Establishing a Financial Institution in Turkey: overview

A Q&A guide to establishing a financial institution in Turkey.

This Q&A gives an overview of the key issues in establishing a financial institution in Turkey, including the principal governing regulations, the commonly used legal structures, the licences, the authorisations and the tax position.

This article is part of the global guide to establishing a financial institution worldwide.

Piraye Kuranel Başol, Ayşegül Özmen, Begüm Femir, Hergüner Bilgen Özeke Attorney Partnership
Contents

Market trends

1. What were the main trends in the financial services industry in the last 12 months?

Banking institutions

Over the past year, Turkey has seen the successful implementation and completion of projects commonly financed using public-private partnership loans and syndicated loans. These projects have involved the participation of various parties, including governmental authorities and local and foreign banks and sponsors. The government and administrative authorities have demonstrated a continuing interest in investing in these and similar financing projects, such as the Dardanelles Straits Project. According to government sources this project is due to begin construction in 2017, although it has not yet been tendered.

There has been a substantial and continuing growth in consumer loans and mortgage loans over recent years. The Regulation on Consumer Credit Agreements, in force since 22 November 2015, made significant changes to consumer bank credits in the following ways:

  • Giving bank customers the right to withdraw from customer credit agreements within fourteen days, without the need to offer any justification or pay any penalty.

  • Stating that banks cannot insure the credit without an explicit request from the consumer.

  • Requiring that consumers be informed that no compound interest will be applied to any transaction regarding the loan agreements, including default interest.

  • Obliging the lender to discount contractual interest if the customer makes early payment of an undue instalment or repays the loan.

The Regulation Amending the Regulation on Debit Cards and Credit Cards came into force on 27 September 2016. This financing regulation increased instalment periods from nine months to twelve months. It also provided that the purchase of certain goods by credit card cannot be repaid in instalments. These goods include telecommunication goods, cosmetic products, payments made abroad, and consumables such as food and alcoholic beverages.

Insurance institutions

The Private Pension Savings and Investment System Law (Law 4632) (Private Pension Law) was amended to require the automatic enrolment of employees to the private pension system. This became effective on 1 January 2017. The current private pension system is voluntary, and participants are entitled to choose among different plans, depending on the amount they wish to contribute and the amount they hope to receive on retirement. It complements the compulsory state-based pension system, which obligates both the employee and the employer to make compulsory contributions. Under the amended Private Pension Law, the individual private pension system will become compulsory, with automatic enrolment for all non-foreign employees under the age of 45 who meet certain qualifications. However, an employee has opt-out rights within the first two months of enrolment.

Investment institutions

Amendments to the Regulation on Asset Management Companies were announced on 5 March 2016, changing the minimum capital requirements of asset management companies and the documents required from foreign persons. The amendments also require the permission of the Banking Regulatory and Supervision Board for certain transactions including:

  • Acquiring over 50% of an asset management company.

  • Changing control of a company.

  • Issuing new privileged shares.

  • Granting or revoking privileges over current shares.

The amendments expanded the intermediary, support, and consultancy services that can be provided by asset management companies. These now include collection, restructuring, and sales of assets and receivables to third parties arising from bank services, the Savings Deposit Insurance Fund, and other financial institutions and insurance companies that provide loan insurance services.

 

Regulatory framework

2. What are the relevant principal regulations for financial services in your jurisdiction?

Banking institutions

The Banking Law (Law 5411) and a wide range of secondary legislation issued under the Banking Law govern banks and other financial institutions that provide financial services, including:

  • Deposit banks.

  • Participation banks.

  • Development banks.

  • Investment banks.

  • Financial holding companies.

The purpose of the Banking Law is to regulate principles and procedures for ensuring confidence and stability in financial markets, efficient functioning of the credit system, and the protection of depositors' rights and interests. The secondary legislation is relatively broad, regulating various particular banking services as well as the operations of asset management companies.

The Payment and Security Settlement Systems, Payment Services, and Electronic Money Institutions Law (Law 6493) was enacted in 2013 to regulate procedures and principles for payment and security settlement systems, payment services, payment institutions, and electronic money institutions. It was followed by secondary legislation including the:

  • Regulation on Payment Services, Electronic Money Issuance, Payment Institutions and Electronic Money Institutions.

  • Communiqué on the Management and Inspection of Information Systems of Payment and Electronic Money Institutions.

The Financial Leasing, Factoring and Finance Companies Law (Law 6361) sets out the principles governing financial leasing, factoring and finance companies.

