TCMA 2020 ANNUAL REPORT

established Cyber Incident Response Teams (CIRT) were submitted to the CMB. Cooperation between MASAK and the Association T.R. Ministry of Treasury and Finance Financial Crimes Investigation Board (MASAK) continues to work in close collaboration and coordination with principally financial institutions and all the other obliged parties for ensuring effective implementation of preventive measures in relation to combating laundering and financing of terrorism. The Association and MASAK conducted collaborative efforts targeting obliged groups for increasing our members’ awareness of the topic, who have important obligations in relation to preventive measures in combating the laundering proceeds from crime and financing of terrorism pursuant to the Law no. 5549 and applicable legislation, for increasing the effectiveness in the enforcement of the applicable legislation, and for mutually deliberating on the current issues in relation to practice. FATF Meetings with MASAK Officials T.R. Ministry of Treasury and Finance Financial Crimes Investigation Board (MASAK) scheduled meetings between 3 and 5 February 2020 participated by representatives from Turkish financial institutions in order to discuss the 4 th Round Mutual Evaluation of Turkey Report of the Financial Action Task Force (FATF) and to co-determine with MASAK the actions to be established by obliged groups for the issues. Accordingly, a meeting was held on 4 February 2020 with representatives from 13 intermediary institutions and 5 asset management companies, for a total of 18 members representing our sector. In the meetings participated also by MASAK officials, the attendants discussed the activities to be undertaken for; • Compiling the data and statistical information that will form the basis for revealing the risk of money laundering and terrorist financing in the capital market, • Preparation of the national risk assessment report in relation to the capital market activities, • Determination of the measures in relation to the issues by the obliged groups, and a new roadmap was defined in line with the timeline that will be followed in the process. Activities Associated with the FATF 4 th Round Mutual Evaluation of Turkey As a result of the consultations with the T.R. Ministry of Treasury and Finance Financial Crimes Investigation Board (MASAK) officials regarding the activities to be undertaken by related institutions and organizations under the responsibility and coordination of MASAK during 2020, our Association was requested to perform a risk assessment and to submit the outcomes to MASAK in relation to the Evaluation of Turkey Report released in December 2019 by the Financial Action Task Force (FATF), of which our Association is also a member. “Capital Market National Risk Assessment Report” compiled together with the MASAK Task Force participants at our Association and the financial data for the Association members were submitted to MASAK. As part of the related activities, a questionnaire was administered to form the basis of the “National Risk Assessment Report” to be prepared for determining our members’ anti-money laundering and combating the financing of terrorism (AML/CFT) capabilities and identifying improvement areas. The set of questions MASAK provided for risk assessment to our Association was adapted and improved for the sector by our Association, and answered by member intermediary institutions, asset management companies and investment trusts. The questionnaire covered questions regarding the activities of intermediary institutions, asset management companies and investment trusts under the following headings: • Policies, procedures and compliance program • Organization and Governance • Implementation (Know-Your-Customer, monitoring, suspicious transaction reporting) • Audit • Training The outcomes of the questionnaire were submitted to MASAK for incorporation in the “Capital Market National Risk Assessment Report”. In response to further demand by MASAK, a separate questionnaire was administered regarding the measures adopted in our sector on the basis of activity. Risk assessment report for the overall sector and on the basis of companies, INITIATIVES 26 TCMA 2020 ANNUAL REPORT