so that my position is not subject to any controversy and the investigation can proceed independently and healthily without any shadow. With this understanding, I have requested the resignation from all my duties from our Party Chairman”.

On 27 September, AK Party Spokesperson Ömer Çelik announced that Kaya had requested and received approval for her resignation from the Central Executive Board (MYK) and the Central Decision and Management Board (MKYK). Thus, Kaya has stepped down from both boards.

AK Party Deputy General Chairman and Party Spokesperson Ömer Çelik stated on his NSosyal account on 27 September 2026: “Every aspect and detail of the agenda referred to as the fund crisis has been closely monitored and evaluated since day one by our party’s authorized institutions under the instructions of our Party Chairman and President. Our fundamental principle in these evaluations is the statement of our President and Party Chairman: ‘Anyone who is responsible will be held accountable.’ Under this principle, we will fight without compromise against any wrongdoing, corruption, exploitation, or irregularity.”

Çelik continued: “Nothing will remain hidden and everything necessary will be done. If there is an allegation, it will be investigated. All irregularities will be brought to light. Those who have erred will answer before the law. There is no systemic risk to our financial system or Türkiye’s economy. Our foundations are solid. This is an issue confined to a limited segment of the capital markets and certain funds. While addressing this issue, as our President has stated, we are comprehensively undertaking all necessary legal and administrative measures to prevent similar problems in the future. All oversight institutions are on duty. We will uphold and strengthen the principles of transparency, oversight, and accountability. Our determination to stand by the trust of our nation in every area is absolute. There can be no compromise, exception, or indecision in standing by our nation’s trust. In our AK Party, ‘the alphabet of our politics’ is the unwavering fight against all wrongdoing.”

In a press statement at the AK Party Beykoz District Headquarters on the same day, Çelik said: “With full coordination between our Ministry of Justice, our Ministry of Treasury and Finance, and all our institutions, and based on our President’s principle of ‘Whoever has done wrong will be held accountable,’ we will address all these issues. The situations of citizens affected negatively will of course be carefully examined.”

Çelik also stated: “There is no systemic risk to our financial system or Türkiye’s economy. This is a crisis centered on a limited number of funds within a restricted segment of the capital markets. We will address this issue, and those responsible will answer regardless of the field. At the same time, we have initiated efforts to take all necessary administrative and judicial measures to prevent recurrence.”

Çelik emphasized that political and legal responsibility are distinct: “Of course, we believe in the presumption of innocence. We are taking steps necessary for the integrity of the investigation, and our colleagues are demonstrating political responsibility. When the legal situation becomes clear tomorrow, we will take further actions. We will decide then.”

Regarding victims, he stated: “Who is a victim and who is not will be determined by the relevant institutions. Afterward, a roadmap will certainly be shared regarding this.” He also noted that they have developed a roadmap in line with the principles stated by President Erdoğan upon his return from the United States, and that a party committee established under the President’s instructions is monitoring the process.

Justice Minister Yılmaz Gürlek, speaking at the Sultanbeyli 10th Book Fair on 27 September 2026, said: “It is our responsibility to protect our citizens’ peace of mind as much as their labor and savings. Therefore, we are closely monitoring developments in our economy and financial system. Our President, Mr. Recep Tayyip Erdoğan, has been monitoring the process since day one and has provided us with all necessary instructions promptly and appropriately. The matter referred to in public opinion as ‘fund operations’ is fully under the control and supervision of our judiciary. Let our citizens rest assured: we will never allow their rights or legal protections to be violated. If anyone has wronged them, we will hold them accountable to the end. Our public prosecutor’s offices and related institutions have comprehensively placed the process under observation, opened necessary investigations, and continue to do so.”

In the same speech, Gürlek said: “My request to you is not to pay attention to provocative and malicious manipulative attacks on social media and in the media, but to follow the process through the official statements of our authorized institutions”.

At the Muhsin Yazıcıoğlu Cultural Center in Sultanbeyli, he added: “In recent days, we have faced certain negative developments in financial markets, one of the most important pillars of our economic system. Be certain that we are addressing this process with the utmost legal rigor. No matter where it leads, we are determined to bring all those responsible for harming our citizens’ interests before justice. In accordance with the instructions of our President, Mr. Recep Tayyip Erdoğan, our government ministries and institutions are swiftly taking necessary measures and working to bring full clarity to the process. Let our citizens rest assured. Nothing will remain hidden”.

AK Party Deputy General Chairman Mustafa Elitaş, speaking at a program at the AK Party Başakşehir District Headquarters on 27 September 2026, said: “Whoever they are, whether from us or others. If anyone manipulated this process, knowingly knowing the entry and exit dates, and turned 1 lira into 10 liras, 10 million liras into 100 million liras, or billions, they will answer for it, my friend. No matter whose child, whose son, whose relative it is, there is no distinction. Tayyip Erdoğan has taken on this issue. God willing, he will do what is necessary”.

According to the statement issued by the Istanbul Public Prosecutor’s Office, during the investigation the Capital Markets Board determined that market fraud had occurred in transactions involving the shares of Destek Holding and Özata Denizcilik. The statement recalled that the owners of these companies, Altunç Kumova and Özdemir Ataseven, had previously been taken into custody and subsequently ordered detained by a judge. Altunç Kumova, identified as the owner of Destek Investment Bank, was arrested following his detention on 17 September 2026.

The prosecutor’s statement also indicated that proceedings had been initiated against members of the boards of directors of Destek Holding and Özata Denizcilik. According to the statement, Altuğ Kantarcı, Özgür Akayoplu, Kerim Tosun, Nuray Elmastaş, Azize Binnur Tosun and Ali Çil were apprehended; arrest warrants have been issued for Tuğba Hicran Ataseven, Duygu Somay and İskender Balcı.

On 28 September, the investigations concerning the 12 suspects held in custody under the investigation were completed by the Istanbul Police Directorate’s Financial Crimes Prevention Unit. After undergoing health checks, the suspects were transferred to the Istanbul Courthouse in Çağlayan for prosecutorial proceedings.

Those transferred to the courthouse are as follows:

• Kerem Lafçı
• Necmettin Enes Töbü – General Manager of Pusula Otomotiv Filo Kiralama AŞ
• Engin Geylan – Procurement Manager of Katılımevim Tasarruf Finansman AŞ
• Niyazi Derindağ – Internal Auditor of Katılımevim Tasarruf Finansman AŞ
• Hacı Bayram Adıyaman – Specialist at Katılımevim Tasarruf Finansman AŞ
• Yusuf Caf – Information Technology Support Specialist at MİEM Yapı İnşaat Sanayi ve Ticaret AŞ
• Ayşegül Kaya, Evren Uçar, Okan Uzunoğlu, Cem Gürkan Alpay, Duygu Kuşçu and Hüseyin Emre Sezer – Employees of Tera Holding

Minister of Treasury and Finance Mehmet Şimşek conducted two days of meetings with relevant institutions regarding the liquidation of funds and payments to investors. During these meetings, technical work on the liquidation and payment procedures of seven portfolio management companies was addressed.

In a statement posted on his social media account on 24 September 2026, Şimşek rejected allegations that he had submitted his resignation or was considering doing so.

In his statement on 28 September, he confirmed that the legal process against those involved in market-distorting activities continues, and that no actions are being taken against individuals or companies not connected to these activities. Şimşek also stated that the legitimate rights of fund investors are being protected and that necessary measures are being taken to prevent negative impacts on the financial system and the real economy. He emphasized the importance of the public following official statements issued by competent authorities.

Following the disclosure that the singer’s wife, Melis Sandal, was among the individuals for whom asset freezes were requested, singer Mustafa Sandal issued a statement on his social media account. Sandal stated that he had not engaged in any fund purchases or sales and was not involved in the aforementioned scheme.

On 28 September 2026, following its investigation into Tera Financial Investments Holding, the SPK decided to file criminal charges against the following 37 individuals: Emre Tezmen, Emir Münir Sarpyener, Abdülkadir Özkan, Kerem Alkin, Kadir Boy, Erdin Özel, Ethem Umut Beytorun, Emre Alkin, Haldun Saffet İnal, Ecem Tuğçe Akçay, Bülent Uygun, İbrahim Bekçi, Okan Uzunoğlu, Furkan Açar, Mehmet Selim Tunçbilek, Adem Karatepe, Rüstem Karakaya, Ali Cesur, Anıl Tokat, Mustafa Zeki Kayahan, Sibel Gökalp, Şemsihan Karaca, Ömer Eryılmaz, Mehmet Nuri Gökalp, Neda Soydan, Ayşe Seher Aydın, Enes Yazıcı, Feryal Köker, Müjdat Ede, Nilgül Sarıçalı, Oğuzhan Özerkaya, Onur Göğebakan, Orçun Berkay Kaya, Ahmet Özcan, Halil İbrahim Ege, Muhammed Yarız and Sezai Bekgöz.

The Board decided to impose a two-year trading ban on the aforementioned 37 individuals as well as on Tera Investment Securities Inc. and Tera Portfolio Management Inc. in the stock market and other organized markets for their involvement in transactions conducted on Tera Financial Investments Holding’s equity market.

The SPK also decided to revoke the licenses and authorizations of the following 24 individuals: Emir Münir Sarpyener, Ethem Umut Beytorun, Ecem Tuğçe Akçay, Bülent Uygun, İbrahim Bekçi, Okan Uzunoğlu, Furkan Açar, Mehmet Selim Tunçbilek, Adem Karatepe, Ali Cesur, Anıl Tokat, Mustafa Zeki Kayahan, Ömer Eryılmaz, Mehmet Nuri Gökalp, Ayşe Seher Aydın, Enes Yazıcı, Feryal Köker, Müjdat Ede, Nilgül Sarıçalı, Oğuzhan Özerkaya, Onur Göğebakan, Orçun Berkay Kaya, Ahmet Özcan and Sezai Bekgöz.

Some of the individuals against whom criminal charges were filed had previously been arrested, placed under judicial control, or detained during the main fund investigation.

In a public announcement published on its website, the SPK recalled that as of 17 September 2026, funds managed by the portfolio managers listed in the Board bulletin of that date had been closed to trading on TEFAS and were subject to liquidation. The SPK shared the updated list of these funds and stated that trading activities for these funds outside TEFAS had also been halted.

According to the announcement, only buy and sell orders submitted to TEFAS on or before 16 September 2026 were processed under the platform’s normal operations. As the funds were closed on TEFAS on 17 September, all orders submitted on that date were canceled by TEFAS.

The announcement stated: “Therefore, due to the closure of trading for the liquidated funds on TEFAS as of 17 September, the owners of the orders submitted to TEFAS on that date and canceled by the platform to comply with Decision 57/1707 will receive payments from the liquidation balance proportional to their participation share in the fund. On the other hand, pursuant to Article A/6 of the liquidation procedures and principles announced in the SPK Bulletin 2026/61, orders submitted to TEFAS on or before 16 September but not executed due to the fund’s default or failure to disclose prices are also included in the liquidation scope.”

On 28 September 2026, the contents of a letter signed by the SPK Chairman and sent to the Chief Public Prosecutor’s Office, which served as the basis for lifting asset freezes on 45 companies and 19 funds, became public. The letter outlined the findings of the Istanbul Public Prosecutor’s Office that there was a strong suspicion of market manipulation and illicit gains obtained through such activities. It also recalled the SPK Board’s decision of 17 September 2026 to suspend trading of 131 funds on TEFAS.

The SPK’s communication stated that it did not object to the findings regarding the suspicion of criminal activity but noted that the Chief Public Prosecutor’s Office, in its memorandum of 26 September, suggested that a reassessment of the measures imposed on the companies and funds listed as “responsible legal entities” and “responsible funds” would be beneficial. It was clarified that the lifting of measures against companies and funds by the Chief Public Prosecutor’s Office did not nullify the SPK’s decisions to suspend trading and liquidate the 131 funds. The SPK’s administrative measures, taken to protect investors and ensure the orderly functioning of the capital markets, continue to be enforced separately. Measures against natural persons remain in effect.

On 28 September, statements were taken from twelve suspects referred to the Istanbul Courthouse in Çağlayan. The prosecutor’s office requested the arrest of Necmettin Enes Töbü, Kerem Lafçı, Cem Gürkan Alpay, Engin Geylan, Okan Uzunoğlu and Yunus Caf, and requested judicial control for Hacı Bayram Adıyaman, Ayşegül Kaya, Duygu Kuşçu, Niyazi Derindağ, Evren Uçar and Hüseyin Emre Sezer.

On 29 September 2026, the court ruled to arrest Töbü, Lafçı, Alpay, Geylan and Caf and applied judicial control to the other seven suspects. Accordingly, judicial control was also applied to Okan Uzunoğlu, despite his initial referral for arrest.

29 September 2026: A news report based on an article in Sabah newspaper made the following allegations:

● It was claimed that Melis Sütşurup Sandal, wife of Mustafa Sandal, withdrew 11 billion 126 million 528 thousand 163 Turkish liras before the fund investigation began, traveled to Dubai, and has not yet returned to Türkiye.

● It was reported that Mustafa Sandal applied for a residence permit in Dubai during the same period; when he attempted to travel abroad for a concert recently, Dubai police prevented him from leaving the airport, requiring him to remain in Dubai for two days to complete procedures, after which he chartered a private jet to reach his concert.

● It was alleged that a travel ban has been imposed on Melis Sütşurup Sandal.

President Recep Tayyip Erdoğan, in a statement following the Cabinet Meeting held on 28 September 2026 at the Presidential Complex, stated that the fund issue, which had been on the agenda since 17 September, was thoroughly reviewed. He noted that Justice Minister Akın Gürlek and Minister of Treasury and Finance Mehmet Şimşek presented comprehensive briefings to Cabinet members on the steps taken so far.

Erdoğan recalled his public statements made after his return from New York and added: “But today I wish to state clearly once again: Whether through market manipulation, stock market games, or blatant corruption as seen in municipalities, anyone who lays hands on the rights, law, property, or assets of the nation will find us and the state standing against them. Let no one confuse us with others. Let no one compare us to those who roam city to city and square to square defending billions of liras in corruption. We are not like them. Our red line is our honorable nation. When it comes to our nation, our stance is clear. We neither appropriate rights nor turn a blind eye to the violation of citizens’ rights. We will never defend those who steal like others. This is precisely the difference. When it comes to the peace of our people, and when it comes to the economic security, prosperity, and development of our 86 million citizens, we show no hesitation whatsoever. We have already demonstrated our resolve on this matter beyond any doubt.”

Erdoğan emphasized that his administration closely monitors developments in the capital markets: “Our economic advisors are working intensively in coordination with other responsible units. We are consulting with our colleagues to ensure that necessary steps are taken swiftly.” Highlighting that Türkiye’s economy is approaching a size of two trillion dollars, Erdoğan stated: “Türkiye’s financial system is strong. The problem has occurred only in a limited segment of the fund market. No risk has affected our financial system. The Turkish capital market is resilient and built on solid foundations. We have more than sufficient capacity to overcome this test. Anyone who claims otherwise is committing a grave injustice against Türkiye’s stock market, Türkiye’s economy, and the Turkish people. No one—not even opposition figures—has the right to harm our economy or unsettle investors merely to gain political advantage.”

Erdoğan also said: “No reason justifies foreign media outlets writing articles to denigrate their own country. I once again entrust to the profound wisdom of our nation the mindset that seeks help from Western patrons through complaint letters. Such a mindset brings no benefit to our country or our people.”

Regarding the liquidation process, Erdoğan said: “We act with extreme caution in accordance with the nature of capital markets. Work on the liquidation of suspended funds is being carried out with meticulous care.” He added: “Those found to have engaged in market-distorting activities through funds will be held accountable under the law. Another critical issue here is preventing a recurrence of a similar problem. We are actively working on this. InshAllah, we will swiftly implement administrative and legal reforms that will make our capital markets function far more healthily. Let everyone rest assured: the relevant institutions of our state are working intensively. Tomorrow I will meet with our economic advisors and the heads of responsible institutions. Within the framework of capital market rules and the limits of the rule of law, guided by the conscience of the people, every necessary step will be taken.”

