Introduction
Anti-money laundering compliance in Turkey is one of the most important legal obligations for banks, payment institutions, electronic money institutions, capital markets institutions, insurance companies, crypto asset service providers, financing companies and other financial institutions. As Turkey’s financial system becomes increasingly digital, cross-border and technology-driven, compliance with anti-money laundering and counter-terrorist financing rules has become a central part of financial regulation.
The main authority responsible for anti-money laundering supervision and financial intelligence in Turkey is the Financial Crimes Investigation Board, commonly known as MASAK. MASAK operates under the Ministry of Treasury and Finance and plays a key role in collecting, analyzing and evaluating suspicious transaction reports, supervising obliged parties, issuing guidance and coordinating the fight against money laundering and terrorist financing.
The principal statute governing anti-money laundering obligations in Turkey is Law No. 5549 on Prevention of Laundering Proceeds of Crime. The objective of this law is to determine the principles and procedures for preventing the laundering of proceeds of crime. Law No. 5549 imposes obligations on “obliged parties,” including financial institutions, to identify customers, report suspicious transactions, retain records, provide information and documents, establish compliance systems and comply with MASAK requirements.
For financial institutions, MASAK compliance is not merely a formal regulatory requirement. It directly affects customer onboarding, transaction monitoring, bank account operations, correspondent banking, fintech partnerships, crypto-related activities, cross-border transfers, internal controls, risk management, board responsibility and regulatory reputation. A weak AML framework may lead to administrative fines, restrictions, suspension of activities, license risks, criminal exposure and loss of banking relationships.
This article provides a comprehensive legal guide to anti-money laundering compliance in Turkey, focusing on MASAK obligations for financial institutions.
1. Legal Framework of Anti-Money Laundering Compliance in Turkey
The Turkish AML framework is based on several legal instruments. The core statute is Law No. 5549 on Prevention of Laundering Proceeds of Crime. This law regulates customer identification, suspicious transaction reporting, periodic reporting, information and document requests, record retention, protection of persons reporting suspicious transactions, supervision of obligations and sanctions.
Another key instrument is the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism. This regulation sets out detailed measures on customer due diligence, suspicious transaction reporting, reporting confidentiality, information and document provision, and related compliance requirements. It also confirms that obliged parties must provide information and documents requested by MASAK or examiners fully, accurately and without delay.
The Regulation on Program of Compliance with Obligations of Anti-Money Laundering and Combating the Financing of Terrorism is also highly important. It regulates compliance programs, compliance officers, risk management, monitoring and control, training and internal audit obligations for certain obliged parties. MASAK’s official materials identify this regulation as part of the AML/CFT compliance framework.
The Turkish AML framework is also connected to Turkish Penal Code Article 282, which criminalizes laundering the proceeds of crime, Law No. 6415 on the Prevention of the Financing of Terrorism, and Law No. 7262 on the Prevention of the Financing of Proliferation of Weapons of Mass Destruction. MASAK’s official legal materials include Law No. 6415 and Law No. 7262 among the relevant legal sources for terrorism financing and proliferation financing.
Therefore, AML compliance in Turkey should not be understood only as customer identification. It is a multi-layered compliance regime covering money laundering, terrorist financing, proliferation financing, suspicious transactions, sanctions, customer risk, beneficial ownership, recordkeeping, internal governance and cooperation with public authorities.
2. MASAK’s Role in the Turkish AML System
MASAK is Turkey’s financial intelligence unit and the central administrative authority in the fight against money laundering and terrorist financing. Its functions include receiving suspicious transaction reports, analyzing financial intelligence, requesting information and documents, supervising obliged parties, coordinating with public institutions, issuing guidance and contributing to national and international AML/CFT cooperation.
For financial institutions, MASAK is not a distant regulatory authority. It directly affects daily operations. Banks, payment institutions, e-money institutions and other financial sector actors must design their onboarding, monitoring, reporting and internal control systems in a way that allows them to detect suspicious transactions and report them to MASAK.
