The government of President Recep Tayyip Erdogan, long plagued by entrenched systemic corruption and blatant political interference in law enforcement at home, has also failed to establish an effective framework to prevent politically connected Turkish companies from using bribery to advance their commercial interests abroad, according to a damning new assessment by the Organisation for Economic Co-operation and Development (OECD), a leading international body that monitors economic governance and anti-corruption standards.
The findings are particularly striking in light of a current US federal prosecutioninvolving Aksa Enerji Üretim A.Ş., a major Turkish energy company with close links to Erdogan’s governing establishment. US prosecutors allege that senior Aksa executives participated with intermediaries in a scheme that involved hundreds of thousands of dollars in bribes to Ghanaian officials to secure approval for a lucrative power plant contract.
While U.S. prosecutors are presenting bank transfers, emails and alleged reimbursement records involving a Turkish company’s overseas business, Turkey itself has not obtained a single conviction for foreign bribery since becoming a party to the OECD Anti-Bribery Convention in 2000.
The two developments together offer a revealing contrast: While U.S. prosecutors are presenting bank transfers, emails and alleged reimbursement records involving a Turkish company’s overseas business, Turkey itself has not obtained a single conviction for foreign bribery since becoming a party to the OECD Anti-Bribery Convention in 2000, two years before Erdogan took the reins in ruling the country.
The OECD’s 2026 follow-up assessment says Turkey has failed to implement 49 of the 71 recommendations made following its Phase 4 evaluation. Only 10 were fully implemented and 12 were partially implemented. The OECD Working Group on Bribery said it was “again dismayed” at the number of recommendations Ankara had ignored, including measures previously identified as top priorities.
Among the most serious failures are the absence of effective whistleblower protection, inadequate corporate liability, the lack of a system to quickly transmit foreign bribery allegations to prosecutors and Turkey’s failure to demonstrate that it is seriously investigating allegations against Turkish companies and individuals.
This reflects a broader lack of political will on the part of the Erdogan government to implement the OECD Anti-Bribery Convention. At home, the government has repeatedly weaponized criminal and administrative investigations to punish corporations and individuals perceived as unsupportive of Erdogan’s increasingly repressive rule, while at the same time disregarding domestic and international legal obligations when politically connected companies and individuals are implicated in wrongdoing. Even when credible evidence of potentially criminal conduct emerges, pro-Erdogan entities and figures have often been shielded from meaningful scrutiny, investigation or accountability.
The OECD found that almost two-thirds of 23 previously known foreign bribery allegations involving Turkish individuals or companies had never even been investigated. Since that assessment, three additional allegations have surfaced. Turkey opened no new investigations or prosecutions into them and still has no foreign bribery convictions.
As a result, under Erdogan’s rule an institutionalized culture of impunity has taken hold in which companies that resort to bribery have little reason to fear investigation or prosecution at home, while politically connected corporations continue to receive diplomatic backing, government support and privileged access to foreign markets even when Turkish authorities are aware of credible evidence suggesting that corrupt practices played a significant role in advancing those commercial interests.
The allegations surrounding Aksa Enerji provide an unusually detailed example of the type of overseas conduct Turkey is required to investigate under the OECD convention.
The company, part of the family-controlled Kazancı Holding, has expanded rapidly overseas, particularly in Africa. Prosecutors in the Eastern District of New York allege that former Goldman Sachs banker Asante Kwaku Berko, senior Turkish company executives and Ghanaian intermediaries participated in a bribery and money laundering conspiracy between December 2014 and March 2017 to obtain government approvals for a 370-megawatt power project in Ghana. At least $700,000 was allegedly earmarked or distributed to Ghanaian officials.
The prosecution has produced a substantial documentary record that prosecutors say shows Turkish corporate executives authorizing transfers, discussing Ghanaian officials and reimbursing intermediaries after payments had been made.
The prosecution has produced a substantial documentary record that prosecutors say shows Turkish corporate executives authorizing transfers, discussing Ghanaian officials and reimbursing intermediaries after payments had been made.