29 September 2026 in the evening, five luxury villas in Beykoz, identified as belonging to detained individuals Muhammed Yarız and Serdar Turhan but registered in the names of third parties, were seized. The total market value of the villas is estimated at approximately 1 billion 200 million lira. Investigations within the scope of the probe revealed that efforts had been made to transfer and reduce asset holdings by transferring properties to third parties; the prosecution determined that such transfers were intended to conceal ownership.

An arrest warrant has been issued against businessman Cengiz Avcı. According to findings in the investigation, Avcı generated approximately 15 billion lira in profits solely through ODINE shares over the past year, of which approximately 12 billion lira was converted to cash and withdrawn from the capital markets. It has been confirmed that Avcı left the country following these transactions and remains abroad. Asset seizure measures have been applied to Avcı’s bank accounts, movable and immovable properties, and other identified assets.

Within the scope of the investigation, the assets of Melis Sütşurup and her father Cihan Sütşurup have been seized, and arrest warrants have been issued for both suspects.

On 29 September 2026, the Istanbul Public Prosecutor’s Office issued the following statement: “Under the fund investigation conducted by the Istanbul Public Prosecutor’s Office’s Unit for Investigating Terrorism Financing and Money Laundering, letters have been sent to relevant institutions ordering the freezing of all assets belonging to Ilyas Kaya and his spouse Fatma Betül Sayan Kaya.”

Minister of Justice Akın Gürlek made a statement on his NSosyal account on 30 September 2026 under the title “Our citizen’s rights will be protected, and those who manipulate markets will be held accountable under the law.” Gürlek stated: “The determination of our President, Mr. Recep Tayyip Erdoğan, to protect the rights of our investor citizens and strengthen the secure and healthy functioning of capital markets is clear. As the Ministry of Justice, we are resolutely fulfilling all our responsibilities to protect our citizens’ rights without compromising the supremacy of law.”

Gürlek continued: “In the fund investigations conducted by the Istanbul Public Prosecutor’s Office’s Unit for Investigating Money Laundering, a fifth wave operation was carried out today, resulting in search, seizure, and detention orders against 34 suspects. Thus, the total number of suspects investigated to date has reached 217, 56 suspects have been detained, and 88 suspects are under judicial supervision. The scope of the investigations is not limited to current funds and suspects. Movements in 26 securities deemed to have been subject to speculative and manipulative transactions are being examined in detail, and the transaction histories, fund flows, and connections of individuals and accounts that achieved abnormal returns in a short period are also being investigated.”

Gürlek stated that the trail of unjust gains will be followed to its end: “Legal procedures will be initiated to transfer asset values identified as derived from illegal activities to a fund to be established under the Savings Deposit Insurance Fund (TMSF), in accordance with legal procedures.”^[9] No legal provisions or details regarding the establishment of this fund are provided in the documents.

According to a report by Demirören News Agency, 21 individuals, including Erdin Özel, Chairman of the Board of Tera Portfolio Management, and Emir Münir Sarpyener, were taken into custody during this operation.

During the investigation, information was obtained indicating that singer Nil Özalp possessed documents belonging to Muhammed Yarız, Chairman of the Board of Pusula Portfolio Management. On 30 September 2026, Özalp was taken into custody by officers from the Directorate of Combating Financial Crimes and a search was conducted at her residence in Kağıthane.

As part of the investigation, former Capital Markets Board Chairman İbrahim Ömer Gönül has been summoned for questioning.

The investigations of 12 suspects taken into custody have been completed at the police station; following medical examinations, Altuğ Kantarcı, Özgür Akayoğlu, Kerim Tosun, Nuray Elmastaş, Azize Binnur Tosun, Ali Çil, Tuğba Hicran Ataseven, Duygu Somay, İskender Balcı, İsmet Öğüt, Tolga Tuğtekin, and Adem Karatepe were brought to the Istanbul Courthouse in Çağlayan. The investigations of 20 suspects taken into custody are ongoing.

The investigations of Emir Münir Sarpyener, Tera Investment’s Chief Executive Officer (CEO), Erdin Özel, Chairman of the Board of Tera Portfolio Management, and Fatmagül Lafçı, along with Bolkan Bekçi, Hasan Dörtkardeş, and İbrahim Halil Rat, were completed at the Istanbul Police Department’s Directorate of Combating Financial Crimes on 30 September, and the suspects were referred to court.

The prosecution requested detention for Bekçi, Dörtkardeş, Rat, Sarpyener, and Özel, and judicial supervision for Lafçı. The court ruled in accordance with the request, ordering the detention of five suspects and applying judicial supervision to Lafçı. As a result, the number of detained suspects in the investigation has risen to 61.

The Capital Markets Board has decided to temporarily suspend the capital markets activities of Tera Investment Securities Inc. effective 18:10 on 30 September 2026. The Board also decided to permanently revoke the licenses of Emir Münir Sarpyener, Hayriye Car, and Hakan Gövdere, who were found responsible for unlawful transactions carried out by Tera Investment Securities Inc.

The Capital Markets Board has established an additional liquidation procedure for funds established by Tera, Pusula, Atlas, and Hedef Portfolio Management Inc. currently undergoing liquidation. Accordingly, interim payments will be made immediately to all unit holders who have completed reconciliation procedures, to be offset against their final entitlements upon liquidation. The principles of the interim payment are as follows:

● In calculating interim payments, the net investment amounts determined by the MKK for each beneficiary under the reconciliation results will be used.

● The interim payment amount for each investor per fund will not exceed one million lira: investors with a net investment amount below one million lira will receive the full amount; those with a net investment amount of one million lira or more will receive a maximum of one million lira.

● No unit redemption will be made in exchange for the interim payment; units will be redeemed during the final liquidation payments.

● The additional liquidation procedure will be implemented first for money market funds.

The Capital Markets Board has also made decisions regarding funds established by A1 Capital, Bulls, and Pardus Portfolio Management Inc. listed for liquidation:

● The liquidation process will begin with funds containing the term “money market” in their names and proceed in order from the fund with the highest number of investors to the lowest.

● Funds not included in liquidation but closed for trading on TEFAS and non-TEFAS distribution channels pursuant to the Board’s decision of 17 September will be reopened simultaneously across all distribution channels after the completion of the liquidation process. The reopening date and trading conditions will be determined by the respective fund promoters, taking into account portfolio structure, liquidity, market conditions, and investor interests.

● Funds not included in liquidation but closed for trading, which have engaged in capital market transactions with funds under liquidation, may be reopened for trading across all distribution channels by the bank assigned to liquidation, without waiting for the completion of the liquidation process.

On 1 October 2026, the Capital Markets Board published a notice on its website titled “Announcement Regarding Voluntary Refund Accounts.” The notice stated: “In accordance with Law No. 6362 on Capital Markets and related regulations, for investment funds included in liquidation, voluntary refund accounts have been opened under the name of the Savings Deposit Insurance Fund (TMSF) at Birleşik Fon Bankası for individuals who, prior to the liquidation decision, realized excessive gains through the sale of participation units and wish to voluntarily return such gains to the relevant fund.”

According to the announcement, amounts deposited voluntarily will be included solely in the liquidation assets of the relevant fund and cannot be transferred to any other fund or account. These amounts will be transferred to Ziraat Bank and Türkiye İş Bankası, the banks assigned to liquidation, for distribution to participation unit holders. The announcement further stated: “Additionally, to accommodate requests from individuals who wish to return excessive profits earned through trading shares of publicly traded companies or similar transactions, a ‘General Share Refund Account’ has been opened under the name of the Savings Deposit Insurance Fund at Birleşik Fon Bankası.”

President of the Presidency State Audit Board (SAB), Salih Tanrıkulu, stated on his NSosyal account on 29 September 2026: “Following the instructions of our President, Mr. Recep Tayyip Erdoğan, the State Audit Board has initiated review and audit activities to examine whether investment fund operations and oversight activities in the capital markets have been conducted in compliance with regulations and to ensure the implementation of necessary administrative and legal measures.” This process is separate from the criminal investigation and the Capital Markets Board’s administrative actions and is being conducted by the audit body under the Presidency.

According to the 29 September statement by the Presidency Communications Director Burhanettin Duran, the Fund Coordination Council, established under the chairmanship of the Vice President of the Presidency, will coordinate the liquidation process to ensure it is conducted swiftly and healthily while safeguarding investors’ legitimate rights and the public interest.

In his social media statement, Duran said: “Actions that harm our nation’s rights and undermine the healthy functioning of markets will not go unpunished; those responsible will be held accountable under the law regardless of their position.” He added: “The essential issue is the full and unwavering implementation of the law and the protection of our citizens’ rights.”

Duran also stated: “While our President underscores this reality, he has clearly stated that those responsible will be held accountable under the law. Therefore, preserving financial stability and resolutely pursuing the legal process are not alternatives but two fundamental elements of the same approach. While relevant institutions implement necessary measures against liquidity and contagion risks, investigations and inquiries into market-distorting transactions continue, and new administrative and legal regulations are being prepared as needed.”

Duran further noted: “The fact that our President, Mr. Recep Tayyip Erdoğan, closely monitors the process and that economic institutions act in unison toward the same goal demonstrates that this matter is not being addressed solely in terms of current victims. Attempts to drag this issue into political polemics and perception debates cannot cast doubt on our determination to uphold the rule of law and protect our citizens’ rights. What matters in this matter is not rhetoric but the law, transparency, and our nation’s rights.”

On 29 September 2026, in a written statement, MHP General Chairman Devlet Bahçeli reported that following a meeting with economic institutions on the same day, President Erdoğan said: “We have no business with those who lay hands on the nation’s property; our government is in control, we have made important decisions, and we are moving forward on this issue with all our institutions.” Bahçeli emphasized the need to take necessary measures to prevent similar harm to vulnerable investors.

Bahçeli stated: “When our President delivered his speech at the 81st UN General Assembly, which made our nation proud and earned worldwide admiration for defending justice and rights, the attack process accelerated immediately after the party spokesperson announced his candidacy. While corruption and immorality in municipalities have reached alarming levels, those who remained silent are now continuously creating an agenda around this issue, attempting to destabilize markets as an open attack against the People’s Alliance. Whoever has laid hands on public property or the rights of orphans must undoubtedly answer for it under the law. We welcome the government’s resolute approach to this matter and support the decisions taken. In this regard, we stand behind our President and our government.”

Bahçeli concluded his statement: “It must be prevented that this incident is turned into an attack or slander against our President and the People’s Alliance. As we have repeatedly stated, politics must be cleansed and purified; no one should remain under suspicion, while those responsible must answer under the law. The MHP is determined to defend our nation’s rights and laws to the very end. Our nation can rest assured: our economy is secure, our institutions are fulfilling their duties, and there is no reason for concern.”

President Recep Tayyip Erdoğan, in his speech on 1 October 2026 at the opening of the 28th Term, 5th Legislative Year of the Grand National Assembly of Türkiye, addressed the fund issue as follows: “We are successfully overcoming the problems that have emerged in a certain segment of the fund market. We are swiftly resolving this matter in strict compliance with capital market rules, ensuring fairness and justice without infringing on anyone’s rights. We will not allow this issue to become a threat to our economic security or social peace.”

Minister Mehmet Şimşek, in his NSosyal post on 1 October 2026, stated: “Our institutions are diligently and coordinately continuing their work on problematic funds. Necessary steps are being taken to enable payments to investors in the shortest possible time and at the highest possible level.”

Şimşek emphasized that the Ministry of Justice is resolutely pursuing the legal process to protect investors’ rights and ensure accountability. He added: “Our growth rate is nearly double that of our trade partners, and our current account deficit as a percentage of national income remains sustainable at 2.6%. The ratio of our long-term gross external financing needs to GDP stands at 16%, well below the long-term average of 20%. Our gross external debt as a percentage of national income is at 32%, significantly below the long-term average of 44.5%. Our budget deficit as a percentage of national income is approximately 3%, half the average for emerging markets, and our public debt as a percentage of GDP is at 22%, one-third of the emerging market average. Strengthened macroeconomic foundations and the measures taken will ensure that the impact of recent developments on the financial system and real economy remains limited. Our capital markets will emerge stronger, healthier, and more resilient as a result of the measures adopted.”

The Capital Markets Board (SPK) announced its new decisions regarding funds in the liquidation process on 1 October 2026 on its website.

The SPK has established an additional liquidation procedure for funds managed by Tera, Pusula, Atlas and Hedef Portföy Yönetimi AŞ, in accordance with the general principles of the liquidation process. Under this framework, an interim payment will be made immediately to all unit holders whose consent procedures have been completed in funds undergoing liquidation, to be offset against their final entitlements upon liquidation. The key elements of the decision are as follows:

● In calculating interim payments, the net investment amounts determined by the Central Registry Agency AŞ (MKK) for each rights holder under the consent results will be used.

● The interim payment amount for each investor per fund will not exceed one million Turkish liras. Investors with a net investment amount below one million liras will receive the full amount, while those with a net investment amount of one million liras or more will receive a maximum of one million liras.

● No unit redemption will be carried out in exchange for the interim payment; units will be redeemed during the final liquidation payments.

● The additional liquidation procedure will be implemented first for money market funds.

The SPK has also made decisions regarding funds managed by A1 Capital, Bulls and Pardus Portföy Yönetimi AŞ, which are listed for liquidation:

● The liquidation process will commence with funds whose titles include the term “money market” and will proceed in order of funds ranked from the highest to the lowest number of investors.

● Funds that are not included in the liquidation process but had their trading suspended on 17 September pursuant to the SPK’s decisions may be reopened for trading across all distribution channels simultaneously after the completion of the liquidation process. The reopening date and trading terms will be determined by the respective fund managers, taking into account the fund portfolio structure, liquidity, market conditions and investor interests.

● To ensure the healthy and prompt execution of liquidation procedures, funds that are not part of the liquidation process but were closed for trading and have engaged in capital market transactions with funds under liquidation may be reopened for trading across all distribution channels by the bank assigned to manage liquidation, without waiting for the completion of the liquidation process.

The hearings of the 13 suspects arrested and brought to the Istanbul Courthouse in Çağlayan as part of the investigation were completed on 1 October. The judge ruled to detain Ali Çil, İskender Balcı, İsmet Öğüt and Adem Karatepe. Altuğ Kantarcı, Kerim Tosun, Özgür Akayoğlu, Mesut Altan, Tuğba Hicran Ataseven, Duygu Somay, Nuray Elmastaş, Azize Binnur Tosun and Tolga Tuğtekin were released under judicial supervision. With these rulings, the total number of detainees in the investigation has reached 65.

The investigations of 19 suspects detained as part of the investigation were completed on 2 October 2026. After medical checks, the suspects were transferred to the Istanbul Courthouse in Çağlayan. The names of the suspects transferred to the courthouse are as follows: Ali Serhat Tüzün, Ali Yöney, Alper Tunga Sagu Burak, Burak Sevindik, Fırat Kerim Ersoy, Gökhan Koçyiğit, Gürsel Akça, İdris Çakır, Jeremy Etienne Debost, Tahir Fatih Mutlu, Mücahit Acaralp, Nil Özalp, Tuncer Köklü, Yasemin Yavuz Koçyiğit, Ali Göl, Hüseyin Emre Güner, İhsan Çimen, Mesut Yalım and Osman Sungur.

Vice President Cevdet Yılmaz responded to journalists’ questions on 1 October 2026 at a reception hosted by TBMM Speaker Numan Kurtulmuş to mark the beginning of the new legislative year. Yılmaz noted that important decisions were made at the previous meeting of the Fund Coordination Board, established by President Erdoğan, and stated: “Each of our institutions makes its own decisions within its domain and shares them with the public. Today, important decisions by the SPK and the Banking Regulation and Supervision Agency (BDDK) were shared. Tomorrow our agenda will be ‘what additional measures can be taken and where further work is needed’, which we will evaluate together with our Board. We will then issue a press statement, God willing.” The content of the BDDK decisions referenced by Yılmaz and the date of the Board’s first meeting are not provided in the documents.