Insurance institutions

The Insurance Law (Law 5684) and the Regulation on the Principles for Incorporation and Operation of Insurance and Reinsurance Companies govern insurance and reinsurance activities by insurance companies, reinsurance companies, intermediaries, actuaries and insurance experts in Turkey. In addition, the Private Pension Law and the Regulation on Incorporation and Governance of Private Pension Companies governs the establishment and operation of pension funds.

Investment institutions

The Capital Markets Law (Law 6362) governs investment institutions and intermediary companies to ensure the functioning and development of capital markets in a secure, transparent, efficient, stable, fair, and competitive environment, and protect the rights and interests of investors. Additionally, various pieces of secondary legislation focused on different investment services and institutions thoroughly regulate the establishment, authorisation, activities, and services of investment institutions.

 
3. What are the principal regulatory bodies for financial services in your jurisdiction?

Banking Regulatory and Supervision Agency

The Banking Regulatory and Supervision Agency (BRSA) maintains the financial markets, provides for efficient operation of the credit system and encourages development of the financial sector. The BRSA is responsible for regulating banks, financial holding companies and with some legislative exceptions, leasing, factoring, and finance companies. This includes overseeing, and supervising their establishment, operation, management, organisational structure, mergers and acquisitions, exchanges of shares, and liquidations. The Banking Regulatory and Supervision Board (Banking Board) is the executive body of the BRSA.

The BRSA and the Turkish Central Bank (TCB) also supervise payment services and e-money activities. While the TCB is authorised to grant licences to system operators, the BRSA has the authority to grant operation licences to payment institutions and e-money institutions, as well as to oversee the activities of asset management companies.

The Central Bank of the Republic of Turkey

Under the Law on the Central Bank of Republic of Turkey (Law 1211) the TCB is authorised to directly determine monetary policy for the purpose of maintaining price stability, which is its principal duty. Its other duties include conducting open market transactions, taking measures to protect the value of the Turkish currency, managing gold and foreign exchange reserves, and monitoring financial markets. The TCB is the sole authority for issuing banknotes. It is also authorised to extend loans to banks, as the lender of last resort, and to set interest rates.

Capital Markets Board

The Capital Markets Board of Turkey regulates and promotes the principles of fairness, transparency and stability in equity and debt markets. It has the authority under the Capital Markets Law (Law 6362) and relevant secondary legislation to strictly supervise institutions that are subject to the capital markets regulations.

Undersecretary of the Treasury

The Undersecretary of the Treasury manages public financial assets and liabilities; regulates, implements, and supervises economic, financial, and sectoral policies. It also co-ordinates international economic relations in co-operation with all economic actors. The Treasury supervises the entire insurance sector under the Insurance Law (Law 5684) (see Question 6). Within the Treasury, the Insurance Supervisory Board supervises, audits, and investigates the activities of insurance companies, and the General Directorate of Insurance drafts, implements, and monitors insurance legislation.

See box, The regulatory authorities.

 
4. What financial services (if any) fall outside the scope of/are exempted from regulation?

All banking, insurance and investment services are strictly subject to legislation and supervising authorities. The legislation is generally broad enough to capture almost all activities and institutions in each sector. However, certain services are exempt from the scope of the laws. For example, the Insurance Law stipulates that social security institutions, the Export Credit Bank of Turkey (Eximbank) and other establishments operating in the insurance sector in accordance with their special laws are not subject to the Insurance Law (other than relevant provisions governing supervision of the Insurance Law).

 

Legal structures

5. What are the most commonly used legal structures for establishing a financial institution?

Local companies

All local and foreign banks, financial leasing, factoring and finance companies, payment and e-money institutions, intermediary, and investment companies established in Turkey must be established as a joint-stock company (JSC). In addition, a bank must meet certain other bank-specific criteria. These include having:

  • Registered shares that are issued in cash.

  • A minimum amount of share capital.

  • Founders and board members who meet certain qualifications.

  • A transparent and open structure for efficient supervision.

Full criteria are provided in the Banking Law and the Banking Regulation.

An insurance or reinsurance company in Turkey can be formed as a JSC or a co-operative company. Co-operative companies have advantageous budget requirements, but in practice insurance and reinsurance companies most frequently establish as a JSC.