Court filings cited in the US case contain allegations that are directly relevant to the weaknesses identified by the OECD.
The Ghana case is also significant because Aksa was not an obscure Turkish company operating without government connections. Its overseas expansion coincided with Ankara’s political and commercial push into Africa. Aksa selected Africa as an important early international market and eventually developed projects across Ghana, Mali, the Republic of Congo and several other African countries.
Naci Ağbal, a former Turkish finance minister, former head of the presidential Strategy and Budget Office and former central bank governor, became Aksa’s chief executive and chairman of its executive committee in January 2026. He also serves as vice chairman of Aksa Enerji and Kazancı Holding.
Erdogan himself traveled to Ghana on March 1, 2016, at a time when the Aksa project was being developed. He was accompanied by his son-in-law Berat Albayrak, then energy minister. During the visit Turkey and Ghana signed an agreement on cooperation in the energy sector in the presence of Erdogan and Ghanaian President John Dramani Mahama.
Years later, Erdogan publicly honored the company. On October 13, 2023, he presented an award to Cemil Kazancı, then Aksa Enerji’s CEO, recognizing the company’s investments in Africa during the Türkiye-Africa Business and Economic Forum.
This illustrates the extent to which a company implicated in a major foreign corruption prosecution enjoyed access to and public support from Turkey’s highest political leadership.
That makes the OECD’s findings about Ankara’s reluctance to police its companies abroad particularly relevant.
The OECD specifically instructed Turkey’s diplomatic missions to monitor foreign media for allegations involving Turkish companies. The Foreign Ministry issued guidelines requiring embassies and consulates to do so. But that remained only on paper. Turkey’s diplomatic missions reported not a single foreign bribery allegation after the previous OECD evaluation.
The OECD’s own monitoring, by contrast, discovered three new cases involving Turkish companies or individuals over the same period. The Working Group concluded that the discrepancy suggested the Turkish diplomatic system’s monitoring remained ineffective.
Rather than effectively monitoring and reporting such allegations, the ministry has shown no willingness to subject government-linked companies to meaningful scrutiny, even when credible evidence of corrupt practices has emerged.
The Turkish Foreign Ministry, increasingly transformed into an intelligence-oriented apparatus under former spymaster Hakan Fidan, who became foreign minister in 2023 after more than a decade at the helm of the National Intelligence Organization (MİT), is far more interested in pursuing exiled Turkish journalists who expose government wrongdoing, including corruption and bribery scandals, than in scrutinizing politically connected Turkish companies accused of using bribes to secure lucrative contracts abroad.
Rather than effectively monitoring and reporting such allegations, the ministry has shown no willingness to subject government-linked companies to meaningful scrutiny, even when credible evidence of corrupt practices has emerged.
A major criminal case in the United States now publicly contains allegations that executives of a Turkish company transferred money from Turkey, communicated about payments to foreign officials and used intermediary companies to reimburse funds allegedly distributed to government officials.
Yet the OECD says Turkey has not opened any new foreign bribery investigation since its Phase 4 assessment. The OECD ultimately reached an even harsher conclusion after Ankara declined to give it an update on its foreign bribery enforcement actions.
Turkish officials claimed information would be supplied after a specialized prosecutorial unit had been formally designated. The Working Group called that explanation “unacceptable,” noting that Turkey is obliged under the convention to investigate foreign bribery whether or not a dedicated prosecutorial unit exists.
Because Ankara provided no evidence of investigative activity, the OECD said the logical conclusion was that Turkey had taken no steps to investigate any foreign bribery allegation since the previous review.
One of the central problems identified by the OECD is remarkably basic: Turkey lacks an effective mechanism for ensuring that allegations actually reach prosecutors. The Foreign Ministry’s new anti-bribery guide tells Turkish missions to transmit allegations to the Ministry of Justice rather than directly to prosecutorial authorities.