In response to a question regarding the payment schedule, Yılmaz replied: “Statements will be made to the public after the meeting. Both the Coordination Board and each of our institutions have their own authority. These are independent regulatory bodies. We must wait for the statements from our institutions regarding their own decisions.”

According to the announcement by the Presidency of Communications, the Second Fund Coordination Board Meeting was held on 2 October 2026 under the chairmanship of Vice President Cevdet Yılmaz. The announcement included the following statements: “During the meeting, the relevant institutions’ work on the method for calculating net investment amounts, as defined by the SPK’s 30 September 2026 decisions, and secondary adjustments regarding the payment decision taken by the Board on the same date were evaluated. Subsequently, work was carried out on the draft Bill on Amendments to the Capital Markets Law, which has been under development for some time, and necessary instructions were issued to relevant institutions and organizations for finalizing the draft. A clear understanding was emphasized in all discussed regulations that no additional burden should be imposed on our citizens. The relevant institutions will continue their necessary efforts swiftly and effectively within the framework of capital market regulations to resolve the issue that has emerged in a specific and limited segment of the fund market, with fairness and justice being upheld.”

Minister Mehmet Şimşek participated remotely in the S&P Global Conference on Emerging Markets on 1 October 2026 and made the following remarks regarding the fund market: “We moved very quickly and placed problematic fund management companies and related funds under quarantine. The process of liquidating and resolving these funds has begun. Our objective here was to prevent contagion from spreading to the rest of the system, and we believe we have been largely successful in achieving this. Of course, there was a limited impact, but we are not talking about a systemic problem. We will continue deepening the capital markets.”

Under the investigation conducted by the Istanbul Public Prosecutor’s Office for Terrorism Financing and Money Laundering, the 20 suspects detained and referred to the Istanbul Courthouse on 2 October 2026 have completed their proceedings before the peace criminal judge. At the request of the prosecution, the judge ordered the detention of Ali Serhat Tüzün, Ali Yöney, Alper Tunga Sagu Burak, Burak Sevindik, Fırat Kerim Ersoy, Gökhan Koçyiğit, Gürsel Akça, İdris Çakır, Jeremy Etienne Debost, Tahir Fatih Mutlu, Mücahit Acaralp, Nil Özalp, Tuncer Köklü, Yasemin Yavuz Koçyiğit, Ali Göl, Hüseyin Emre Güner, İhsan Çimen, Mesut Yalım, Osman Sungur and Erol Demirbaş. As a result, the number of detained individuals in the investigation has risen to 85.

Vice President Cevdet Yılmaz, during his briefing to the Grand National Assembly of Türkiye on 7 October 2026, described the measures taken regarding assets as follows: “Between 15 September and 2 October, in order to address investor losses and prevent the concealment of illicit proceeds, asset seizures were ordered on 21 movable and immovable properties belonging to 63 individuals and 12 legal entities. Seizures were carried out on bank, cryptocurrency and safe deposit box assets of 67 individuals and companies, and on equity stakes of 27 individuals and companies. Additionally, the assets of 42 individuals listed as investors were frozen based on fund exit dates and transaction ratios.”

Yılmaz also stated that all data requested regarding ownership claims related to the funds ordered for liquidation have been shared by the Central Registry Agency (CRA) with the Ministry of Justice, the Istanbul Public Prosecutor’s Office, the Ministry of Treasury and Finance, the Capital Markets Board, the Banking Regulation and Supervision Agency, MASAK and the Central Bank of Türkiye, as well as other relevant institutions. According to Yılmaz, under a decision by the Capital Markets Board, asset and cash outflows related to the funds ordered for liquidation are being conducted under the supervision of the Capital Markets Board and with the joint decision of the Central Registry Agency, Borsa Istanbul and Takasbank.

On 23 September, the court accepted the prosecutor’s request to seize the assets of 11 suspects, including Emre Tezmen, Chairman of the Board of Tera Investment Holding, and Muhammed Yarız, Chairman of the Board of Pusula Portfolio Management Inc. Assets of the suspects were seized accordingly. It was determined that five luxury vehicles belonging to detained suspect Muhammed Yarız were transferred to four different individuals for a total vehicle sale value of 26,280 lira. In response, the prosecution decided to seize the vehicles, whose market value is estimated at approximately 200–220 million lira. Four of the seized vehicles have been placed under custody, and a search operation has been launched for the missing vehicle. As part of the investigation, financial reviews have been initiated to determine whether funds or cryptocurrency assets were transferred abroad by the company executives and their first-degree relatives.

Justice Minister Akın Gürlek, in his statement on 6 October, stated that two days after the investigation began, the spouse of a detained individual issued a 40 million lira wire transfer order abroad, which was prevented. Gürlek also noted that legal proceedings have been initiated to recover the funds sent to Switzerland.

Capital Markets Board Chairman İbrahim Ömer Gönül has submitted a letter to the Ministry of Treasury and Finance requesting authorization to investigate him for the offense of “abuse of official duty” under the first paragraph of Article 113 of the Capital Markets Law.

The application submitted by Fatma Betül Sayan Kaya and her husband İlyas Kaya under the voluntary repayment method announced by the Capital Markets Board has been examined as part of the investigation. In letters sent by the Public Prosecutor’s Office to seven different banks, permission was requested to transfer the amounts indicated in the Kayas’ petitions to the account of Birleşik Fon Bankası AŞ Central Branch.

Fatma Betül Sayan Kaya and her husband İlyas Kaya were summoned for questioning on 7 October 2026. They appeared at the Istanbul Courthouse in Çağlayan and provided statements to the investigating prosecutor under the status of “suspect”. After approximately one hour of questioning, they left the courthouse.

On 8 October 2026, the Istanbul Public Prosecutor’s Office issued a statement indicating that all information, documents and reports obtained from the Capital Markets Board, Borsa Istanbul, the Central Registry Agency and other relevant institutions are being thoroughly reviewed. The statement included the following: “However, it has been observed that certain social media platforms and digital channels are disseminating claims regarding the investigation that do not reflect the truth, along with disinformation targeting individuals and institutions. The public dissemination of false information will be evaluated under the offense of ‘publicly disseminating misleading information’ as stipulated in Article 217/A of the Turkish Penal Code, and formal legal proceedings will be initiated against those responsible for such dissemination.”

Ali Emre Ballı (46), President of the Financial Institutions Union and Alternate Member of the Turkish Basketball Federation, was found dead in the driver’s seat of a vehicle in an empty plot of land in Çekmeköy, Istanbul on 6 October 2026. Responding to a report of an unresponsive person inside the vehicle, the dispatched team confirmed Ballı’s death. Initial examinations at the scene suggested that Ballı died from a gunshot wound, and an investigation has been launched to clarify all aspects of the incident. The final footage captured by surveillance cameras showing Ballı driving his vehicle with license plate 34 HKC 506 has also been released.

Justice Minister Akın Gürlek responded to questions regarding the fund investigation during his appearance on the Anadolu Agency Editor’s Desk program on 6 October 2026. Gürlek’s remarks on other topics during the same program fall outside the scope of this report.

In response to a question about how the investigation began, Gürlek stated that reports and complaints were received, and the Capital Markets Board granted the necessary investigation authorization, without which formal investigations could not proceed. Gürlek noted that during his tenure as Istanbul Public Prosecutor, in February 2025, unusual activity was detected in certain funds and shares, prompting official correspondence; in August 2026, complaints from citizens followed. Gürlek emphasized the need to distinguish between legitimate and illegitimate gains, noting the presence of abnormal, unjust profits generated through rapid buying and selling of so-called “balloon shares.”

Gürlek stated: “We noticed this activity, and our colleagues wrote to the Capital Markets Board requesting investigation authorization; I even met with them personally. Of course, our esteemed Minister also followed this process and made statements regarding the funds. The final investigation authorization was granted in response to the memorandum we submitted in August. Thus, the fund investigation began. The Public Prosecutor’s Office can only examine these offenses after receiving investigation authorization. There is currently an ongoing investigation. I wish to emphasize that the Turkish market and Turkish economy are very strong. They are our pride. We must not generalize a minor incident occurring in a small part of it.

Our President, Recep Tayyip Erdoğan, has been monitoring this process from the very beginning and receives real-time updates. We have held continuous consultations and meetings with our Minister of Treasury and Finance. Most recently, the Fund Coordination Board was established under the chairmanship of Vice President Cevdet Yılmaz. Our Minister of Treasury and Finance and we ourselves are members of this board. Daily routine operations remain entirely within the domain of the free market economy and are subject to the discretion of the boards. Our prosecutors examine matters based on received reports, complaints and granted investigation authorizations. There are ongoing processes.”

In response to a question regarding the depth of the investigation, Gürlek stated: “On 17 September, the Capital Markets Board decided to liquidate the funds. Upon that decision, our Public Prosecutor’s Office immediately implemented all preventive measures under the granted investigation authorizations. Currently, 85 suspects have been detained, proceedings have been initiated against 207 individuals, and the assets of many have been frozen. Our colleagues have also taken necessary measures to prevent asset concealment.”

Gürlek noted that the State Audit Board has also become involved, examining whether institutions have been negligent. He added that if negligence, fault, intent or malice is found, further actions will be taken against the institutions. Gürlek highlighted that through short-term speculative trading in closed or open funds, excessive profits were made. He stated: “We have already initiated investigations into these matters. We have the Capital Markets Board, Borsa Istanbul and the Central Registry Agency. Based on all lists received from them, the Istanbul Public Prosecutor’s Office has issued asset freeze orders against individuals and companies engaging in manipulative activities and generating excessive or abnormal profits in a short time. Some have been detained, others are fugitives. Travel bans abroad are in place. This is an ongoing process, entirely under the supervision of an independent judiciary.”

Gürlek stated that the Public Prosecutor’s Office acts based on lists provided by the Capital Markets Board, Borsa Istanbul and the Central Registry System. Regarding refunds, he reminded that the Capital Markets Board has decided to refund up to one million lira to good-faith investors. Gürlek continued: “Some individuals made rapid manipulative trades, entering and exiting with enormous sums in just two months, generating substantial profits. We have a list of these individuals. Many have been detained, and we have seized their assets. Based on the decisions of the newly established board and the Capital Markets Board, we have also seized personal assets, including those of portfolio managers and fund managers. A refund account has been opened at the Savings Deposit Insurance Fund under established principles, specifically for those wishing to voluntarily repay. I met with the President of the Savings Deposit Insurance Fund yesterday, and five individuals have already made repayments to these accounts.”

Gürlek stated that these assets have been legally transferred to the Savings Deposit Insurance Fund, which will subsequently submit the necessary documentation to the prosecutor’s office. Regarding effective repentance, he said: “Compensating twice the damage constitutes grounds for effective repentance, but this does not mean the investigation or file will be closed. It is merely a legal provision for mitigation. It is incorrect to assume that no action will be taken against those who compensate. Action will definitely be taken against them.”

Gürlek further stated: “We have information on individuals, legal entities and companies who made excessive profits in a short time. We have already taken steps. I want to make it clear: Our President has been very clear and explicit. We will pursue our rights to the fullest extent under the law against those who have exploited the public’s finances and gained unjust profits. We will transfer these unjust gains to a fund established by the Savings Deposit Insurance Fund. Subsequently, based on decisions made by the Capital Markets Board and the newly established board, we will compensate the losses of good-faith investors. However, under the law, we will certainly recover all concealed assets and money transfers. We have seized personal assets, imposed asset freezes, and placed liens on real estate. There are still ongoing investigations.”

Emphasizing the protection of citizens’ rights, Gürlek stated: “I assure our citizens unequivocally: Within the legal framework, we will do everything in our power to recover funds from those who made excessive profits in a short time through insider tips. We will fulfill our duties to protect our citizens’ rights.” and “We will remain vigilant to the very end in pursuing these matters under the law.”

In response to a question about whether state institutions have established a coordination mechanism, Gürlek stated: “Certainly. From the very beginning, we have maintained continuous consultation with our Minister of Treasury and Finance, and our President has monitored the process from the outset. We are in constant communication. The Fund Board has now been established, and we are participating. All state institutions are coordinating. I want to assure our citizens: They should feel at ease. The ongoing investigations will not affect our market, Borsa Istanbul or our investors. These are ongoing processes, but our Ministry of Treasury and Finance has also taken measures, as have our independent institutions. All state institutions are working together under the direct instructions of our President. I urge our citizens to maintain confidence in the Turkish economy, Turkish capital and our markets. The process continues. We are focused solely on the judicial process, while daily market operations continue under the independent oversight of other bodies.”

In response to a question about whether losses will be recovered from those who profited or from public funds or taxes, Gürlek replied: “There is absolutely no such thing. We must clearly distinguish between those who gained unjustly and those who earned legitimately. Our operations target fund owners and manipulators who have gained unjust profits. We have seized all their assets. We will pursue their unjust gains to the fullest extent and return them. We are already recovering them. We seize assets and transfer them to the Savings Deposit Insurance Fund.”

Thus, under the decisions of the Fund Board, no burden will be imposed on citizens who do not hold shares in these exchanges, stocks or funds. I am making this absolutely clear. We are determined to confront this issue regardless of who is involved or what their name is. Look, arrests have been made. We have seized all assets, including real estate. We will recover all assets that were taken or transferred, and we will transfer them to the Savings Deposit Insurance Fund. Under the legal rules of the Savings Deposit Insurance Fund and the decisions of the Fund Board, these assets will be compensated to good-faith investors. There is already an active process underway.”

Gürlek emphasized that they distinguish between those who made excessive and unjust profits through illegitimate means and those who entered the funds legitimately. He stated: “We are working within the legal framework to ensure that all these funds ultimately reach the treasury.”

AK Party Deputy Group Chair Özlem Zengin, during the Grand National Assembly of Türkiye session on 6 October 2026, addressed the investigation, referring to it as the “fund issue.” She stated: “Whoever acted wrongly, violated the law, exploited or embezzled our citizens’ money, must be held accountable before the law regardless of their political views, social connections, position or family ties.” Zengin emphasized that these individuals must be investigated and summoned for questioning, adding: “I also wish to state that tomorrow, under Internal Regulations Article 59, our Vice President will appear before the General Assembly and provide us with information.”

The AK Party Parliamentary Group, under the chairmanship of Group Chair Abdullah Güler, has established a working group to examine fund-related matters on the agenda. Based on evaluations by a group of lawyer-members of parliament, a law proposal regarding capital market operations has been prepared. The proposed temporary legislation, to be submitted to the Parliament Presidency in the coming days, is expected to consist of 10 articles and will address the liquidation of assets up to one million lira for 455,578 investors.

The goal of the proposal is to protect investors’ rights and ensure transparent implementation. The main provisions of the proposal are as follows:

● Each fund’s assets and true beneficiaries must be identified, fund assets must be liquidated without causing economic loss while prioritizing the collective interest of investors, and cash proceeds must be distributed fairly to beneficiaries.

● To enable comparison of historical cash flows with current values and to equitably compensate investor losses, an adjustment will be made based on the arithmetic average of the Consumer Price Index and Producer Price Index; exits will be offset using the “first in, first out” method.

● To prevent investors from receiving no payments until liquidation is complete, a maximum advance payment of one million lira per person will be made, without exceeding the net investment amount or confirmed claims.

● If available cash is insufficient to cover all claims, it will be distributed proportionally among current cash claimants, establishing a transparent and predictable method for equal-status investors. Payments will begin with the beneficiary having the lowest net investment amount, or a minimum advance payment amount may be set for all beneficiaries, as determined by the Capital Markets Board.