Foreign companies

Foreign banks and branches of foreign banks can conduct banking activities in Turkey provided they obtain necessary local licences and approvals (see Question 6), and comply with all other requirements for establishing a local bank. In addition, the primary activities of a foreign bank establishing a branch in Turkey must not have been prohibited in the country where it is headquartered, and the supervisory authority in that country must have no opposition to the bank's operation in Turkey.

A foreign bank can also open a representative office in Turkey with the permission of the Banking Regulatory and Supervision Authority, provided it does not accept deposits or participation funds. Only one representative can work at a representative office of a bank. Banks wishing to open a representative office should have:

  • A strong financial position.

  • Equity not less than the minimum paid capital required for establishment of a bank in Turkey.

  • No restrictions on its activities

  • Been operating for at least three years.

Foreign-owned insurance and reinsurance companies can be formed in the same manner as Turkish insurance and reinsurance companies.

 

Authorisation or licensing

6. What licences or authorisations are required to provide financial services in your jurisdiction?

Banking institutions

There is a two-tier licensing procedure for establishing a bank in Turkey. A bank must obtain both an:

  • Establishment licence.

  • Operating licence.

Only banks licensed by the Banking Regulatory and Supervision Authority (BRSA) and branches of foreign banks are authorised to perform banking activities in Turkey. Conducting any banking activity without a licence is a crime under the Banking Law (Law 5411) and may lead to monetary fines and imprisonment for the persons involved.

Licence applicants must make all licence payments set out under the Law on Charges (Law 492) and that are relevant to its banking licence or the provision of financial services. Besides the Banking Law, the Regulation on the Transactions of Banks Subject to Approval and Indirect Shareholding (Banking Regulation) governs the establishment and operating principles of banks.

For an establishment licence, the applicant must submit its application along with the documentation required under the Banking Regulation. An establishment licence does not authorise a bank to commence its operations. Once the establishment licence is granted, the bank must be established as a legal entity (see Question 5).

Once established, the bank must register with the Trade Registry and an announcement of its establishment must be made in the Trade Registry Gazette.

An application for an operating licence must then be filed with the BRSA. The application for an operating licence must be made within nine months of the establishment licence having been issued, otherwise the establishment licence will be cancelled by the Banking Board.

Similar to the establishment licence, when considering an application for an operating licence, the Banking Board evaluates certain criteria, such as the payment of system entrance fees, share capital being fully paid to enable the execution of planned activities. The BRSA must notify the applicant of its decision regarding an operating licence within three months from the application date, or the date in which the applicant provides any missing application document. If any missing document is not provided within six months, the application becomes invalid.

If the Banking Board does not approve the application for an operating licence, the establishment licence will be cancelled.

An operating licence will be cancelled if a bank:

  • Fails to commence operations within six months.

  • Is inactive for an uninterrupted period of six months within any given year.

  • Has obtained the operating licence based on a non-factual declaration.

The Banking Board will cancel the operating licence of a foreign bank's branches in Turkey, if, the following circumstances occur in the country where the bank's headquarters is located:

  • Its operation licence has been cancelled.

  • Its activities have been suspended.

  • It has declared bankruptcy or liquidation in the country where it is established.

Financial leasing, factoring, and finance companies

Financial leasing, factoring and finance, companies must also apply to the Banking Board for an establishment licence and an operating licence. To be successful, an applicant must meet criteria under the Financial Leasing Law (Law 6361), which are similar to those of banks under the Banking Law. These include qualification requirements, time periods for applications, and the requirement to pay all fees. However, a financial leasing, factoring or finance company has one year from receipt of an operating licence to begin operations or its operating licence is cancelled.

System operators, payment service institutions, and e-money institutions

System operators must apply to the Turkish Central Bank (TCB) under the e-Money Law (see Question 3) for an operating licence to operate systems, other than those operated by banks. The criteria are similar to the requirements for banking institutions (see above, Banking institutions). The TCB will complete the process within six months from submission of all documents. As with a bank, a systems operator's operating licence will be cancelled if it fails to commence operations within six months of receiving its operating licence.

Payment institutions and electronic money institutions that are carrying out their activities (for example, issuance of electronic money) through banks must apply to the Banking Board to obtain an operating licence. To be successful in their application they must meet the conditions under the e-Money Law, which parallel the requirements for system operators. The Banking Board consults the TCB regarding the application, and may cancel a payment institution's operating licence for either:

  • A failure to commence operations within one year from receipt of the operating licence.

  • Renouncement by the payment institution of its licence.

