{"id":"TUR-043","notes":"Operationalization of Law 7262 (TUR-034) risk-based system; FATF grey-listing (TUR-038) provides international legitimacy cover; disproportionate impact on rights-based vs. service-delivery CSOs is key analytical finding","country":"Turkey","sources":[{"url":null,"citation":"TUSEV CSO Monitoring Matrix Turkey 2022-2023; MASAK audit notifications; DGRCS consultation records"}],"summary":"DGRCS (Directorate General of Civil Society Relations) and MASAK (Financial Crimes Investigation Board) implemented the risk-based classification system established by Law No. 7262, operationalizing audit categories across Turkish civil society. Organizations classified as 'high risk' — predominantly those receiving foreign funding, engaged in human rights or advocacy work, or connected to international networks — became subject to mandatory financial audits by MASAK investigators. CSOs reported receiving audit letters from governorships and MASAK with short response windows. Multiple organizations underwent multiple audits within a 12-month period. The DGRCS also organized joint consultation meetings with sector representatives in 2022-2023 — the first structured government-CSO dialogue on Law 7262 implementation, which TUSEV documented as a positive if insufficient development.","tactics":[{"code":"TC-19","role":"primary","label":"AML/CFT Framework Weaponization","needs_review":false},{"code":"TC-24","role":"secondary","label":"Administrative CSO Burdening","needs_review":false}],"version":1,"channels":["banking system","DGRCS","Governorships","MASAK"],"entities":[{"id":1133,"name":"MASAK; DGRCS; Ministry of Interior; Governorships","role":"actor","entity_type":"State; Financial Intelligence Unit"},{"id":1134,"name":"Rights-based and foreign-funded CSOs classified as high-risk; all associations subject to MASAK reporting","role":"target","entity_type":"CSO"}],"date_text":"01/01/2022","created_at":"2026-09-24T17:50:55.358311+00:00","escalation":4,"harm_track":"Track 1 — Organisational Integrity","narratives":[{"code":"NF-10","role":"primary","label":"Sovereignty Protection / State Security Infrastructure","needs_review":false},{"code":"NF-01","role":"secondary","label":"Foreign Agent / Foreign Influence","needs_review":false}],"report_ids":[],"signal_ids":[],"updated_at":"2026-09-24T17:50:55.358311+00:00","occurred_on":"2022-01-01","campaign_ids":["TUR-CAMP-004"],"enabler_type":"","response_ids":[],"trigger_type":"TR-08: Proactive / Ambient","campaign_phase":"Phase 3: Enforcement Intensification","civic_response":"TUSEV documented burden in qualitative research; DGRCS consultation meetings used by sector to raise implementation concerns; foreign donors imposed additional compliance layers on grantees; FATF grey-list removal process ongoing","date_precision":"day","enabler_status":"","campaigns_served":[],"consequence_category":"Financial Surveillance; AML/CFT Weaponization; Selective Administrative Targeting","institutional_consequence":"Rights-based and internationally-funded CSOs bear disproportionate audit burden; multiple audits within 12 months reported; foreign donation volumes declining; self-censorship on advocacy activities documented; first DGRCS-sector consultation meetings also held (positive but insufficient)"}