● A voluntary repayment mechanism will be established for individuals who exited funds before the liquidation date based on inflated values and gained profits above normal market returns, or who gained above-normal returns from shares whose prices were artificially inflated. To prevent arbitrary determination of repayment amounts, benchmark returns from similar funds aligned with the fund’s type and investment strategy, or other objective market indicators determined by the Capital Markets Board, will be used; these funds will not be included in benchmark calculations. Repayments will be based on voluntary participation.

● Values transferred to parties or third parties through fraudulent or gratuitous loans, debts, advances, guarantees, transfers, assignments, purchases, sales, repos, reverse repos and similar transactions will remain linked to the fund’s assets.

● The fund’s founder and manager, and the portfolio management company, will be held personally liable; if this is insufficient, individuals and legal entities determined to be responsible for losses or incomplete liquidation will also be held personally liable.

● Assets seized or confiscated during criminal investigations or prosecutions may be used to compensate investor losses. For assets that cannot be directly transferred to the fund, the Savings Deposit Insurance Fund, acting as receiver, will conduct sales or liquidation to convert economic value into cash and rapidly transfer it to the relevant funds.

The proposal aims to protect investors’ rights to the highest possible extent and as quickly as possible, ensuring that liquidation and recovery operations are conducted with legal certainty, accountability and inter-institutional coordination.

Vice President Cevdet Yılmaz provided a government briefing on the Fund Coordination Board’s activities to the Grand National Assembly of Türkiye on 7 October 2026. Following the speech, and in accordance with a recommendation from the Advisory Council, representatives of political parties delivered statements, and Yılmaz answered questions from members of parliament.

Yılmaz stated that the foundations of the economy remain strong, with the budget deficit at approximately 3 percent of national income despite earthquake expenditures, and the current account deficit at 2.6 percent of national income despite negative impacts from regional conflicts, particularly on oil prices. He noted that the Central Bank’s reserves have ensured protection against external shocks, the banking system maintains a reliable structure with high capital adequacy ratios, and there is no systemic risk in financial markets. Yılmaz added: “Our capital markets structure is sound. The liquidation of problematic funds will not weaken our capital markets; rather, our capital markets, freed from potential risks, will continue on a stronger path.”

Yılmaz commented on media and social media approaches to the issue: “I would like to briefly assess the approach to this issue through you, our parliamentarians. Let us not exaggerate or minimize the problem. Let us be realistic and base our commentary on accurate information. Otherwise, we will harm funds and investors that have no connection to the problem. While treating and eliminating diseased elements from the body, we must not harm the body itself. I believe we share collective responsibility for the impact of these developments on affected companies and millions of investors. I wish to emphasize that Türkiye will never retreat from its goal of expanding and deepening its capital markets, a fundamental component of our development process. We will persistently work toward building a stronger capital market structure that encourages savings to flow into production and investment, provides confidence to investors and diversifies financing options. In this process, we will protect our citizens’ rights, ensure the market operates securely, and implement necessary regulations without delay.”

Yılmaz further stated: “As clearly stated by our President, anyone who is responsible and has gained unjust profits through speculation and manipulation will be held accountable under the rule of law. Anyone engaging in unlawful actions will bear the consequences. Every detail of the issue in our capital markets has been closely monitored since the beginning by our competent judicial and administrative institutions, concrete measures have been taken, and necessary steps have been implemented.” Another statement by Yılmaz was: “We will not unjustly accuse anyone through hasty or insufficiently informed approaches. While protecting the rights of our investors, capital markets and nation, we will continue our most effective struggle against manipulators and speculators.”

Yılmaz reported that as of 5 October 2026, the total portfolio value of funds under liquidation represented 2.4 percent of household financial assets. He added: “The 131 funds under liquidation constitute 4.6 percent of the total number of funds and 7.7 percent of the total portfolio value. In other words, the problem has occurred in a limited segment of the fund market. Türkiye’s financial system is strong, our capital markets continue to develop, and our fundamental policy in this area remains unchanged. However, the fact that the problem emerged in a limited area does not diminish its importance. Under the principles of the rule of law, we are determined to address transactions that affect our citizens’ savings, undermine market confidence, or lead to unjust gains. While taking steps to protect the rights of those adversely affected, we are also evaluating necessary administrative and legal measures to prevent recurrence of similar problems.”

Another key point I wish to emphasize: state treasury resources will not be used to compensate for private losses incurred in this process. There is no state guarantee in the fund market, especially for high-risk free funds, unlike in our banking system. Every investor entering free funds signs a Professional Customer and Qualified Investor Request Form. Entry requires at least 10 million lira in financial assets, and investors accept the high risk of loss proportional to their high return expectations. The primary principle in the liquidation process is to meet investors’ rights using the fund’s own resources. In the liquidation process, priority will be given to using the fund’s existing resources. Additionally, resources recovered from those who gained excessive or unjust profits and proceeds from the sale of assets removed from the system will be utilized.”

Yılmaz recalled that, under the instructions of President Erdoğan, the “Fund Coordination Board” was established on 29 September to ensure the rapid implementation of the liquidation process while safeguarding the legitimate rights of fund investors and the public interest. According to Yılmaz, the Board has worked intensively, established a roadmap and fundamental principles, and relevant institutions have begun taking concrete steps within their respective jurisdictions under coordinated efforts. Yılmaz noted that most of these institutions are independent regulatory and supervisory authorities that make their own decisions under the law; the Board ensures overall coordination, accelerates inter-institutional cooperation, identifies common principles, and provides technical support to institutions on matters requiring legal amendments, collaborating with the AK Party Parliamentary Group.

Yılmaz stated that instructions have been issued to relevant institutions to finalize the draft law proposal, which was comprehensively reviewed at the third meeting of the Board and will be submitted to Parliament through the AK Party Group in its final technical form. Yılmaz said: “In all proposals and regulations considered, the principle of not imposing any additional burden on our citizens and nation has been clearly emphasized.”

Yılmaz outlined the main framework of the liquidation process as follows: “The process will be conducted transparently, fairly, effectively and as rapidly as possible. By rapid, I mean fast and accurate. It will be carried out as quickly as possible without compromising accuracy. State treasury resources will not be used. Each fund will act based on its own resources and funds deposited into its accounts. The general principle is to distribute payments to investors proportionally to their holdings; this is a legal principle. For funds subject to extraordinary liquidation, advance payments will be made to return principal amounts up to one million lira. Priority will be given to small investors and money market funds in making payments.”

Yılmaz pointed out that the Madoff scandal in the United States in 2008, the Jiwasraya crisis in Indonesia in 2018 and the Lime crisis in South Korea in 2019 demonstrated that market-disrupting activities can occur even in advanced economies with strong oversight mechanisms. He stated: “Problems can arise in financial markets at various times for different reasons. The key is to detect these market-disrupting structures as quickly as possible and liquidate them most effectively. In our case, the responsibilities of our institutions and independent regulatory and supervisory authorities will be clarified through comprehensive investigations initiated by the State Audit Board. There are detailed laws and procedures established by our Parliament regarding independent regulatory and supervisory bodies. These procedures will certainly be followed. Our President has assigned the State Audit Board this task. Currently, 10 inspectors are actively conducting these investigations in the field.”

Yılmaz noted that various steps had already been taken before this process, and had these steps not been taken, problematic funds would have continued to grow, leading to a larger problem than the current one.

Yılmaz indicated that in response to problems emerging in mid-September, the Ministry of Treasury and Finance, the Ministry of Justice, the Capital Markets Board and the Banking Regulation and Supervision Agency swiftly took action. On 16 September, a two-year trading ban was imposed on certain individuals and portfolio management companies, and licenses of some were revoked. On 17 September, the Financial Stability Committee convened and adopted decisions to prevent the problem from spreading to other funds and the financial system, and the Central Bank of Türkiye provided additional liquidity to the market.

Yılmaz explained that the Capital Markets Board decided to liquidate 131 funds belonging to seven portfolio management companies to reduce systemic risk, adding: “Other funds belonging to these companies have also been suspended from trading on TEFAS. In effect, problematic and potentially problematic funds have been quarantined to prevent system-wide impact. The Banking Regulation and Supervision Agency has decided to transfer three banks (Tera Investment, Destek Investment and Hedef Investment) and two factoring companies (Destek Finance Factoring and Tera Finance Factoring) belonging to problematic groups to the Savings Deposit Insurance Fund, and these transfers have been completed. The process of acquiring Katılımevim, Birevim and İktisat Participation Bank by Emlak Participation Bank has been initiated. While independent administrative authorities took these steps, judicial processes also swiftly and effectively came into effect.”

Yılmaz outlined the following regarding the liquidation process: “For the seven companies and 131 funds under liquidation by the Capital Markets Board, Ziraat and İş Bank have been designated to manage the liquidation process. To date, İş Bank has managed the liquidation of six funds under TERA, and Ziraat Bank will manage the liquidation of the remaining 125 funds. Control of investors’ share certificates, verification of cash and liquid assets, identification of debts and receivables, and determination of the actual status of fund assets have been completed. The official custody activities of the relevant banks have been formally assumed. A1 Capital, Bulls and Pardus will begin the ordinary liquidation process. We anticipate that 17 funds will be liquidated under this process, and investors in these 17 funds will receive payments.”

Yılmaz stated that after completion of Central Registry Agency data, the extraordinary liquidation process will begin for the remaining four companies and their underlying funds, adding: “Work is also underway on the ordinary liquidation of the Atlas company. If an agreement is reached, the Atlas company will also pay investors’ rights under ordinary liquidation rules, leaving only three companies remaining.” According to Yılmaz, the essence of extraordinary liquidation is the repayment of principal amounts up to one million lira; efforts will continue to collect fund receivables and settle debts, and the final liquidation balance will be settled within a period of five to six months. Yılmaz continued: “These advance payments will be offset against the final settlement. If the draft law proposal on extraordinary liquidation submitted to Parliament is enacted, we anticipate that principal repayments up to one million lira can be made within October. The Capital Markets Board will issue necessary detailed decisions. Technical preparations have been completed.”

The investor and fund numbers reported by Yılmaz are as follows:

Regarding the three companies scheduled for ordinary liquidation, Yılmaz stated: “Among the 49 special funds under these companies, there are 2,098 individuals, and their issues are planned to be resolved within their own frameworks. If the required guarantees are obtained, payments will be made immediately to the 56,614 individuals covered by the 16 funds under the Atlas company under ordinary liquidation rules.”

Yılmaz stated that under extraordinary liquidation, advance payments will be made as offsets against entitlements, based on the net investment amount calculated by the Central Registry Agency, with a maximum advance payment of one million lira. According to Yılmaz, under a Capital Markets Board decision, 131 voluntary refund accounts and one general share refund account have been opened within the Savings Deposit Insurance Fund. Resources generated in each fund will be used for its creditors; resources allocated to the general account will be distributed among funds according to calculation methods determined by the Capital Markets Board using various criteria. Proceeds from the sale of seized or confiscated assets will also be transferred to the recovery account for use in payments.

Yılmaz emphasized that ownership rights will be determined on a fund and account basis, stating: “With the implementation of ordinary and extraordinary liquidations in October, a large portion of the 455,758 investors will have received their payments. I believe our Parliament, taking into account investors’ expectations, will promptly address this law. Of course, the final decision rests with our Parliament. The points I have presented regarding extraordinary liquidation will be finalized only after the law text is adopted by our esteemed Parliament. All technical preparations have been completed. Once the law enters into force, the necessary actions will be taken immediately.”

Our state is managing this process with an approach centered on protecting our citizens’ rights, maintaining market confidence, and fully implementing the rule of law. While taking necessary steps to protect the rights of investors entitled under the liquidated funds, we will ensure that those who gained unjust profits and disrupted market order are held accountable under the law. At the same time, we are determined to transform this experience into an opportunity to further strengthen the functioning of our capital markets. We are also continuing work on a law addressing certain structural issues. However, we believe it is more appropriate for our Parliament to review this preparation after the State Audit Board’s report.”

Yılmaz stated: “These events must not be attributed to any funds or other instruments in our capital markets that have not engaged in these unlawful practices.” and “There is no systemic risk in our markets. Unnecessary discussions in social media and the media that harm millions of our citizens regarding our capital markets and stock exchange serve no purpose.” Yılmaz concluded his speech with these words: “Türkiye’s financial system is strong, and our determination regarding the future of our capital markets is clear. Under the leadership of our President, we will continue our determined efforts to build deeper and stronger capital markets where our citizens can safely invest their savings and which support production and investment. In this process, we will adhere to the rule of law and the legitimate sensitivities of our nation, leave no abuse unpunished, and strive to protect the rights of our citizens and investors to the fullest extent.”

In response to criticism regarding the participation of AK Party members and the AK Party Parliamentary Group in the Fund Coordination Board meeting, Yılmaz stated that he personally invited AK Party Group Chair Abdullah Güler and Deputy Chairs Efkan Ala and Mustafa Elitaş to the meeting. Yılmaz noted that under the Presidential Government System, the government does not have direct authority to propose laws, only to submit the budget law, stating: “Therefore, if a law proposal is to be made, we must work with our parliamentary group. If there is a discussion on legal regulation, we must conduct this work together with our party group. For this reason, we invite our colleagues. We discuss with them. This is the structure of the new system.”

Reiterating that the nation’s resources will not be used in the fund liquidation process, Yılmaz stated: “However, the funds’ own resources and amounts recovered from unjust gains obtained through inflated prices and excessive profits will be used. Additionally, assets and real estate seized due to illegal activities will be evaluated and returned to investors as much as possible. In extraordinary liquidation, our approach focuses on the principal amount. I wish to emphasize this point: We are discussing certain figures, but what matters is the size of the money originally invested in the system. Values artificially inflated through manipulation do not reflect the true loss. What matters is the original principal and its corresponding value. We are making every effort in this regard.”

Regarding criticism about senior public officials serving on various boards, Yılmaz stated: “This is not a legal issue but has been raised as a potential concern. As one of the steps to improve the system, we should perhaps discuss these issues for the future. I am not accusing anyone. Please do not misunderstand. Personally, I also trust our State Audit Board Chairman. He does not conduct the audits himself; the inspectors do. However, I wish to emphasize that this is a topic worth considering for future frameworks.”

According to the Capital Markets Board bulletin, taking into account developments in the Borsa Istanbul markets, the Board decided to extend the measure introduced on 17 September regarding the relaxation of the own capital ratio requirement for credit-based capital market transactions until the end of the trading session on 30 October, in order to ensure the reliable, transparent and stable operation of capital markets and protect investors’ rights and interests.

The Capital Markets Board clarified that claims circulating in some media outlets and social media accounts that the provision regarding the protection of the Investor Compensation Center (ICC) assets was first established in July 2026 are entirely baseless and intended to mislead the public. The statement included: “Contrary to these false and misleading claims, the provision regarding the protection of ICC assets was not first established in July 2026. This provision has been in the Capital Markets Law since 30 December 2012 and in the ICC regulations since 6 June 2013.”

The Capital Markets Board responded to claims that Borsa Istanbul issued 130 warnings since 2025 regarding suspicious funds and that the Board ignored them. The Board stated that it carefully evaluates all notifications received from Borsa Istanbul and “Our Board takes into account information notes transmitted electronically by Borsa Istanbul and applies necessary sanctions against relevant parties.” The statement noted that the number of information notes related to the funds in question does not reflect the truth.

The Capital Markets Board shared the following information regarding administrative fines and criminal reports: “As a result of our inspections, we imposed administrative fines totaling 2 billion 741 million lira in 2025 and 948 million lira in the first nine months of 2026 on individuals and legal entities. We filed criminal reports against 152 individuals in 2025 and 174 individuals since the beginning of 2026. 96 of the criminal reports filed in 2026 were related to fund operations.”