  • Detection of a non-factual declaration or document submitted by the institution when obtaining the operating licence.

  • Failure to meet the requirements to obtain an operating licence, as determined under the E-money Law.

  • Failure to inform the BRSA of any change in the required information and documents.

  • Evaluation by the Banking Board that the activities of the payment institution endanger the safety of payments.

Pre-paid cards that are used to purchase a certain group of goods or service or solely used in a certain service network are exempted from such restriction as they are stated to be completely excluded from the scope of the E-money Law.

Insurance institutions

An insurance company must obtain an establishment licence from the Treasury (see Question 3) for each insurance branch it intends to operate. Once an insurance company has completed establishment formalities and requested an operating licence, it must increase its paid-up capital to an amount to be determined by the Treasury. If an application is successful, a licence will be granted within three months of receipt of all documents for an initial licence and two months for each subsequent licence. Within the scope of insurance services, insurance and reinsurance brokerage activities can only be performed under a licence granted by the Treasury.

Pension funds

The Pension Law requires private pension companies to apply to the Ministry of Finance. If the application is successful, the ministry will grant an establishment licence within two months of receiving all required documents.

Investment institutions

An investment institution must fulfill the conditions stipulated under the Capital Markets Law (Law 6362) to obtain an establishment license from the Capital Markets Board (CMB). Once established, it must apply to the CMB for an operating licence within six months of obtaining the establishment licence. The CMB will decide on the operating licence within six months from the submission of all required documents. If approved, an investment institution must pay a fee under the Law on Fees and has one month to submit a receipt for payment to the CMB, otherwise the operating licence will be cancelled.

Appeal process

A party can request an administrative authority to revoke, withdraw, or procure a new licence decision. The request must be made within sixty days of the party being notified of the decision. If there is no response to the request within sixty days, it is deemed to have been denied. The Banking Law (Law 5411) and the Insurance Law (Law 5684) refer specifically to this appeal process against decisions of the BRSA and the Insurance Supervisory Board respectively.

 
7. What approvals or licences are required for persons performing key roles at authorised financial institutions in your jurisdiction?

The relevant laws governing each of the banking, insurance, and investment sectors do not set out approval or licence requirements for persons performing key roles but the do regulate the qualification of board members. In general, board members must:

  • Not be declared bankrupt.

  • Not hold shares or control over a bank transferred to the Savings Deposit Insurance Fund.

  • Not hold qualified shares in or control over a bank (or other institution in the relevant sectors) that has been subject to liquidation, or certain types of financial institutions whose operating permissions have been revoked.

  • Not have been found guilty of certain crimes.

In addition to those requirements, general managers and assistant general managers of financial, insurance and investment institutions must meet certain criteria regarding educational background and work experience.

Finally, the relevant regulatory authorities must be notified of the appointment of a board member, general manager, or assistant general manager within certain time periods following their appointment. These education and experience criteria also apply to members of any investigation committee organised within a bank, the members of which must be qualified as managers under the legislation.

 
8. Are there any alternatives to authorisation available for entities carrying on financial services in your jurisdiction?

Banking, insurance, and investment services are strictly subject to mandatory licence requirements under applicable laws (see Question 6). Unlicensed activity is a crime under the regulatory framework and may result in monetary fines and imprisonment.

 

Restrictions on ownership or control

9. Are there any restrictions on the ownership or control of financial institutions in your jurisdiction?

The founder of a financial institution must meet requirements similar to those required for a member of the board of directors and a general manager (see Question 7). In addition, he or she must have the necessary financial capabilities, reputation, honesty and competence required for the business. If the institution's founding owner is a legal entity, the legal entity must have a transparent and open partnership structure.

Foreign persons are subject to the same requirements, and equivalent documents must be obtained from abroad, as evidence that the requirements are met.

Change of control requirements are explained separately below for each institution. In all cases "control" is defined as any of the following:

  • Direct holding of the majority of a company's share capital.

  • Holding privileged shares, regardless of the percentage held.

  • Having the right to appoint or dismiss board members in a number that forms a decision quorum (as per a shareholders agreement or otherwise).

A minimum holding of 51% is not required for control.

Banking institutions

Banks and e-money institutions. Banking Board approval is required for the following transactions causing a change of control in the ownership of banks and e-money institutions:

  • Any share transfer leading to the direct or indirect acquisition of a shareholding of more than 10%.

  • Any share transfer by which the direct or indirect shareholding of an existing shareholder exceeds or falls below 10%, 20%, 33% or 50%.

