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.