Ethics & Compliance

Where do you stand on compliance with AML regulations?

Do you understand the consequences of the crime of money laundering?

We provide the following services within this context:

• Preparation of corporate policies and procedures for Anti-Money Laundering and financing of terrorism; coordination of related oversight, detection, training and internal audit activities
• Assessment on regulatory compliance of current corporate procedures and implementation of necessary remedial measures
• Assessment of compliance with foreign legislation for obliged parties with partners resident outside Turkey and implementation of necessary remedial measures
• Advisory services for establishment and implementation of the required IT infrastructure and assessment of the effectiveness of systems already in place
• Identification of high-risk operations and assessment of necessary remedial measures during mergers and acquisitions via review of procedures and past transactions of target companies

Through data analytics, we can help your organization meet the challenges of AML and KYC:

• Creating AML incident scenarios
• Using analytical tools to test AML scenarios
• Identifying potential risks associated with AML compliance

Various Anti Money Laundering (AML) regulations require financial institutions to undertake customer due diligence measures, including identifying and verifying the identity of their customers.

The range of measures depends on the clients’ risk assessment in regard to the likelihood of money laundering and terrorist financing.

• We offer support in design and implementation of suitable end-to-end KYC operating models, development and optimization of KYC processes and procedures, as well as review, support in selection and implementation of IT solutions dedicated to KYC processes.
• We can also provide operational support for your KYC Business as Usual processes or design and deliver remediation of deficient KYC files through our Centre of Excellence.  
• We are also supporting financial institutions in the review of KYC functions from the compliance perspective. This includes independent review of group and local policies and procedures against regulatory requirements.

Today, the priorities of the companies are to create a common corporate culture, to protect the reputation of the Corporation, to improve the behavior of employees, to comply with legal requirements including EU Whistleblowing Directive and ISO 37301, to meet the expectations of stakeholders, to be a responsible company to society, to strengthen the position of the company against competitors, to reduce the effects of misconduct by creating an Ethics Code / Regulation and manage the ethical reports. In this context, we will provide you with the following support for the development of the ethical culture:

• Assisting you in assessing and improving ethics case management process
• Meeting with Senior Management regarding the tone at the top impact on ethics culture
• Providing Ethics Trainings to management and employees
• Evaluation and improvement of the Code of Ethics
• Assessing employee’s perception on whistleblowing mechanism and recommending actions to improve ethics culture

Code of Ethics & Conduct helps to demonstrate Organisation’s awareness and shape its responsibility in front of employers, customers, business partners, communities and competitors. It facilitates the Organisation’s ability to make a difference on a market. Moreover, it helps to articulate the Organisation’s expectations to its employees much clearer and positively influences their behaviours. Code of Ethics & Conduct is an essential attribute of any Organisation that aims to secure its profitability, brands and reputation on the market.

We help to enhance corporate culture in Organisations through support with design and implementation of strong and effective ethics and compliance practices.

• Reviewing the Company’s current operations from a compliance aspect such as an ABAC and trade control & sanctions perspective
• Review of the Company’s key documents including current policies and procedures;
• Assess the Company’s current stance with respect to compliance and trade controls;
• Site visits to the Company’s offices to hold workshops with Company management (including: key executives, business unit leaders and relevant people from legal, finance, internal audit and compliance teams) to understand Company controls with respect to bribery, corruption and trade controls / sanctions;
• Identify Company’s compliance related risks and improvement areas with respect to the current regulations including: Foreign Corrupt Practices Act of US, UK Bribery Act, OECD Convention, and US Trade Controls and Sanctions.
• Provide you with a legal memorandum (in conjunction with legal counsel) identifying risk and improvement areas and our recommendations to mitigate those risks and enhance the current compliance program.

Phase 1 - Assessment

• Assessing the current control environment and identifying the gaps/risks with regards to ABAC, AML & Sanctions and Ethics compliance design via interviews with process owners

Phase 2 – Road Map to Compliance Program

• Determination of compliance risks and drafting enhanced policies and procedures for the Company.
  • Anti-Bribery Anti-Corruption
  • Anti-Money Laundering & Trade Sanctions
  • Ethics

Phase 3 - Implementation of Compliance Program

• Providing full day training sessions for the Company’s management and selected group of managers.
• Provide ad-hoc assistance and guidance to the Company during the implementation of the compliance program. 

Entitlement assessment and contract compliance

Make sure you’re paid or paying the appropriate fees under the licensing agreements and supplier or vendor contracts.

Different accounting policies and practices, as well as changes in accounting guidance, can impact key calculations under these agreements, affecting terms such as sales returns, damaged goods and consignment sales. Understand your agreement to make sure you’re getting what you’re entitled to.

In the event of a dispute, our experienced professionals can support your claim with legal and alternative dispute resolution methods.

• Data Analytics and Customer Contract Tool
• Decision Making and Negotiation Strategy
• Pilot Negotiations and Settlements

On-site review of selected distributor and agents to identify potential irregularities by understanding general business practices, corporate relations, compliance environment, potential conflict of interest and suspicious transactions to assist your organization in mitigating third party risks.

Our forensic experts help you with Competition Investigation Support which includes the following compliance procedures:

• Review of compliance with regulatory framework related to competition
• Developing strategies for mitigating the risks of possible competition law violations and establishing corporate policies for managing key risks