  • Transfer of shares with board or audit committee nomination privileges, regardless of the percentage acquired.

Banking Board approval is also required if there are changes in the shareholding structure of any company holding 10% or more of the shares in a bank, provided that the transferee entity has the qualifications that are required for the founding owners.

Financial leasing, factoring and finance companies

Banking Board approval is required for the following transactions causing change of control in the ownership of a financial leasing, factoring, or finance company:

  • Acquisition or change of control of a shareholding of 10% or more.

  • Transfer of shares with board nomination privileges, regardless of the percentage acquired.

Banking Board approval is also required for if there are changes in the shareholding structure of a legal entity holding 10% or more of the company's share capital.

Insurance institutions

The following transfers of shares are subject to the approval by the Treasury:

  • A direct or indirect transfer of shares that leads to a shareholder's portion of the share capital in an insurance company exceeding or falling below 10%, 20%, 33% or 50%.

  • Transfer of shares with board nomination privileges that have an effect over the audit or management of an insurance company, regardless of the percentage acquired.

Pension companies

At least 51% of the capital of a pension company must belong to a legal entity with adequate knowledge and experience in financial markets.

Persons who have an effect over the audit and management of an insurance company should meet the requirements for banking institutions, except for the financial capability condition (see Question 7).

The following changes in the control and ownership of a pension company are subject to approval by the Treasury:

  • Any share transfer leading to the direct or indirect acquisition of a shareholding of more than 10%.

  • Any share transfer by which the direct or indirect shareholding of an existing shareholder exceeds or falls below 10%, 20%, 33% or 50%.

  • Transfer of shares with board or audit committee nomination privileges, regardless of the percentage acquired.

Treasury approval is also required if there are changes in the shareholding structure of any company holding 10% or more of the shares in an insurance company.

Investment institutions

The following transactions that cause change of control in the ownership of a pension company are subject to approval by the Capital Markets Board (CMB):

  • Acquisition of a shareholding of 10% or more.

  • Any share transfer by which the direct or indirect shareholding of an existing shareholder exceeds or falls below 10%, 20%, 33% or 50%.

  • If the shareholder has management privileges, any share transfer leading to a change of 10%, 20%, 33%, or 50% in the capital structure of the shareholder.

  • Transfer of shares with management privileges, regardless of the percentage acquired.

The CMB must also be notified of any change in the shareholding structure of a legal entity even if it does not reach the above shareholding percentages.

 

Taxation

10. What main taxes are financial institutions subject to in your jurisdiction?

Stamp tax

Stamp tax duty varies depending on the nature of the documents to be stamped.

The following are exempt from stamp tax duty:

  • Documents on loans from banks and foreign financial institutions, and related security and repayment.

  • Certain agreements regarding capital market transactions and insurance undertakings.

A stamp tax payer must declare the duty payable on a document issued in the preceding month by informing the tax office in writing by the evening of the 23rd day each month. Certain tax payers, as determined by the Ministry of Finance, including banks, joint stock companies and certain public institutions, must make payments by the evening of the 26th day of the following month.

For other entities, stamp tax should be paid within 15 days following the execution of a relevant document.

Corporate tax

There are two types of corporate tax liability:

  • Full liability.

  • Partial liability.

Those with a full corporate tax liability are corporates whose legal or business headquarters are in Turkey. These entities must declare and pay their taxes based on their worldwide corporate income.

Companies with no legal or business headquarters in Turkey (that is, branches established by foreign banks in Turkey) have partial liability for corporate tax. They are liable for taxes only on corporate income earned in Turkey.

The Corporate Tax Law (Law 5520) sets out certain exemptions and discounts for payment of corporate tax. Corporate tax for a given year must be declared between the first and the 25th day of the fourth month of the following calendar year, and is payable before the end of the same month.

Value Added Tax

Value Added Tax (VAT) is payable on every transaction involving the production of goods or the performance of a service. It is also payable on the import of goods or services.

VAT is reported and paid monthly. Each month's VAT return must be submitted to the tax office by the 24th of the following month and paid by the 26th of the same month.

Subject to the VAT Law (Law 3065), for the purpose of calculating the VAT payable to the authorities, a taxpayer can offset (deduct) the VAT paid on goods and services provided to it against the VAT payable on goods and services supplied by it.

The general VAT rate in Turkey is 18%. However, reduced rates apply to:

  • Newspapers and magazines.

