Country Manual Private Banking
Turkey – Update 2024
BRP has updated its Country Manual Private Banking for Turkey out of Bank’s Country of Establishment (DEF, RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
We have reviewed the documents following consultations with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.
Notwithstanding the foregoing, the country manual has been updated to reflect the evolution of the expert’s interpretation of the regulatory framework in the following points:
We have underlined that activities relating to the provision of documentation to the EAM for the clients’ attention must be carried out on an occasional basis to avoid the risk of agency or permanent establishment in Turkey.
The condition for acting on-site in Turkey on a one-to-one basis has been removed for certain activities (such as presenting the Bank in general terms or providing general macroeconomic information). Our local lawyers have indeed confirmed that it is sufficient for the information to be generic in nature, without having to rely on the one-to-one exception.
Foreign exchange control rules: the list of companies exempted to generate foreign income in order to borrow foreign currency has been revised, and the reporting requirements have been extended.
Non-material changes
The document has been reformatted onto the latest template. Many answers in the RT and RS have been re-worded, to provide more clarity and a more detailed explanation.
Implications for business relations with third parties
The documents having been reformatted onto the latest template, this section now provides for more answers, better distinguishing between the provision of documentation to the EAM for its own use and provision of documentation for its subsequent distribution to end-clients.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “TURKEY” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
For more information, please contact us: info@brpsa.com
Geneva, November 1st, 2024