The OECD said the Justice Ministry’s existing formal denunciation procedure was poorly defined and had repeatedly hampered timely information sharing. Reports received from the OECD itself were likewise not covered by an effective system ensuring transmission to prosecutors.
No specific prosecutorial unit has primary responsibility for foreign bribery, either. The OECD also found virtually no progress in preventing corruption before it happens.
Turkey was specifically instructed to promote anti-bribery awareness among private companies, particularly businesses operating in high-risk sectors and countries, including state-owned and state-controlled companies. Ankara provided no evidence that it had implemented the recommendation.
The government was also urged to encourage Turkish corporations to develop programs for preventing and detecting foreign bribery. The OECD’s finding was unequivocal: No action had been taken.
The government was also urged to encourage Turkish corporations to develop programs for preventing and detecting foreign bribery. The OECD’s finding was unequivocal: No action had been taken.
The government has similarly failed to create meaningful incentives for corporations to self-report corruption discovered internally. Training and guidance are merely planned, and the OECD stressed that awareness programs are not a substitute for mechanisms that actually encourage companies to disclose wrongdoing.
Even when evidence points toward corporate involvement, Turkey’s laws make holding companies responsible extraordinarily difficult. The OECD says the current system effectively ties corporate liability to the conviction of an individual responsible for the underlying offense.
Turkey has proposed amendments that could remove some of those barriers, but they remain drafts, and Ankara has provided no timetable for enactment.
More revealing is the enforcement record. Turkey’s corporate liability provision has been in force for more than 17 years, yet no legal entity has been held liable under it for either domestic or foreign bribery. Nor has Ankara provided data demonstrating that companies are being investigated, prosecuted or sanctioned under the law.
The OECD also found no implementation of key recommendations governing confiscation from companies and state-controlled enterprises involved in bribery.
Türk Eximbank, the government institution that helps finance Turkish companies’ overseas business, also remains deficient. The OECD says the bank does not systematically consider the anti-corruption compliance systems of every applicant. Such scrutiny is largely reserved for companies already found responsible for bribery or under investigation.
The Working Group stressed that it wanted Eximbank to consider the quality of such programs when deciding whether to provide government-backed support. Turkey failed to implement the recommendation.
The failure takes on additional importance given the international business model of companies such as Aksa, whose growth increasingly depends on government-backed long-term contracts in foreign states.
In Ghana, for example, Aksa’s original 370-megawatt facility developed into a long-term commercial foothold. In October 2022 its power sales arrangement was extended for another 15 years, and the company later secured a separate 20-year agreement for a natural gas plant in Kumasi. By March 2026 Aksa had approximately 500 megawatts of operational capacity in Ghana and projects or subsidiaries across several African countries.
Ankara was instructed to introduce anti-corruption provisions into official development assistance contracts, consider corporate compliance programs when awarding projects and determine whether potential partners had been debarred by multilateral development banks.
Ankara was instructed to introduce anti-corruption provisions into official development assistance contracts, consider corporate compliance programs when awarding projects and determine whether potential partners had been debarred by multilateral development banks.
Those recommendations were not implemented.
This is significant because Turkey increasingly combines diplomacy, development assistance and commercial investment in Africa, often using institutions such as the Turkish Cooperation and Coordination Agency (TİKA), government ministries, diplomatic missions and Turkish businesses as overlapping instruments of foreign policy.
At the same time, individuals inside Turkish companies or government agencies who might expose corruption continue to lack meaningful protection. The OECD has raised the issue since 2007. The Erdogan government has promised legislation, commissions, working groups and reviews, but none has resulted in comprehensive whistleblower legislation. The 2026 report says there is still no draft law and no timetable for one.
The OECD noted that the Turkish government’s latest answer repeated the same pattern of meetings and promises seen in previous evaluations and said there was no reasonable expectation of progress.
This deficiency is particularly important in cases resembling the Ghana allegations, where evidence can depend heavily on insiders with access to emails, consultancy agreements, invoices and records of payments.
