Sanctions to be Implemented in Violation of STR Obligation
Legal Framework of STR
Definition of Suspicious Transaction
Those who are obliged to Report Suspicious Transac...
Confidentiality of Reporting
Protection of Obliged Parties
The Time Allowed For Reporting Suspicious Transact...
Suspicious Transactions Types
Submission of Suspicious Transaction Reports by Ha...
Submission of Suspicious Transaction Reports Elect...
Principles and Procedures for Suspicious Transacti...
Period in Suspicious Transaction Reporting
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Sanctions to be Implemented in Violation of STR Obligation

Judicial Penalty
According to Article 14 of Law No.5549; the obliged parties shall be sentenced to imprisonment from one year to three years and to judicial fine up to five thousand days in case that they violate the obligation stated in paragraph (2) of Article 4 of the same Law regarding not giving information to anybody that they report the suspicious transactions, other than the examiners assigned to conduct supervision of obligations and the courts during legal proceedings.

Administrative Fine

According to Article 13 of Law No. 5549, the obliged parties shall be punished with an administrative fine of five thousand New Turkish Liras by the Presidency in case that they violate the obligation stated in Paragraph (1) of Article 4 regarding suspicious transaction reporting. If the obliged party is a bank, finance company, factoring company, money lender, financial leasing company, insurance and reinsurance company, pension company, capital market institution or bureau de change, administrative fine shall be applied two-fold.

The total amount of administrative fines applied within the year of the violation of suspicious transaction reporting cannot exceed ten million Turkish Liras for obliged parties that will be punished with a twofold fine and one million Turkish Liras for other obliged parties. If the obliged parties subject to upper limit on fines make same kind of failure to comply with obligation in the following year, the limit shall be applied twofold.

With the amendments in Law No. 5549 dated 18.06.2014, the employees of obliged parties shall no longer be punished with administrative fine in case of violation of obligations.
Administrative fine cannot be imposed after five years from the date of violation of obligation.

Amount of Administrative Fines

According to Article 17 (7) of Misdemeanor Law No.5326; “The administrative fines are implemented as being valid from the beginning of each calendar year by increasing in the ratio of revaluation for that year determined and announced in accordance with provisions of Article reiterated 298 of tax Procedural Law No.213 dated 4.1.1961. By this means, in calculation of administrative fine, the fraction of one Turkish Liras is not taken into consideration”.

Accordingly, the amount of administrative fine to be imposed in violation of obligation of suspicious transaction reporting by years is shown in the table below.


The obliged party whom an administrative fine to be imposed

For violations in 2010 (TL)

For violations in 2011 (TL)

For violations in 2012 (TL)

For violations in 2013 (TL)

For violations in 2014 (TL)

Obliged party
(Law No.5549 Article 13/1)






Obliged party (two fold fine) (Law No.5549 Article 13/1)