TCMA 2020 ANNUAL REPORT

which also included residual risk calculation in view of risk measurements inherent in all activities of our members and the measures/actions taken, was submitted to MASAK. Within the scope of the FATF 4 th Round Mutual Evaluation of Turkey Report, informative activities were carried out to raise increased awareness of: • Improved AML/CFT risk perception, • Knowing the real beneficiary, • Suspicious Transaction Reporting reports, • High-risk situations and stricter measures that need to be adopted in such cases, • Implementation of targeted financial sanctions. Suspicious Transactions Reporting Guidance and Forms In relation to the Financial Action Task Force (FATF) 4 th Round Mutual Evaluation of Turkey Report; in order to improve the quality and nature of suspicious transaction reports (STRs) and catering to the needs of liable parties for submission of STRs, Financial Crimes Investigation Board (MASAK) updated the “Suspicious Transaction Reporting Guidance (Capital Market Intermediary Institutions)” and Suspicious Transaction Reporting Form”. The feedbacks on related forms, compiling the opinions and suggestions presented to our Association, were submitted to MASAK. Financing of the Proliferation of Weapons of Mass Destruction Within the frame of the decisions passed in the general assembly meetings of the Financial Action Task Force (FATF) held in June 2020, it was decided that the recommendations in relation to the revision of FATF recommendations and explanatory notes for improving the combat against the financing of proliferation of weapons of mass destruction conducted by FATF will be negotiated by financial institutions, certain non-financial businesses and professions, and other related stakeholders. Accordingly, suggested revisions to FATF guidance and explanatory notes were submitted to our members for their feedback and suggestions in line with the demand from the T.R. Ministry of Treasury and Finance Financial Crimes Investigation Board (MASAK). Our members’ opinions that FATF efforts and changes in relation to the proliferation of financing are critical and essential, and their suggestions were submitted to MASAK. Contracts to be Concluded with Customers for Capital Market Transactions Following the feedbacks and suggestions submitted by the Association prior to the amendment of the Law and the Association’s endeavors within the scope of the activities of the Grand National Assembly of Turkey (GNAT) the Committee on Plan and Budget concerning the law amendment, the Law Amending Certain Laws and Statutory Decrees published in the Official Gazette dated 26 June 2020 set out the requirements for: • Customer contracts that can be established from a distance with the use of distance communication tools; or contracts, whether or not distance, which will be established by means of methods that may replace the written form as determined by the Capital Markets Board of Turkey (CMB) and that may be realized through information or electronic communication devices enabling verification of the customer’s identity, • Our members’ access to identification data, settlement and other address data stored on the central database of the T.R. Ministry of Interior Directorate General of Civil Registration and Citizenship Affairs. The Association started working particularly on determining the methods that will allow contracts, distance or otherwise, to be concluded through an information or electronic communication device, and that will allow verification of the customer’s identity. The feedbacks and suggestions developed by the technical working group set up at the Association regarding methods that will allow verification of customer identity in contracts, distance or otherwise, to be concluded by intermediary institutions or asset management companies through an information or electronic communication device were submitted to the T.R. Ministry of Treasury and Finance Financial Crimes Investigation Board (MASAK) and the CMB. TCMA 2020 ANNUAL REPORT 27