The OECD also drew a direct link between press freedom and corruption enforcement. Turkey had been told to ensure constitutional and legal protections for journalism were actually applied so that foreign bribery allegations could be reported freely. Ankara took no action to implement the recommendation.
The OECD separately recommended that if a news report alleging bribery by a Turkish individual or company is censored, the information contained in the suppressed report should nevertheless be forwarded to prosecutors. That did not happen, either.
The result is an environment in which investigative reporting about politically connected corporations can be suppressed, while the enforcement system itself lacks effective mechanisms for independently identifying the underlying allegations.
At the prosecution stage, the OECD highlighted another structural problem: the independence of the Turkish judiciary. The Working Group had called for reform of the Council of Judges and Prosecutors (HSK) so that a majority of its members would be judges selected by their peers, and that executive officials such as the justice minister and deputy minister would no longer serve on it. Turkey has not implemented the recommendation and instead points to a possible analysis and action plan that may not be produced until 2028.
The OECD also wants safeguards ensuring that disciplinary proceedings against prosecutors and judges are not politically motivated or used to interfere with corruption cases. Turkish measures to date do not directly address those concerns, the Working Group found.
Turkey had been told to ensure constitutional and legal protections for journalism were actually applied so that foreign bribery allegations could be reported freely. Ankara took no action to implement the recommendation.
The Berko prosecution therefore provides an instructive contrast with Turkey’s enforcement record. US prosecutors say their evidence includes bank transactions, internal emails, electronic records, government documents and charts tracing money moving from Turkey through American correspondent banks to Ghana.
Berko was indicted under seal in 2020, arrested at London’s Heathrow Airport in November 2022 and extradited to the United States in July 2024. He faces charges including conspiracy to violate the Foreign Corrupt Practices Act, a substantive FCPA violation, and conspiracy to commit money laundering.
A related US Securities and Exchange Commission proceeding previously resulted in Berko agreeing in 2021 to disgorge $275,000 and pay more than $54,000 in prejudgment interest. The SEC alleged that he helped funnel at least $2.5 million to a Ghanaian intermediary and assisted in payments to government officials.
The case exposes an uncomfortable fact for Ankara: Foreign authorities have assembled detailed allegations of corrupt conduct involving money originating from a Turkish corporation while Turkey’s own enforcement system has produced no foreign bribery convictions at all.
Turkey has been formally committed to the OECD Anti-Bribery Convention for more than a quarter-century. Yet the latest review shows a striking gap between that international commitment and domestic enforcement.
Of the 23 cases known during the previous evaluation, 15 were never investigated, six ended without charge and two produced acquittals. Three more allegations have since emerged, bringing the total to 26, but there are still no convictions.
The OECD has now instructed Turkey to report again in December 2026 on several priority reforms and to provide annual reports on its foreign bribery enforcement activity.
Taken together with the Ghana prosecution, the OECD findings suggest a broader problem than mere bureaucratic delay. The Erdogan government has created an overseas commercial strategy in which politically connected Turkish businesses receive intensive diplomatic backing and high-level political support, while the institutions that are supposed to police how those companies win contracts abroad remain ineffective.
It is clear that a wide gap remains between Ankara’s international anti-corruption commitments and its actual enforcement, a discrepancy underscored by some of the most damaging findings in the OECD report.
A company that enjoyed high-level access to Erdogan’s government allegedly transferred money from Turkey as part of a foreign bribery scheme, according to US prosecutors, while building a contract that ultimately became the foundation of a substantial African energy business. Years later, it is US rather than Turkish law enforcement examining the alleged payments.
It is clear that a wide gap remains between Ankara’s international anti-corruption commitments and its actual enforcement, a discrepancy underscored by some of the most damaging findings in the OECD report.
Published originally under the title “OECD Slams Turkey’s Foreign Bribery Enforcement as Erdoğan-Linked Firm Faces Us Case.”
Documents referenced in this article are available in the original Nordic Monitor version.