The “Regulation on Amendments to the Regulation on Measures to Prevent Money Laundering and Terrorist Financing,” prepared by the Financial Crimes Investigation Board (MASAK) of the Ministry of Treasury and Finance, was published in the Official Gazette on 7 October 2026 and entered into force. The monetary thresholds applied under the obligation to identify customers, last determined on 14 January 2023, have been revised. Accordingly, the transaction amount requiring collection of customer identification information has been raised from 185,000 lira to 370,000 lira, and the threshold for electronic fund transfers (EFT) and cryptocurrency transfers has been raised from 15,000 lira to 30,000 lira. The requirement to obtain a signature sample for previously identified customers has been removed when their identity can be verified through internet banking, mobile banking or similar secure authentication methods.

Alpaslan Çakar, Chairman of the Board of the Turkish Banks Association (TBB), responded to questions regarding the fund investigation during a press conference titled “Financing the Transformation: Towards COP31.” In response to a question about whether the increase in the 4.5 percent growth limit for SME loans by the Central Bank of Türkiye to 5 percent was related to the fund investigation, Çakar stated that the fund issue occurred in a limited area and involved mostly individuals, adding: “There was already a need in the market recently, as the biggest problem in accessing liquidity was for SMEs. Large entities did not face significant issues in this regard. This was an expected development. Therefore, it has no connection to the fund issue. There were already decisions made before the fund investigation to ease liquidity. We can consider these as continuations of those decisions.”

In response to a question about the impact of the investigation on the banking sector, Çakar stated: “We never expect any negative impact on the banking sector. It is the same market. Where did the money that left go? It entered the banking sector. Therefore, the money remained within the system. Hence, a negative impact on the banking sector is not conceivable.”

MHP General Chairman Devlet Bahçeli, in his written statement on 3 October 2026, addressed not only the costs faced by the Turkish economy and allegations of corruption in municipalities but also the fund investigation. Bahçeli stated that developments in the fund investigation indicate that a narrow group manipulated the market through violations of the law, adding: “It is clear from the statements of state institutions and authorized officials that the situation has been assessed, a roadmap has been determined to identify those who committed crimes and to address victims’ losses, and implementation has begun. Turkey’s economic stability depends on financial stability. The financial system is built on trust. When our citizens, especially small investors, invest their money in banks or capital market instruments, they are expressing their trust not only in the financial product but also in the financial system and the institutional structure that manages and supervises it. Therefore, the damage caused by allegations of manipulation in financial markets is not limited to investors who lost money. Loss of trust can affect the entire market, related institutions and the economy as a whole.”

Bahçeli continued: “Questioning whether an effective mechanism exists to guarantee this will elevate the issue from an economic matter to a systemic and governance problem, as well as a matter of social trust. It is natural for investors to seek returns on their savings through legitimate means in financial markets. Some investors’ willingness to take risks is their own choice. The key issue here is whether unlawful acts such as market-disrupting operations, manipulation, fraud and abuse of trust occurred during the management of these funds. Undoubtedly, while the fund market is an area where savings owners seek returns, it also closely affects the overall confidence and stability of the economy.”

Bahçeli noted that the problem in Türkiye stems not from rules but from implementation, with deficiencies, shortcomings and inadequacies in supervision and oversight being at the core of the issue. He stated: “Therefore, legal, administrative and structural measures must be taken to establish and maintain a financial system in which investors can have confidence. Publicly disclosed confessions indicate that in municipalities, corruption and bribery are operating openly through demands and collapse. The events in the fund market, however, involve hidden manipulations and are based on voluntary savings.”

Bahçeli also stated in his statement: “Türkiye must not be placed in a situation of social erosion of trust and decay due to developments such as corruption, irregularities and favoritism. These should be viewed as opportunities for purification, cleansing and addressing underlying causes.” and “Therefore, wherever and whoever is involved, if there is corruption, irregularity, misuse of public property, violation of rules or similar offenses, action must be taken under the law without regard to the nature of the offense or the identity or status of the accused.”

AK Party Deputy Chairman and Party Spokesperson Ömer Çelik, in his statement following the Central Executive Board (MYK) meeting chaired by President Erdoğan on 7 October 2026, addressed Yılmaz’s briefing to Parliament and stated that all institutions have revealed the full dimensions of the process, including legal gaps. Çelik stated: “While conducting the work of the Fund Coordination Board, we are also developing an action plan to protect the rights of our citizens who have been victimized by these fund fraudsters. Let our citizens who have been robbed by these fraudsters rest assured. The state possesses the information and documents capable of exposing who engaged in greed and who truly suffered harm. When this is revealed, these processes will be completed swiftly within the framework of the work carried out by all institutions. An action plan has emerged to compensate victims of harm. Steps will be taken to submit to our esteemed Parliament any necessary legal amendments to prevent recurrence.”

Çelik continued: “There will be no dark spot left.” He added: “We are also witnessing provocative activities and certain narratives targeting the Turkish economy, as well as political lynching campaigns. We will not allow these to pass. We will carry out this entire framework with the utmost determination, ensuring transparency of these issues, punishment of the guilty and protection of the rights of those harmed, all in full view of the public.”

Çelik was reminded of allegations made by New Party General Chairman Özgür Özel and his aides regarding President Erdoğan, certain ministers and Çelik concerning the fund investigation. Çelik noted that state institutions are taking swift coordinated steps, and that similar crises have occurred elsewhere in the world, with some countries resolving them in five years and others in nine. He stated: “This concerns only a very small part of the capital markets. We are extremely determined to reveal all dimensions. We are not acting on speculation. We are acting based on information, documents and data. Yesterday, this person appeared before our President and made inappropriate, unlawful and unjustified statements saying, ‘You are at the center and head of this.’ The will to uncover and clean up this issue lies with our President. The will to eliminate this hardship, fraud and deceit lies with our President. How dare they make such statements against our President? They always try to involve our President’s family members in these matters. These allegations have repeatedly backfired on them, yet they persist. All actions are transparent, and everyone can see what is happening on screen. Today, our President also stated that these matters must not be politicized. They are trying to link unrelated issues based on allegations, rumors or supposed facts. The will to clean up this issue lies with our President. The struggle to clean up corruption and fraud in their municipalities is also ours. Therefore, the statements targeting our President are nothing more than political nonsense from someone whose party has been captured by fraudsters and dishonest individuals.”

Çelik noted that numerous meetings, both public and private, have been held with President Erdoğan on this issue, and that Erdoğan made a speech in the closed session of the MYK reaffirming his resolve. He stated: “Let anyone with documents and information bring them forward and submit them to the judiciary.” Regarding criticism of the Ministry of Justice, Çelik said: “Whenever corruption or misconduct is exposed, they always target our Minister of Justice and the Ministry of Justice. Do they expect a ‘acceptable’ Ministry of Justice that will not apply the Constitution and laws or conduct any investigations? All these investigations are being conducted within the powers granted by the Constitution and laws and are openly shared with the public. On what grounds are you targeting the Ministry of Justice? Shouldn’t the law be applied to you?” and “We are also clearly stating this from our party’s perspective. Steps are being taken in accordance with political responsibility.”

Çelik also stated regarding the fund allegations: “If anyone has any document, regardless of the position, title or identity of the person involved, immediately submit it to the judiciary. If the necessary procedures are not followed in court applications, then they can speak. Send information and documents to the Ministry of Justice and the Ministry of Treasury and Finance. But these issues must not be reduced to political lynching campaigns or political protection debates. Principles must be applied. The issue is about fraud and deception. If they are trying to extract a political operation from this, it will not work for us.” and “We will not submit to political lynching campaigns nor allow political protection to obscure any truth. Everything will be revealed. Those who committed fraud and deception will pay the price. The rights of those harmed by these frauds will be restored. Nothing will be taken from the pockets of the state or our citizens. This will is the will of our President as head of state, and clear instructions have been given to all institutions. We will take all necessary measures to ensure this never happens again.”

The Istanbul Public Prosecutor’s Office, within the scope of the fund investigation concerning capital market operations, ordered the taking of statements from İsmail Saymaz, Murat Ağırel and Şaban Sevinç as suspects, on the grounds that they made misleading statements to the public through media and social media platforms.

Under the same investigation, detention orders were issued against Mustafa Balcı and Şaban Sevinç. At the request of Minister of Trade Ömer Bolat, the investigation also called for statements from Saymaz and Ağırel.

Şaban Sevinç and Mustafa Balcı were detained on charges of publicly disseminating misleading information. After procedures at the police station, the two were brought to the Istanbul Courthouse in Çağlayan, where they gave statements to the prosecutor and were referred to the Peace Criminal Court with a request for arrest. The court decided to arrest Sevinç and Balcı.

İsmail Saymaz and Murat Ağırel also appeared at the courthouse to give their statements. After proceedings at the prosecutor’s office, they were referred to the court with a request for judicial control measures including a signature requirement and travel ban. Both were released under judicial control conditions.

In addition, investigations were initiated against four other individuals regarding allegations of disseminating misleading information related to the fund inquiry. At this stage, proceedings have been conducted against 207 individuals in the context of the fund investigation, with 85 suspects arrested.

The Istanbul Public Prosecutor’s Office has launched an ex officio investigation into allegations of violating the confidentiality of the investigation, following the dissemination of circulars sent to certain institutions via social media and digital platforms.

The Prosecutor’s Office stated that appropriate instructions and circulars consistent with the stages of the investigation were sent to the Capital Markets Board, Borsa İstanbul, Central Registry Agency, Turkish Banks Association and other relevant institutions. It was announced that the public dissemination of documents marked “confidential” will be assessed under Article 285 of the Turkish Criminal Code and that judicial proceedings will be initiated against those responsible for such disclosures.

On 9 October, the Fourth Fund Coordination Board Meeting was held under the chairmanship of Vice President of the Republic Cevdet Yılmaz. Representatives from the Ministry of Justice, the Ministry of Treasury and Finance, and related institutions under these ministries attended the meeting.

The meeting addressed the status of funds in ordinary liquidation processes and those under consideration for extraordinary liquidation. Technical preparations for interim payments up to one million Turkish liras, as planned under a draft law to be submitted to the Grand National Assembly of Türkiye for its discretion under extraordinary liquidation, were reviewed.

Inter-institutional coordination regarding the refund process through accounts opened for the return of excessive gains was also discussed. The Board resolved to continue coordinated efforts with relevant institutions in accordance with established fundamental principles. It was reported that technical teams established at the operational level are conducting detailed work and that independent regulatory and supervisory institutions will continue to share their decisions within their respective jurisdictions with the public.

AK Party Group Chairman Abdullah Güler announced that the “Draft Law on Certain Investment Funds Decided for Liquidation” was submitted to the TBMM Presidency on 9 October 2026. At a press conference held with the initial signatories of the draft, AK Party MP Ersan Aksu from Samsun and AK Party MP Atay Uslu from Antalya, Güler stated that the draft law consists of nine articles.

Güler emphasized that macroeconomic stability and the resilience of the financial system remain strong, and that no general negative trend has been observed in the capital markets.

Regarding the funds whose liquidation was decided by the Capital Markets Board (CMB) on 17 September 2026, he stated: “We have prepared a special legal regulation to resolve the extraordinary situation experienced in the investment funds decided for liquidation by the Capital Markets Board (CMB) on 17 September 2026, in a fair and transparent manner that safeguards the collective interests of investors.”

Güler stated that the funds intervened in by the CMB do not reflect the general condition of the markets. He clarified that the total portfolio size of the funds under liquidation corresponds to 2.4 percent of household financial assets and that the 131 funds represent 4.6 percent of the total number of funds in the system. Güler emphasized that the problem is confined to a limited segment of the fund market and that decisive action will be taken against those responsible.

Güler noted that the draft law does not establish a general or permanent liquidation regime but is a temporary and exceptional regulation applicable only to the funds decided for liquidation by the CMB on 17 September 2026 and whose liquidation had not been completed by the date of the law’s publication. He stated that no public funds will be used in the process and that liquidation will be carried out using the funds’ own assets.

Güler stated that the draft law is scheduled to be reviewed by the TBMM Planning and Budget Committee next week, followed by the General Assembly. He also noted that investigations under the Capital Markets Law are ongoing. Güler emphasized that necessary actions will be taken regardless of who is responsible, including individuals serving within his own party.

The draft law covers investment funds whose liquidation was decided by the CMB on 17 September 2026 and whose liquidation had not been completed by the date of the regulation’s publication. Its purpose is to establish procedures and principles to ensure the fair, transparent and efficient liquidation of these funds, recover values unlawfully withdrawn from the funds’ assets, collect compensation for losses and damages from responsible parties, and distribute recovered values to fund unit holders.

The regulation does not establish a general or permanent liquidation or liability regime for other investment funds outside its scope.

- The liquidation of funds will be carried out by institutions appointed for liquidation under the supervision and control of the CMB. The CMB will have the authority to determine the stages of the liquidation process, identify the fund’s assets and convert them into cash, establish valuation principles, determine fund unit ownership, set interim and final payments, define distribution order, and establish other procedures and principles.

- Where the CMB determines that the market price on the exchange does not reflect the true value of the relevant asset or would delay liquidation, methods such as buyback, sale to the dominant shareholder, bulk sale and special transaction notification may be used. The CMB may also temporarily apply a different price margin. Upon request by institutions responsible for liquidation, the CMB may approve the sale of assets outside the exchange, and certain regulatory restrictions applicable to investment funds will not apply to such sales. Additionally, investors purchasing these assets may be prohibited from selling them on the exchange for a specified period.

- Amounts collected during the liquidation process will be added to the liquidation assets after deducting mandatory expenses incurred for fund management and liquidation. Amounts collected after the completion of liquidation will be transferred to the recovery account to prevent duplicate payments.

- The Central Registry Agency (CRA), Takasbank, Borsa İstanbul, Turkish Banks Association, institutions responsible for liquidation, portfolio management companies, portfolio custodians, other capital market institutions and public institutions are obligated to provide, without delay, all necessary information and documents to the CMB, the Investor Compensation Center (ICC), and/or the Savings Deposit Insurance Fund (SDIF) upon request. Institutions cannot refuse to provide information by invoking confidentiality or secrecy provisions in their special regulations.

- Fund unit ownership will be determined by comparing records from the CRA, Takasbank, the Turkish Electronic Fund Purchase and Sale Platform (TEFAS), portfolio custodians and distribution institutions, on a fund and account basis, by institutions responsible for liquidation.

- Market manipulation, information abuse and market fraud acts committed by the funds decided for liquidation, in coordination with these funds, or through their participation will result in no payment being made to the individuals or institutions identified by the CMB as having committed such acts or coordinated with the funds, from the liquidation or recovery accounts.

- Where the distributable cash does not cover the total amount calculated based on the fund unit price as of the last day before the liquidation decision and the number of subscription units, the net investment amount will be calculated. In this calculation, the investor’s cash inflows into the fund and outflows from the fund will be updated using the arithmetic mean of the inflation rates reflected in the Consumer Price Index (CPI) and the Domestic Producer Price Index (PPI) up to the liquidation date. If the total inflow exceeds the total outflow, outflows will be deducted using the first-in-first-out method, and the calculation will be performed by the CRA.

- For funds determined by the CMB, interim payments of up to one million Turkish liras may be made to investors whose net investment amount is below one million Turkish liras, and a maximum of one million Turkish liras to those whose net investment amount is one million Turkish liras or more. Except for money market funds, the interim payment cannot exceed the total value of the investor’s fund units as of the last day before the calculation date. Fund units will not be returned in exchange for interim payments; they will be returned during the final liquidation payment.

- If the distributable cash is insufficient to cover the full net investment amounts or interim payments, the CMB may determine the payment order to ensure as many investors as possible benefit from the available resources. In this context, payments may begin with the investor having the lowest net investment amount, or a minimum interim payment amount may be set for all investors.

- No investor may receive a payment exceeding their net investment amount, calculated rights and claims, or the one million Turkish lira limit for interim payments. In the final liquidation payment, amounts previously paid to the investor from the liquidation assets, recovery account or other legal means will be offset.

