The Turkish Ministry of Finance has added to the country's anti-money-laundering rules by issuing a new regulation that outlines its ideas about 'suspicion.'

According to the new regulation, suspicious transactions are noted for their 'extraordinary nature - a very wide phrase that rules out all sorts of statistically significant but less-than-extraordinary activity; by the fact that the facts surrounding them are the subject of adverse publicity that is found on databases; and their circumstances, if those circumstances are 'risky' or give the money-laundering reporting officer in question the impression that it would be difficult or impossible for the Turkish authorities to seize any related proceeds (or, in the case of terrorism, 'preceeds') of crime. The regulation states that this list is not exhaustive.

There is, however, a stipulation that MASAK, Turkey's financial intelligence unit, is obliged to respond to every suspicious transaction report within seven working days. Private banks and asset management firms must send it STRs every time they have any evidence or 'indications' that suspicious transactions have take place or are pending. The FIU, in its turn, is empowered to ban the financial institutions from executing proscribed transactions for a week.

As Turkey has just announced that it is about to introduce a tax amnesty, this initiative seems to anticipate the deluge of cases that is likely to follow.