{"id":"TUR-022","notes":"The 2022 legislative amendments illustrate how international compliance frameworks (FATF) can be selectively implemented to create new domestic repression tools. The administrative suspension mechanism is particularly dangerous because it sidesteps the judicial process, removing the last avenue of formal legal challenge available to targeted organizations. | DATE CHECK: the administrative suspension power described here was introduced by Law No. 7262 (27 Dec 2020, see TUR-034); verify whether March 2022 refers to a separate amendment. | Additional tactic: TC-24","country":"Turkey","sources":[{"url":null,"citation":"ICNL Turkey Legislative Monitor 2022; CIVICUS Monitor Turkey 2022; Human Rights Watch reporting on FATF greylisting weaponization; European Commission Turkey Progress Report 2022"}],"summary":"In March 2022, Turkey enacted amendments to the Law on the Prevention of Financing of Terrorism and the Law on Associations, introducing new provisions allowing the suspension of civil society organizations by administrative order — without judicial oversight — if they are suspected of financing terrorism. The laws created a new category of 'administrative suspension' that could be applied pending investigation, effectively closing organizations for months without any criminal finding. Human rights organizations warned the provisions could be weaponized against any CSO whose work touched on issues deemed sensitive by the government. The amendments came as Turkey was seeking FATF removal from the greylist.","tactics":[{"code":"TC-18","role":"primary","label":"Legislative Operationalization","needs_review":false},{"code":"TC-19","role":"secondary","label":"AML/CFT Framework Weaponization","needs_review":false}],"version":1,"channels":["Legislation, Parliamentary Process, Administrative Mechanism"],"entities":[{"id":1107,"name":"AKP Parliamentary Group, Ministry of Interior, Financial Crimes Investigation Board (MASAK)","role":"actor","entity_type":"Senior Official / Legislature / Administrative Body"},{"id":1108,"name":"Civil society organizations, human rights defenders","role":"target","entity_type":"Sector-wide"}],"date_text":"2022-03-31","created_at":"2026-09-24T17:50:55.358311+00:00","escalation":5,"harm_track":"Track 1","narratives":[{"code":"LEGACY-N-e74436c0a03e","role":"primary","label":"Terrorism Financing Risk","needs_review":true},{"code":"LEGACY-N-9b7c809c7926","role":"secondary","label":"National Security","needs_review":true}],"report_ids":[],"signal_ids":[],"updated_at":"2026-09-24T17:50:55.358311+00:00","occurred_on":"2022-03-31","campaign_ids":["TUR-CAMP-004"],"enabler_type":"","response_ids":[],"trigger_type":"FATF greylisting compliance used as pretext; ongoing need to control CSO sector","campaign_phase":"Legislative Operationalization","civic_response":"Turkish civil society organizations published joint legal analyses; ICNL submitted formal critique; international NGOs engaged FATF directly on weaponization concerns; EU issued formal statement","date_precision":"day","enabler_status":"","campaigns_served":[],"consequence_category":"Restrictive Legislation / Administrative Suspension Mechanism","institutional_consequence":"New legal mechanism for administrative CSO suspension without judicial review; increased self-censorship among CSOs; FATF compliance framing normalized financial surveillance of civil society"}