For funds decided for liquidation by the CMB on 17 September 2026, individuals who received payments by returning fund units to the fund at values inconsistent with reality before the liquidation date may voluntarily refund a portion of the amount received. The refundable amount will be the portion exceeding the normal return calculated based on the annual average return of funds in the same investment strategy category, taking into account the actual amount invested by the investor and the duration of their investment. Returns of the funds decided for liquidation will not be considered in the calculation.

Individuals who gained profits from units whose prices were determined by the CMB to be inconsistent with reality may also voluntarily transfer the amount exceeding the normal return, calculated based on the return of the relevant index or other objective market indicators determined by the CMB, to the general unit refund account announced by the CMB. The CMB will determine the procedures and principles for identifying the reference fund group, calculation period and methodology.

Values withdrawn from fund assets through transactions that are contrary to regulations or, although formally compliant, lack any genuine economic purpose benefiting the fund, such as gratuitous or collusive transactions, will be considered unlawful transfers. Money, capital market instruments, goods, rights and claims transferred to related parties, dominant shareholders, managers, persons under their direct or indirect control, or third parties through credit, debt, advance, guarantee, transfer, assignment, purchase, sale, repurchase, reverse repurchase and similar transactions, as well as values obtained in exchange for or through evaluation of such assets, will fall under this category. In such cases, the fund will be deemed to have suffered loss or damage.

The portfolio management company acting as the fund’s founder and/or manager will be primarily liable for the loss or damage. If it is clearly determined that the loss cannot be fully or partially recovered from this company, personal liability will be assigned to the real and legal persons identified by the CMB as having acted in coordination with the fund. Their resignation from office will not absolve them of liability arising from actions and decisions made during their tenure or period of control.

The CMB will determine, for each fund, the amount of loss or damage, the responsible parties and their respective liability amounts, taking into account the results of liquidation and audit investigations, and will notify the SDIF. Upon notification, the SDIF will initiate collection proceedings against the liable parties under the Law on the Collection of Public Debts. The SDIF will exercise its powers under this regulation and relevant provisions of the Banking Law. In such proceedings, Istanbul Administrative Courts will have jurisdiction.

- Assets seized or confiscated under criminal investigation and prosecution will be included in the recovery system in proportion to their legal and economic connection with the fund. Cash and capital market instruments that can be legally returned directly to the fund may be transferred to the relevant fund or recovery account by decision of the public prosecutor, judge or court under the relevant provisions of the Criminal Procedure Code. Reports submitted by the CMB as the basis for criminal complaints will also be accepted as reports on the value obtained from the offense.

- For other asset values such as real estate owned by liable parties that cannot be directly transferred to the fund, the SDIF may be appointed as administrator. The SDIF may sell or liquidate these assets without waiting for the outcome of legal proceedings, using the powers granted to it under the Banking Law.

- Values determined by the court to have been confiscated as a result of the trial and identified as originating from the fund’s assets or as compensation for the fund’s loss will not be recorded as state revenue. These values will be transferred to the relevant investment fund or, if liquidation is complete, to the recovery account.

- Amounts collected or refunded and asset values linked to the offense, upon decision to be transferred to the fund or fund unit holders, will be tracked under separate sub-accounts labeled “recovery account” within the SDIF for each fund. These accounts will be kept separate from the SDIF’s own assets. Funds in these accounts may only be used for the liquidation of the relevant fund and payments to investors; they cannot be used for other purposes, pledged as collateral, or seized for public debts or other claims. No precautionary measures or attachment orders may be applied to these amounts.

- Amounts accumulated in the recovery accounts will be transferred by the SDIF to the institution responsible for liquidation after deducting mandatory expenses. Upon completion of liquidation, these amounts will be sent to the ICC for payment to the fund unit holders as notified by the CMB. Payments will be made in proportion to each investor’s unit ownership. In payments other than the final distribution, if the amount due to an investor falls below the minimum payment threshold determined by the CMB, the amount will be carried forward and added to the investor’s entitlement in subsequent distributions. Where an amount is linked to multiple funds, the CMB will determine the allocation principles among the funds.

- Where deemed necessary for the implementation of the regulation, the CMB and the ICC may procure external legal, accounting and software development services under conditions determined by the Board Decision Authority.

- The CMB will determine the procedures and principles for implementation. The views of the SDIF will be sought on matters within its jurisdiction. For situations not covered by this regulation, provisions of the Capital Markets Law, Criminal Procedure Code, Banking Law and other relevant legislation that are not contrary to this regulation will apply.

The impact analysis of the draft law aims to ensure the fair, transparent and efficient liquidation of investment funds without using public resources or budgetary means. The regulation seeks to recover values unlawfully withdrawn from fund assets, collect compensation for losses from responsible parties, and transfer recovered amounts to fund unit holders. The following data are included in the impact analysis:

- The CMB decided to liquidate a total of 131 funds established by A1 Capital Portfolio Management Inc., Atlas Portfolio Management Inc., Bulls Portfolio Management Inc., Hedef Portfolio Management Inc., Pardus Portfolio Management Inc., Pusula Portfolio Management Inc. and Tera Portfolio Management Inc. on 17 September 2026.

- According to data from the Central Registry Agency (CRA), as of 17 September 2026, the number of individual investors in these funds was 455,758. The 131 funds under liquidation represent 4.6 percent of the total number of funds and 7.7 percent of the total portfolio value. The impact analysis anticipates that the liquidation process will be conducted without burdening the state budget.

- According to the CRA’s analysis for the same date, approximately 199,000 investors in non-free funds with “money market” in their titles established by Atlas, Hedef, Tera and Pusula Portfolio Management Inc. have a net investment amount below one million Turkish liras, as do approximately 341,000 investors in free funds with “equity” in their titles.

- The impact analysis notes that the CMB submitted seven written applications to the Istanbul Public Prosecutor’s Office, resulting in criminal complaints against 69 individuals. According to CMB notifications, the Istanbul Public Prosecutor’s Office has applied seizure measures against 189 individuals.

- It is reported that the CMB and ICC are monitoring approximately 1,500 ongoing litigation cases, and the potential number of lawsuits is expected to reach at least ten times the current number. Given that existing personnel capacity may be insufficient to monitor the process, it is anticipated that the CMB may procure external services from its own budget if necessary.

The bill’s hearings were held on 14 October 2026 in the committee; the bill’s first signatory, AK Party Samsun Member of Parliament Ersan Aksu, Deputy Minister of Treasury and Finance İlhan Hatipoğlu, MASAK Chair Hasan Kaymak, SPK Deputy Chair Ahmet Aksu and Borsa Istanbul General Manager Korkmaz Ergun responded to questions from members of parliament.

Hatipoğlu noted that the Capital Markets Law already contains provisions regarding ordinary liquidation and that the bill clarifies matters related to extraordinary liquidations: “There is no definition in current legislation for interim payments or net investment amount. Such a need arose. Additionally, TMSF has been granted additional powers; otherwise, TMSF could not have assumed its role.” Hatipoğlu also stated that it was not possible under ordinary liquidation or SPK regulations to assign the two appointed custodial institutions any responsibilities.

Hatipoğlu further stated: “Under the fund dossier, MASAK has made 48 separate requests to 29 different countries to date. Information requests have been issued regarding accounts, assets, and all types of holdings—including cash and crypto—of 278 individuals and legal entities.” He confirmed that formal communication with public prosecutors via judicial inquiries has been established and that the process of repatriating assets abroad is being monitored.

Kaymak explained in response to the criticism “Could MASAK have prevented money transfers abroad?” that the mechanism relies on the know-your-customer principle, requiring obligated parties to report suspicious transactions to MASAK: “There is no such thing as MASAK overseeing large or medium-sized financial transactions.” Regarding the question of whether crypto assets were transferred abroad, he noted that it is impossible to monitor whether crypto assets are stored in cold wallets: “There is not even the slightest trace of any transaction involving the amounts mentioned. There is no crypto asset service provider in Türkiye capable of handling transactions of such magnitude.” Kaymak also reported that MASAK receives over 600,000 suspicious transaction reports annually.

SPK Deputy Chair Ahmet Aksu expressed regret regarding the transactions under investigation and stated: “The State Audit Board is carrying out its duty. Whatever findings emerge from its audit, the responsibilities of the SPK—whether in quantity or location within the system—will become clear. We will accept the outcome.” Borsa Istanbul General Manager Ergun said: “We submitted our disclosures to both the SPK and the Public Disclosure Platform. Thus, we have fulfilled our obligations on this matter.”

● Share freezes and TEFAS: According to Aksu, the reason records remain in the Banking Regulation and Supervision Agency is twofold: transactions did not occur due to unpriced units in TEFAS and payments were not made because funds became delinquent. It was confirmed by Takasbank and TEFAS officials that claims arising from instructions transmitted to TEFAS on 14, 15 and 16 September and matched with prices were settled. Aksu emphasized that merely submitting a sale instruction does not mean the end of participation share ownership.

● Transfer of Emlak Katılım operations: According to Aksu, Katılımevim Savings Finance Inc., Birevim Savings Finance Inc. and İktisat Participation Bank Inc. will carry out their transfer operations “without using any public, liquidation or tax resources”; real estate owned by shareholders will be transferred free of charge to these companies and Türkiye Emlak Participation Bank Inc. will not pay any consideration to acquire these companies.

● Other legislative work concerning the SPK: Aksu stated that another legislative initiative concerning the SPK exists and that the bill may be submitted to the committee after budget discussions.

● Regulatory process: In response to the question “Why was no intervention made earlier?”, Aksu noted that the weight of free funds in the fund market was around 35 percent in 2021, rose to 52 percent in 2022, and reached 65 percent in 2026. Aksu outlined the following timeline: The Financial Stability Committee met on 2 December 2025; on 18 December 2025, the qualified investor threshold was raised from one million to ten million lira; the draft guide was submitted to the Ministry of Treasury and Finance on 28 January; sectoral opinions were gathered on 15 February; TEFAS implementation principles were approved by the SPK on 17 June and implemented by Takasbank on 31 July 2026. According to Aksu, the guide was publicly announced on 29 August 2026 and it became mandatory for the MKK to disclose fund participation ratios if they exceeded certain thresholds, following weekly publication of free fund portfolio allocations.

● SPK actions: Aksu stated: “To date, the SPK has filed criminal complaints against 117 individuals; a two-year trading ban on exchanges and other organized markets has been imposed on a total of 117 individuals and five legal entities. Licenses have been revoked for 64 individuals in total.” In response to calls for disclosure of names of those who profited from the fund investigations, he said: “If there is any list to be disclosed, let it be disclosed.”

Proposals by CHP members of parliament rejecting the bill on grounds of unconstitutionality and calling for the establishment of a subcommittee for comprehensive review were rejected, after which the committee proceeded to discuss the bill’s articles.

The Bill on Certain Investment Funds Whose Liquidation Has Been Decided was adopted by the TBMM Planning and Budget Committee on 14 October 2026. The bill includes provisions on the execution of liquidation, interim payments, personal liability, asset seizure and recovery. The adopted text establishes the following provisions regarding voluntary refunds:

• For funds whose liquidation has been decided, the portion of returns received by individuals who redeemed their participation units before the liquidation date and received payment, exceeding the amount calculated by the arithmetic average of the percentage changes in the Consumer Price Index (TÜFE) and the Domestic Producer Price Index (Yİ-ÜFE) as published by TÜİK, may be refunded voluntarily to accounts announced by the SPK.
• Individuals who have realized gains from shares held in fund assets and evaluated under relevant provisions of the Capital Markets Law may voluntarily refund to a general share refund account announced by the SPK the portion of returns exceeding the acquisition cost of those shares, calculated by the same method. The SPK is granted authority to determine the calculation period, methodology and other procedures for the refund amount.
• Participation share ownership will be determined on a fund and account basis by verifying records with the Central Registry Agency (MKK).

At the sixth meeting of the Fund Coordination Board, it was recalled that the bill was adopted by the TBMM Planning and Budget Committee on 14 October and it was announced that the bill is expected to be discussed in the TBMM General Assembly next week.

Vice President Cevdet Yılmaz, in a post on his NSosyal account on 16 October 2026, stated: “Following the passage of the bill expected in our parliament next week, the process will accelerate further.”

The Fifth Meeting of the Fund Coordination Board was held under the chairmanship of Vice President Cevdet Yılmaz, with participation from the Ministry of Justice, the Ministry of Treasury and Finance and their relevant institutions and organizations.

At the meeting, it was announced that Ziraat Bank made a total payment of 6.4 billion lira to 43,643 investors in funds managed by A1, Bulls and Pardus last week.

It was indicated that the liquidation of the remaining 49 funds of the three portfolio management companies is targeted for completion by the end of the week. Upon completion of these operations, a total of 40.5 billion lira in kind and cash liquidation payments is expected to be made to 45,745 individuals holding shares in the 66 separate investment funds established by the three portfolio management companies.

It was stated that after the bill becomes law, interim payments for the remaining 65 funds in the liquidation process will also be completed urgently.

The Sixth Meeting of the Fund Coordination Board was held under the chairmanship of Vice President Cevdet Yılmaz, with participation from the Ministry of Justice, the Ministry of Treasury and Finance and their relevant institutions and organizations.

At the meeting, it was announced that Ziraat Bank has completed total kind and cash liquidation payments of approximately 40.8 billion lira to over 45,000 individuals holding shares in the 66 separate investment funds managed by A1, Bulls and Pardus since the start of the liquidation process. Thus, the number of funds under liquidation has been reduced from 131 to 65.

By the SPK’s decision dated 15 October 2026, the liquidation of funds established by Hedef Portföy Yönetim Şirketi AŞ will be conducted under the same principles established for funds managed by A1, Bulls and Pardus. Accordingly, it was indicated that payments will be made to as many investors as possible, starting with those holding money market funds, in the coming week.

The meeting also included initial assessments of a new draft regulation proposing permanent and comprehensive amendments to the Capital Markets Law aimed at resolving structural problems in capital markets, strengthening regulatory and supervisory mechanisms, and increasing the deterrent effect of sanctions and penalties.

The Public Prosecutor’s Office’s statement regarding the violation of investigation secrecy due to the sharing of official circulars on social media was published on 10 October 2026 at 18:58. The same statement was previously reported in a news article dated 12 October. The discrepancy between the two dates is addressed in the section “Discrepancies Between Documents.”

Minister of Treasury and Finance Mehmet Şimşek granted investigation authorization against former Capital Markets Board (SPK) Chair İbrahim Ömer Gönül based on the preliminary inspection report of the Ministry’s Inspection Board.

According to information obtained from the Ministry of Treasury and Finance, the Istanbul Chief Public Prosecutor’s Office requested investigation authorization against Gönül as part of the fund investigation. In response, Şimşek immediately assigned the Ministry’s Inspection Board on 2 October 2026 to conduct a preliminary review.

President Recep Tayyip Erdoğan, in his statement following the Cabinet Meeting held at the Presidential Complex on 12 October 2026, stated that intensive efforts are being made to swiftly resolve the fund issue.

Erdoğan stated that since the previous Cabinet Meeting, steps have been taken including the assignment of the State Audit Board, the establishment of the Fund Coordination Board, the briefing of the TBMM and the submission of the bill to the parliament’s discretion. He also noted that the process for transferring Katılımevim, Birevim and İktisat Participation Bank to Emlak Katılım has been initiated and that payments have begun for funds whose MKK procedures have been completed.

Erdoğan, providing information on actions taken in the investigation, said:

“Investigations on the judicial side are continuing with diligence and depth. Legal proceedings have been initiated against 282 individuals, including members of the management boards of fund companies. Of these, 84 have been detained, arrest warrants have been issued for 27 suspects, and 99 individuals have been subjected to judicial supervision.”

Erdoğan stated that with the passage of the bill in the TBMM, principal repayments of up to one million lira are planned to begin within October. He added that after ordinary and extraordinary liquidation procedures are completed within October, a significant portion of investors will receive interim payments, and the Fund Coordination Board will regularly and detailedly inform the public.