  • Houses up to 150 meters square.

  • Medical products and devices.

Banking and insurance transactions (excluding financial leasing activities) that are subject to Banking and Insurance Transaction Tax (see below) are exempted from VAT.

BITT

Banking and Insurance Transaction Tax (BITT) is a transaction revenue tax payable by banks and insurance companies on all transactions (that is, banking charges, insurance premiums, brokerage fees, capital gains, interest income), except for transactions carried out under the Financial Leasing Law.

The general BITT rate is 15%, although at the discretion of the Council of Ministers some transactions are subject to 1% or 0% BITT.

BITT is declared and paid monthly. A return must be made and the tax must be paid by the 15th day of the month following the month of the transaction.

Resource utilisation support fund levy (RUSF)

RUSF is a special type of levy applied to both domestic and foreign loans and is generally collected by Turkish intermediary financial institutions in Turkey.

The amount payable is based on the average maturity of a loan, its currency and the type of credit. For example, the RUSF percentage payable on a foreign bank loan with an average maturity of more than three years and made to a Turkish resident is 0%.

 
11. What is the tax position when profits are remitted abroad?

A dividend paid to an entity resident in Turkey or to a branch of a foreign company is not subject to withholding tax. However it is subject to corporate tax (see above, Corporate tax).

If profits are remitted abroad, a 15% withholding tax applies to the distributed dividend, unless the rate is reduced by a double taxation treaty. This 15% rate of withholding tax also applies to taxable profits that are repatriated by a branch to its headquarters, after the deduction of corporate income tax.

 

Proposals for reform

12. Are there any impending developments or proposals for significant reform?

No significant reform of relevant sectors is envisaged in the near future. However the Regulation on Provisions and Classification of Loans and Receivables has come into force in 2017.

In addition, the following legislation recently came into force:

  • The Law Amending the Law on the Pension Fund of the Republic of Turkey, published in the Official Gazette on 27 January 2017 (Law 6770).

  • The Regulation Amending the Regulation on Debit Cards and Credit Cards, published in the Official Gazette on 27 September 2016.

  • The Regulation on Asset Management Companies, published in the Official Gazette on 5 March 2016.

The BRSA also announced on its website two draft communiqués regarding debt instruments to be included in both the equity calculation and independent audit of banks.

 

The regulatory authorities

Capital Markets Board of Turkey (CMB)

Main activities. The CMB is the regulatory and supervisory authority in charge of the securities markets in Turkey.

T +90 (312) 292 90 90

W www.spk.gov.tr

The Banking Regulatory and Supervision Agency (BRSA)

Main activities. The BRSA is responsible for regulating, supervising the establishment and operations of banks, financial holding companies etc.

T +90 (212) 214 5000

W www.bddk.org.tr

The Central Bank of Republic of Turkey (TCB)

Main activities. TCB, as a regulatory authority, is also authorized to directly determine monetary policy.

T +90 (0312) 507 5000

W www.tcmb.gov.tr

The Undersecretary of the Treasury (UT)

Main activities. The UT regulates, implements, and supervises economic, financial, and sectoral policies, especially insurance sector.

T +90 (312) 204 60 00

W www.hazine.gov.tr



Contributor profiles

Piraye Kuranel Başol, Partner

Hergüner Bilgen Özeke Attorney Partnership

T +90 (212) 310 18 25

F +90 (212) 310 18 99

E pkuranel@herguner.av.tr

W www.herguner.av.tr/

Professional qualifications. Lawyer, Turkey.

Areas of practice. International financial institutions; procurement; public-private partnership; mergers and acquisitions; export finance; project finance.

Professional memberships. Member of the Istanbul Bar Association.

Ayşegül Özmen, Associate

Hergüner Bilgen Özeke Attorney Partnership

T +90 (212) 310 16 77

F +90 (212) 310 18 99

E aozmen@herguner.av.tr

W www.herguner.av.tr/

Professional qualifications. Turkey, Lawyer.

Areas of practice. Banking; project finance.

Professional memberships. Member of the Istanbul Bar Association.

Begüm Femir, Associate

Hergüner Bilgen Özeke Attorney Partnership

T +90 (212) 310 18 47

F +90 (212) 310 18 99

E bfemir@herguner.av.tr

W www.herguner.av.tr/

Professional qualifications. Turkey, Lawyer.

Areas of practice. Banking; project finance.

Professional memberships. Member of the Istanbul Bar Association.


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