In his assessment of the management of the process, Erdoğan said: “Our primary priority now is not to engage in polemics, but to manage this process transparently, fairly and swiftly without using public resources.” Emphasizing that protecting investors’ rights is paramount, he stated: “Protecting the rights and legal entitlements of our nation is our red line. Whoever has gained excessive returns through speculation and manipulation must pay the price.”

Erdoğan also noted that no one, including himself, is exempt from criticism; however, he emphasized that titles, professions or positions cannot justify character assassination against others: “But no one’s title, profession or position grants them the right to conduct a character assassination against another person using FETÖ methods.”

Minister of Trade Ömer Bolat, in his statement on 10 October 2026, stated that no withdrawal or account closure transaction of 170 million lira was recorded in the Central Registry Agency (MKK) records or in the sukuk account of Hedef Yatırım Portföy Şirketi.

Bolat argued that repeated transactions related to maturing receivables over a 2-year 8-month period and payments for new sukuk purchases have been incorrectly grouped together to create a false impression. He pointed out that these transactions were misrepresented as a 170 million lira withdrawal and said: “We have identified this.”

Bolat stated that no new sukuk payment or collection transaction has been recorded since 25 October 2024, that sukuk accounts have been transferred to Ziraat Bank for liquidation purposes, and that no crypto assets or foreign savings accounts exist.

The minister reported that allegations have been made on social media that he himself closed his fund account before the operation and invested 400 million lira and withdrew 800 million lira. He also noted that Yeni Parti İzmir MP Ümit Özlale made new allegations against him and Minister of Family and Social Services Mahinur Özdemir Göktaş on 8 October, and that Yeni Parti General Chairman Özgür Özel claimed during a rally in Mersin that Bolat had conducted a 170 million lira transaction. Bolat labeled these allegations “slander.”

Bolat emphasized that the MKK is a record and custody center and that relevant information can be officially requested from banks and the MKK: “We will settle accounts with them in the high courts of Turkey. […] I will pursue this battle with them to the end in court.”

Minister of Treasury and Finance Mehmet Şimşek, in his social media post on 16 October 2026, announced that legal reforms to strengthen the fight against capital markets crimes—including coordinated fund operations—are planned to be completed by the beginning of 2027.

Şimşek noted that under the Fund Guide announced at the end of August, weekly disclosure of free fund portfolios has been implemented and regulations have been introduced requiring notifications when participation thresholds are exceeded or fallen below. He also stated that concentration limits have been imposed on funds and that borrowing transactions are now mandatory to be conducted on organized markets with collateral.

Şimşek said: “We will closely monitor the outcomes of these reforms and, in consultation with all stakeholders, take any additional necessary steps without delay.”

In its statement regarding Türkiye, global index provider MSCI indicated that certain equity market index changes have been suspended until a second announcement. The statement noted that additional time is needed to evaluate whether the measures taken have delivered the structural improvements investors expect, and that the process will be monitored until June 2027.

Vice President Cevdet Yılmaz, in his NSosyal post, stated that administrative steps have been taken to prevent similar problems during the closure of problematic funds through ordinary and extraordinary liquidation methods. Yılmaz stated that preparations for a bill containing structural reforms for capital markets are ongoing.

President Recep Tayyip Erdoğan made the following assessments regarding the fund investigation on 16 October.

• “With the decisive steps we have taken since 17 September, we have brought the issue under control.”
• “We are conducting the operation with surgical precision. With determined, careful and sensitive steps, we are resolving the matter in the most equitable manner.”
• “We cannot accept the criminalization of our entire capital markets based on the fund issue.”
• “Just as it is wrong to ignore the problem in a certain segment of the fund market, using this issue as a shield to attack the capital markets is also wrong.”
• “Using a problem found in just 4.6 percent of funds to terrorize all capital market instruments would undermine the Turkish economy.”

On 21 October, an arrest warrant was issued for Nusret Altınbaş, owner of Altınbaş Holding, as part of investigations into capital market operations. Altınbaş’s brother, İnan Altınbaş, was also detained, and all assets of other family members were frozen.

According to the same-day statement by the Istanbul Chief Public Prosecutor’s Office, under the fund investigation conducted by the Office for the Investigation of Terrorist Financing and Money Laundering, and based on reports submitted by the Capital Markets Board (CMB) and written applications, examinations were carried out regarding shares in Işıklar Enerji ve Yapı Holding AŞ (IEYHO), Vişne Madencilik Üretim Sanayi ve Ticaret AŞ (VSNMD), Odine Solutions Teknoloji Ticaret ve Sanayi AŞ (ODINE), and Tera Finansal Yatırımlar Holding AŞ (TRHOL). As part of this, detention orders were issued for 31 individuals.

During an operation conducted by the Istanbul Police Directorate’s Financial Crimes Prevention Branch, 26 suspects subject to detention orders were taken into custody, and it was reported that five suspects, including Nusret Altınbaş, remain at large.

The detained suspects and their positions are as follows:

• Çetin Genç: Director of the Fatih Branch of Pirnus Yapı Gayrimenkul Anonim Şirketi.
• Eren Yeşilyurt: former bureaucrat.
• Fadimenur Demir: Member of the Board of Directors of Alnus Yatırım Menkul Değerler Firması.
• Hakan Avdan: Member of the Board of Directors of Atlas Portföy.
• Gülsüm Doğan, Osman Uçar and Canan Özdemir
• Metin Kartal Emür: Deputy Chairman of the Board of Directors of Alnus Yatırım Firması.
• Mustafa Terzi: Chairman of the Board of Directors of A1 Capital Portföy Yönetimi Anonim Şirketi.
• Zuhal Topaloğlu: Partner of Atlas Portföy Yönetimi AŞ.
• Seyit Tahir Özek: Chairman of the Board of Directors of Alnus Yatırım Menkul Değerler.
• Konuralp Özkan: Employee of Atlas Portföy.
• Rüstem Karakaya and Furkan Açar: Managers of Pardus Portföy Yönetimi Anonim Şirketi.
• Neda Soydan and Ömer Eryılmaz: Members of the Board of Directors of Hedef Girişim Sermayesi Yatırım Ortaklığı.
• Mustafa Zeki Kayahan: Manager of Hedef Girişim Sermayesi Yatırım Ortaklığı; Anıl Tokat: employee.
• Mehmet Selim Tunçbilek: General Manager of Pardus Portföy; Ali Cesur: Member of the Board of Directors; Ahmet Haluk Güner: employee.
• Ümit Yılmaz, Yasemin Yılmaz and Burak Poyraz: portfolio employees at banks.
• İnan Altınbaş: Official of Altınbaş Holding.
• Ayşegül Kaya: Manager of Tera Portföy.

On 22 October 2026, detention orders were issued for five additional suspects: Ertan Aydın, Seda Tarım Kocabalkan, Abdullah Dal, Hakan Eryılmaz and Fahri Uğur were taken into custody. Of the 31 suspects detained, 16 had completed their police procedures and were transferred to the Istanbul Court in Çağlayan after medical checks. While the statements of the other 15 suspects were still being taken at the police station, efforts continued to apprehend five suspects, including Nusret Altınbaş.

The names of the 16 suspects transferred to court are recorded as Çetin Genç, Eren Yeşilyurt, Fadimenur Demir, Gülsüm Doğan, Hakan Avdan, Konuralp Özkan, Metin Kartal Emür, Osman Uçar, Seyit Tahir Özek, Zuhal Topaloğlu, Ahmet Haluk Güner, Furkan Açar, Mehmet Selim Tunçbilek, Mustafa Terzi, Ümit Yılmaz and Yasemin Yılmaz.

According to information published on 24 October 2026 and updated on 25 October, arrest and judicial control decisions were issued for suspects previously transferred to court. Çetin Genç, Eren Yeşilyurt, Hakan Avdan, Konuralp Özkan, Metin Kartal Emür, Osman Uçar, Seyit Tahir Özek, Ahmet Haluk Güner, Mehmet Selim Tunçbilek, Mustafa Terzi and Ümit Yılmaz were arrested. Fadimenur Demir, Gülsüm Doğan, Zuhal Topaloğlu and Yasemin Yılmaz were subjected to judicial control measures prohibiting them from leaving their residences.

Following statements to the prosecution, İnan Altınbaş, Taha Çakmak, Rüstem Karakaya, Burak Poyraz, Ömer Eryılmaz, Osman Saraç, Neda Soydan, Mustafa Zeki Kayahan, Anıl Tokat, Ali Cesur, Furkan Açar, Mehmet Ali Gedik, Fatih Uğur, Ömer Ejder and Hakan Eryılmaz were ordered to be arrested by the peace criminal court.

Judicial control measures were applied to Selay Turhan İnce, Ebru Avcı, Canan Özdemir, Abdullah Dal, Seda Tarım Kocabalkan, Feyza Gözde Özdemir and Erhan Tunç under the same scope.

Former AK Party MP and founder of a research and campaign company, Ertan Aydın, was among the suspects detained on 22 October 2026. On 24 October, after completing his police procedures and undergoing a medical check, Aydın was taken to the Istanbul Court in Çağlayan. Following his statement to the prosecution, he was referred to the peace criminal court with a request for arrest.

On 25 October, following an appeal against the judicial control decision, Aydın was re-detained in Ankara. After completing procedures, he was brought back to Istanbul and presented to the on-duty peace criminal court at the Istanbul Court of Justice in Çağlayan. The court ordered Aydın’s arrest.

Gürol Sami Özer, Deputy General Manager of Türkiye Sigorta, was taken into custody and, after completing police procedures and undergoing a medical check, was transferred to the Istanbul Court. Following his statement to the prosecution, he was referred to the on-duty peace criminal court with a request for arrest and was ordered to be arrested. On the same day, Türkiye Sigorta’s disclosure on the Public Disclosure Platform (KAP) stated that Özer’s employment contract was terminated effective 26 October 2026 by decision of the Board of Directors.

Nusret Altınbaş, owner of Altınbaş Holding, was reported on 24 October 2026 to still be undergoing police procedures. On 26 October, after completing his police procedures and undergoing a medical check, Altınbaş was transferred to the Istanbul Court in Çağlayan.

Minister of Justice Akın Gürlek, in his statement on 21 October 2026, reported that, as part of investigations into manipulative activities in capital markets, legal proceedings had been initiated against 404 individuals, 88 suspects had been arrested, 26 suspects had been detained, and judicial control measures had been applied to 195 individuals. Gürlek noted that efforts were ongoing to apprehend 42 suspects who were fugitives.

Providing information on the financial scale of the investigations, Gürlek stated that bank accounts of 351 natural persons and 102 legal entities had been frozen, assets seized, and transfers of real estate blocked. These measures aim to preserve assets under investigation and bring financial transactions under control.

Gürlek reported that repayments by natural and legal persons deemed to have gained unjust enrichment are being made to accounts established under the Savings Deposit Insurance Fund (TMSF). Gürlek emphasized that the amounts repaid and findings from the investigations are being tracked by the relevant public prosecutor’s offices, and that all legal procedures will be carried out with due diligence and efforts to remedy damages will continue.

On 25 October 2026, Gürlek stated that voluntary repayments in the context of the fund investigations do not absolve individuals of legal responsibility. He emphasized that repayments contribute to remedying damages but do not hinder the continuation of investigations or the evaluation of evidence.

Gürlek stated that his priority is ensuring that repaid amounts reach the rightful owners. He explained that the source, timing, amount, and method of delivery of repayments will be examined in detail, and allegations against individuals and transactions will be subject to legal assessment based on existing evidence. He further stated that the distinction between individuals deemed to have gained unjust enrichment and good-faith investors will be carefully observed.

Gürlek noted that protective measures have been applied to natural and legal persons to prevent the concealment, transfer, or disposal of assets and to safeguard investor rights. He indicated that additional measures may be taken if new information, documents, or evidence establish the necessary legal conditions. He affirmed that necessary steps will be taken in coordination with relevant institutions to ensure the proper conduct of investigations and the remediation of damages.

In the Grand National Assembly of Türkiye, the five articles of the first section of the Bill on the Liquidation of Certain Investment Funds were adopted on 22 October 2026. The bill was enacted on the same day. Deputy Speaker of the TBMM Tekin Bingöl closed the session, scheduling the next meeting for Tuesday, 27 October 2026 at 15:00.

The law covers investment funds whose liquidation was decided by the Capital Markets Board (CMB) on 17 September 2026. The regulation aims to ensure the fair, transparent, and efficient liquidation of funds not yet fully liquidated as of the date of publication of the law.

The law also regulates procedures and principles for recovering values improperly withdrawn from fund assets, collecting damages and losses from responsible parties, and paying recovered values to fund unit holders. The regulation does not establish a general or permanent liquidation or liability regime for other investment funds outside those specified.

The liquidation of investment funds decided for liquidation will be carried out by institutions appointed for this purpose under the supervision and oversight of the Capital Markets Board (CMB). The CMB is authorized to determine the stages of the liquidation process, identification and conversion of fund assets into cash, valuation principles, determination of fund unit ownership, interim and final payments, distribution order, and other procedures and principles related to liquidation.

The institutions assigned to liquidation will exercise due diligence to protect fund assets and achieve the highest possible economic value, taking into account the interests of investors and the common interests of fund unit holders. Market conditions and the structure of fund portfolios will be considered during this process.

If the CMB determines that the market price does not reflect the true value of an asset or would delay the liquidation process, methods such as buyback, right of sale to the controlling shareholder, bulk sale, and special transaction notification may be applied. Temporary different price margins may also be established and other sale methods may be used. Upon request by the liquidation institutions, the CMB may approve the sale of assets outside the stock exchange. Restrictions under regulations governing investment funds will not apply to these sales; however, restrictions may be imposed on buyers requiring them to hold assets for a specified period before selling them on the stock exchange.

From amounts collected during the liquidation process, mandatory expenses for fund management and liquidation will be deducted, and the remaining amount will be added to the liquidation asset pool. After liquidation is completed, collected amounts will be transferred to the recovery account to prevent duplicate payments.

The Central Registry Agency (CRA), Takasbank, Borsa İstanbul AŞ, Turkish Banks Association, institutions assigned to liquidation, portfolio management companies, portfolio custodians, and other relevant capital market institutions and public bodies are obligated to provide necessary information and documents to the CMB, the Investor Compensation Center (ICC), and/or the Savings Deposit Insurance Fund (TMSF) without delay upon request. Relevant institutions cannot avoid information and document sharing by citing confidentiality and secrecy provisions in their special legislation.

Unit holders of funds under liquidation will be determined by the Central Registry Agency (CRA) through reconciliation on a fund and account basis.

The resolution adopted by the TBMM General Assembly regulates the scope of transactions that could not be executed due to fund default or non-disclosure of participation unit prices despite being transmitted to the Turkish Electronic Fund Buy-Sell Platform (TEFAS).

Accordingly, individuals whose participation units were blocked due to instructions transmitted to TEFAS on or before 17 September 2026 that could not be executed will be recognized as fund unit holders and subjected to liquidation provisions. The regulation aims to include individuals holding participation units in the TEFAS Transaction Blockage Sub-Account within the scope of ownership rights during liquidation.

If market-disrupting acts, information misuse, or market fraud as defined in the Capital Markets Law were committed by funds decided for liquidation, in coordination with such funds, or through their participation, individuals and institutions identified by the CMB as having committed such acts or coordinated with the funds will not receive any payment from the liquidation and recovery accounts. The regulation aims to prevent individuals and institutions linked to such acts from benefiting from payments under liquidation.

If the distributable cash obtained from converting fund assets into cash is insufficient to cover the total amount calculated based on the fund unit price as of the last day before the liquidation decision, a net investment amount will be determined as the basis for payments.

The net investment amount will be calculated by the Central Registry Agency (CRA) based on actual cash inflows into and outflows from the fund by fund unit holders. The arithmetic average of the inflation rates published by the Turkish Statistical Institute (TÜİK) for the Consumer Price Index (CPI) and the Domestic Producer Price Index (D-PPI) up to the liquidation date will be used, applying the Kistelyev method. If total cash inflows exceed outflows, outflows will be deducted using the first-in-first-out (FIFO) method. Calculations will be made subject to payment restrictions specified in the law for certain acts.

Interim payments may be made to fund unit holders to offset their final payments from the liquidation balance. For funds determined by the Board, investors whose net investment amount calculated without indexation is below one million Turkish Liras may receive an interim payment up to that amount; for investors with a net investment amount of one million Turkish Liras or more, the interim payment may be up to one million Turkish Liras.

The interim payment amount cannot exceed the total value of the fund participation units in the investor’s account as of the close of the day before the calculation date. The previous day’s fund price will be determined by Takasbank based on the valuation for the relevant day.

If the distributable cash is insufficient to cover the calculated net investment amounts or interim payment amounts, the CMB will be authorized to determine the payment method. The Board may decide to make payments starting from the investor with the lowest net investment amount to ensure the maximum number of fund unit holders benefit fully from available cash. Alternatively, a minimum interim payment amount may be set for all fund unit holders, and payments may be made up to that amount.

No payment exceeding the net investment amount, calculated rights and claims, or the one million Turkish Lira cap on interim payments may be made to any fund unit holder. Participation units will not be returned in exchange for interim payments; their return will occur during final liquidation payments.

For funds decided for liquidation by the CMB’s decision of 17 September 2026, individuals who received payments by returning their participation units to the fund before the liquidation date may voluntarily repay a specified portion of their gains to accounts announced by the Board. The amount repayable will consist of gains exceeding the amount calculated using the Kistelyev method for cash inflows.

Additionally, individuals who have realized gains from shares held in fund assets and evaluated by the CMB under relevant provisions of the Capital Markets Law may voluntarily transfer the portion of such gains exceeding the cost of acquisition, calculated using the Kistelyev method, to the general share repayment account. The CMB will have the authority to determine the calculation period, method, and other procedures and principles for repayment amounts.

In the final liquidation payment, amounts previously paid to the fund unit holder from the liquidation assets, recovery account, or other legal means will be offset. Thus, the final payment to the investor will be calculated taking into account previously collected amounts.

Values withdrawn from fund assets in violation of regulations or even if formally compliant but without any genuine economic purpose serving the fund’s interests will be considered illegally transferred assets. Money, capital market instruments, goods, rights, and receivables transferred to related parties, controlling shareholders, managers, persons under their direct or indirect control, or third parties through gratuitous or collusive transactions such as credit, debt, advance, guarantee, transfer, assignment, purchase, sale, repo, reverse repo, or similar agreements or contracts will be evaluated under this scope.

Values replacing such assets or obtained from their evaluation will also be considered illegally withdrawn assets. Such transactions will be deemed to have caused losses or damage to the fund.

The portfolio management company acting as the fund’s founder and/or manager will be primarily liable for losses or damages suffered by the fund. If it is clearly determined that the portfolio management company cannot fully or partially recover the loss, individuals and legal entities identified by the CMB as responsible for the loss, as well as those determined to have acted in coordination with them, will be held personally liable.

Having left their positions does not absolve responsible persons of liability arising from actions and decisions made during their tenure or period of control.

Except for special provisions regarding seized and confiscated assets and the recovery account, the CMB will determine the amount of loss or damage for each fund and identify the responsible parties. The Board will identify responsible natural and legal persons and the amounts for which they are liable, taking into account liquidation operations and audit findings, and will notify the Savings Deposit Insurance Fund (TMSF).

Upon notification from the CMB, the TMSF will initiate collection and recovery proceedings against responsible parties under the Law on the Collection of Public Debts. The TMSF will have the authority to apply provisions of this law and the Banking Law during this process. Courts in Istanbul administrative courts will have jurisdiction over lawsuits initiated under these provisions.

The law regulates the inclusion of values seized or confiscated in criminal investigations and prosecutions into the recovery system in proportion to their legal and economic connection with the funds. In investigations related to acts connected to the funds, seizure orders may be issued under relevant provisions of the Criminal Procedure Code (CPC).

If seized assets include cash or capital market instruments that can legally be returned directly to the fund, the public prosecutor, judge, or court may order their return to the relevant fund or recovery account. Reports submitted by the CMB as the basis for criminal complaints will be accepted as reports on proceeds of crime under relevant provisions of the CPC.

The law allows for the appointment of the Savings Deposit Insurance Fund (TMSF) as receiver for other asset values, such as real estate owned by responsible parties, that cannot be directly transferred to the fund. The TMSF may sell or liquidate such assets without waiting for court decisions, using powers granted to it under the Banking Law.

It is provided that values determined by the court as having been withdrawn from the fund’s assets or as compensation for fund losses, following conviction, will be transferred to the relevant fund. These values will be transferred to the relevant investment fund without being recorded as revenue by the Treasury, or to the recovery account if the fund has already been fully liquidated.

Amounts collected or repaid and values determined for transfer to the fund or fund unit holders from assets linked to crimes will be tracked in a recovery account established within the TMSF. Separate sub-accounts will be created for each fund and these accounts will be kept separate from the TMSF’s own assets.

Amounts in the recovery accounts may be used only for the liquidation of the relevant fund and payments to fund unit holders. These amounts cannot be used for other purposes, pledged as collateral, or seized for any claim, including public debts. No precautionary measures or precautionary seizures may be imposed on assets held in the accounts.

After deducting mandatory expenses, the remaining amount in the recovery account will be transferred to the institution assigned to liquidation for funds still undergoing liquidation. For fully liquidated funds, amounts will be sent to the Investor Compensation Center (ICC) for payment to fund unit holders as notified by the CMB. Payments will be made by the ICC according to the proportion of fund unit ownership.

In payments other than the final distribution, if the amount allocated to a fund unit holder falls below the minimum payment amount determined by the CMB, the amount will be recorded in the investor’s name. This amount will be added to future entitlements and paid once the accumulated amount reaches the minimum payment threshold.

If an asset value is linked to multiple funds, the CMB will determine the procedures and principles for allocating the amount among the funds. In this determination, criteria such as fund types, liquidity adequacy ratio, fund unit ownership structure, investor protection, and liquidation rate of the relevant funds will be considered.

When deemed necessary for the implementation of the law, the Board Decision Body may authorize the Capital Markets Board (CMB) and the Investor Compensation Center (ICC) to procure external services under conditions determined by the Board. In this context, services such as legal representation, accounting, and software development may be obtained for the execution of tasks arising from implementation and for litigation and follow-up proceedings.

Procedures and principles regarding implementation of the regulation will be determined by the CMB after obtaining the opinion of the Savings Deposit Insurance Fund (TMSF) on matters within its jurisdiction. In cases not covered by the regulation, provisions of the Capital Markets Law, Criminal Procedure Code (CPC), and Banking Law that are not contrary to the regulation will apply.

Capital Markets Board (CMB) has imposed a trading ban on 48 natural persons and five legal entities due to transactions conducted on the equity markets of Altınkılıç Gıda ve Süt Sanayi Ticaret AŞ and Anel Elektrik Proje Taahhüt ve Ticaret AŞ. Following the investigation, the CMB decided to file criminal complaints against 48 natural persons and impose trading bans; licenses of 28 natural persons were revoked.

Additionally, trading bans were imposed on Tera Portföy Yönetimi AŞ, Tera Yatırım Menkul Değerler AŞ, Tera Yatırım Bankası AŞ, Tera Yatırım Holding AŞ, and Century City Securities SA. The duration of the trading bans and the names of natural persons involved were not disclosed.

On 22 October 2026, the CMB issued a press release titled “Press Announcement on Settlement Finality and PBLK Issues.” The announcement noted that some confusion had arisen in public opinion regarding the application of settlement finality and share blockage under the bill under discussion in the Grand National Assembly of Türkiye.

The first paragraph of Article 79 of the Capital Markets Law stipulates that settlement instructions, settlement operations, and payment obligations related to capital market instruments remain irrevocable and non-cancelable even if the activities of the relevant institutions are suspended or enter liquidation. The provision aims to preserve confidence in capital markets by ensuring that settlement obligations are fulfilled in an irrevocable manner.

The CMB clarified that this provision does not apply to all instructions given through the Turkish Electronic Fund Buy-Sell Platform (TEFAS) regardless of the stage of the transaction. Unlike classical organized markets, TEFAS is a platform enabling investors to purchase fund participation units directly from the fund founder and return them to the founder. Therefore, each sale instruction transmitted via TEFAS does not inherently constitute a completed settlement transaction.

The CMB stated that, particularly for investors in PBLK status, the submission of a sale instruction or the existence of a record in the system does not alone signify the commencement of a settlement transaction. The settlement transaction is completed only when cash is transferred to the investor’s account and the fund participation unit ownership record is removed.

The CMB assessed that including unsettled instructions in the liquidation scope will contribute to the fair distribution of fund assets among investors. It was clarified that individuals with a share blockage record are included among the total of 455,758 fund unit holders and do not constitute a separate investor group.

The CMB stated that the regulation in the bill does not affect completed transactions but applies only to instructions whose settlement process has not yet been completed. These instructions will be evaluated under equal conditions with other participation unit holders based on amounts obtained from liquidation. The primary purpose of the regulation is to clarify the legal status of fund unit holders and make their rights during liquidation explicit. The CMB evaluated the regulation as a necessary and proportionate approach.

The CMB extended the deadline for investment funds to fully comply with portfolio and investment restrictions to 31 January 2027. Accordingly, certain provisions of the Guide to Investment Funds have been amended. The provision regulating exceptions for public institutions and subsidiaries regarding investments in cash and capital market instruments has been removed, subject to the preservation of similar provisions in the Principles Regarding Investment Funds.

The compliance schedule has been updated in light of recent market developments. The previous schedule provided for phased compliance on 31 October 2026 and 30 November 2026, with full and final compliance by 31 December 2026. Under the new regulation, the deadline for full compliance with portfolio and investment restrictions is set at 31 January 2027 without phased compliance requirements.

On 27 October, as part of the fund investigation, Hakan Gövdere, Elif Özüş, Elif Değerli and Rıza Kandemir were taken into custody. After completing procedures at the police station, three suspects were transferred to the Istanbul Courthouse.

The statements of all four suspects before the prosecutor’s office have been completed. Hakan Gövdere and Rıza Kandemir were referred to the peace criminal court with a request for detention. Elif Özüş was sent to the court with a request for a judicial measure of “travel ban”, while Elif Değerli was referred with a request for “non-removal from residence” as a judicial measure.

On 28 October, the court decided to detain Hakan Gövdere and Rıza Kandemir. It also ruled that judicial measures should be applied to Elif Özüş and Elif Değerli. The specific types of judicial measures were not specified.

With these decisions, the number of detained individuals has risen to 120.

As part of the investigation, the court lifted the asset freeze measures imposed on Fatih Erdoğan, Chairman of the Board of Pasific Holding, Abdulkerim Fırat, Deputy Chairman of the Board, and Mehmet Erdoğan, Board Member. The prosecutor’s office stated that the investigation was conducted on charges of “money laundering” derived from the principal offenses of “violation of the Capital Markets Law” and “qualified fraud”. It was noted that obligations were imposed requiring the reporting of unusual changes in the assets of individuals under investigation and seeking the opinion of the Chief Public Prosecutor’s Office to prevent fraudulent transactions.

The statement included the following: “The Capital Markets Board’s bulletin dated 27 October 2026 and numbered 2026/77 reported a complaint regarding the shares of Pasific Eurasia Logistics Foreign Trade Inc. (PASEU), and it was indicated that Fatih Erdoğan, Mehmet Erdoğan and Abdulkerim Fırat were not among those named in the complaint. Upon reassessment of the evidence, it was determined that there was no need for precautionary measures against the suspects at this stage, and therefore it was decided to lift the asset freeze measures and suspension orders concerning the individuals named.”

The Law on Certain Investment Funds Ordered for Liquidation was published in the Official Gazette on 27 October 2026 and entered into force.

The Capital Markets Board decided to temporarily suspend the capital markets activities of Tera Portfolio Management Inc. and Pusula Portfolio Management Inc. The Board also decided to include the investment funds and real estate investment funds, as well as venture capital investment funds, established by these companies but closed for operations and not yet liquidated, into the liquidation process. Türkiye İş Bankası was appointed to manage the liquidation of funds established by Tera Portfolio Management Inc., and Ziraat Bankası was appointed to manage the liquidation of funds established by Pusula Portfolio Management Inc. The decision was published on the CMB’s website.

The Capital Markets Board decided to revoke all operating licenses and authorizations of Tera Investment Securities AŞ, to compensate its investors, and to initiate the gradual liquidation of the company. The same bulletin also decided to initiate the necessary legal procedures to block access to five websites in order to prevent unauthorized activities in the capital markets.

The Board decided to file criminal complaints against 50 individuals; to impose a two-year trading ban on 51 individuals and on Aura Portfolio Management Inc, Tera Investment Securities AŞ, Tera Portfolio Management Inc, and MAG Agricultural Products Marketing and Trade Inc in the stock exchange and other organized markets; and to apply license revocation penalties against 31 individuals. The Capital Markets Board also decided to approve the request to increase the capital of Piramit Securities AŞ from 300 million liras to 500 million liras through an amendment to its articles of association.

The Capital Markets Board stated that it had observed in recent media and social media outlets allegations that are “unfounded and not based on concrete information or evidence” regarding the activities and investment positions of foreign financial institutions in Türkiye’s capital markets.

The Board’s statement included the following: “Our assessments have determined that the claims suggesting foreign financial institutions have made excessive profits, that some have exited after achieving high returns, closed their entire positions, and fully divested their holdings in certain capital market instruments, do not reflect the truth.”

The statement further emphasized that the regulatory processes conducted by the Board are carried out in accordance with the principles of transparency and predictability, with input from relevant stakeholders, and that draft and final regulations are simultaneously published to the public without distinction between domestic and foreign investors.

The Eighth Fund Coordination Board Meeting was held under the chairmanship of Vice President Cevdet Yılmaz, with participation from representatives of the Ministry of Justice, the Ministry of Treasury and Finance, and their affiliated institutions. Although the date of the meeting was not specified, the announcement was issued on 28 October 2026. According to the Presidential Communication Directorate’s announcement, the first interim payments for funds under extraordinary liquidation are expected to begin on Friday, 30 October 2026, as stipulated by Law No. 7596 and the relevant Capital Markets Board Regulation.

The announcement stated: “Pursuant to previous decisions of the Fund Coordination Board, Law No. 7596 on Certain Investment Funds Ordered for Liquidation, which establishes fair, transparent, and effective liquidation procedures and ensures legal safeguards for payments, was published in the Official Gazette on 27 October 2026 and entered into force. Under Law No. 7596, the Capital Markets Board’s Decision No. 76/1903 dated 27 October 2026 also defined the procedures and principles for liquidation and payments.”

According to the announcement, as of 23 October 2026, the liquidation process for 27 out of 31 funds established by Hedef Portfolio Management Company Inc, for which liquidation payments began following the Capital Markets Board’s 15 October 2026 decision, has been largely completed. In this context, a total of 27.2 billion liras have been paid to 26,152 accounts; work continues on the liquidation of the remaining four funds in the group. The Communication Directorate reported that the number of funds undergoing liquidation since the beginning of the process has decreased from 131 to 38, and that a total of 68 billion liras in cash and in-kind liquidation payments have been made to 71,899 accounts.

The announcement also noted that repayments to accounts established under the Savings Deposit Insurance Fund are ongoing, and that MASAK continues its international investigations into companies subject to fund inquiries, individuals suspected of manipulation, and the ultimate beneficial owners of suspicious transactions and funds. It was stated that technical preparations for a draft law containing structural measures to prevent recurrence of similar problems will be accelerated and that the finalized draft, after consultation with sector stakeholders, will be submitted to Parliament for consideration.