MASAK’s role is especially important because financial crime risks evolve quickly. Traditional money laundering typologies such as cash-based transactions, shell companies, trade-based laundering and third-party transfers now exist alongside digital risks such as online fraud, mule accounts, crypto asset transfers, fake merchant structures, cross-border payment layering and misuse of fintech platforms.
A financial institution that fails to maintain an effective MASAK compliance program may face not only administrative sanctions but also serious reputational damage. In modern banking and fintech practice, AML compliance is a prerequisite for sustainable financial activity.
3. Who Are the Obliged Parties Under Turkish AML Law?
Under Law No. 5549, obliged parties include those operating in fields such as banking, insurance, individual pension, capital markets, money lending and other financial services, as well as several non-financial sectors determined by law and regulation. The official text of Law No. 5549 identifies obliged parties broadly and includes persons and institutions operating in banking, insurance, individual pension, capital markets, money lending and other financial services among them.
For the purpose of financial institutions, the most important obliged parties include:
Banks, participation banks, development and investment banks, payment institutions, electronic money institutions, financing companies, factoring companies, financial leasing companies, capital markets institutions, portfolio management companies, insurance and reinsurance companies, pension companies, intermediary institutions, crypto asset service providers and other institutions operating in regulated financial markets.
The scope of obliged parties is not static. It may expand as new financial products and risks emerge. For example, crypto asset service providers have become an important part of MASAK compliance discussions, particularly due to the risk of anonymity, rapid transfer, cross-border movement and use of virtual assets in layering transactions.
For businesses operating in or around the financial sector, the key question is whether their activity brings them within the AML obligation perimeter. A company may describe itself as a technology provider, but if it provides payment, wallet, crypto, money transfer, financial intermediation or account-based services, AML obligations may arise.
4. Customer Due Diligence and Know Your Customer Obligations
Customer due diligence, commonly known as CDD, and Know Your Customer, commonly known as KYC, are the foundation of anti-money laundering compliance in Turkey. Law No. 5549 requires obliged parties to identify the persons carrying out transactions and the persons on behalf of or for the benefit of whom transactions are conducted before the relevant transactions are performed. The Ministry is authorized to determine the documents, transaction types, thresholds and procedures relating to customer identification.
For financial institutions, KYC is not limited to collecting an identity card. It requires understanding the customer’s identity, beneficial ownership, purpose of account opening, expected transaction profile, source of funds, source of wealth, business activity, risk level and whether the customer is acting on behalf of another person.
In practice, a robust KYC process should include:
Verification of identity, verification of address or contact information, identification of ultimate beneficial owner, review of corporate documents, identification of authorized signatories, screening against sanctions and watchlists, politically exposed person checks, purpose and nature of business relationship, expected transaction volume, source-of-funds information and ongoing monitoring.
For legal entity customers, financial institutions should review trade registry records, articles of association, tax registration, shareholder structure, board resolutions, signatory authorities and beneficial ownership information. For foreign companies, apostilled or legalized documents, sworn translations and ownership charts may be necessary.
Weak KYC is one of the most common sources of AML risk. If a financial institution does not know who its customer is, it cannot properly evaluate suspicious transactions.
5. Risk-Based Approach in AML Compliance
Modern AML compliance is built on a risk-based approach. This means that financial institutions should not apply the same level of review to every customer and every transaction. Instead, they should classify customers, products, services, countries, channels and transaction types according to risk.
High-risk customers may include politically exposed persons, customers with complex ownership structures, offshore companies, cash-intensive businesses, customers from high-risk jurisdictions, crypto-related businesses, money transfer-intensive customers, newly incorporated companies with large transactions, and customers whose declared activity does not match transaction behavior.
High-risk products may include cross-border transfers, prepaid instruments, anonymous or limited-verification products, digital wallets, crypto transfers, trade finance, correspondent banking, private banking and high-value cash transactions.
A risk-based system should include risk scoring, enhanced due diligence, senior management approval for high-risk customers, periodic review, transaction monitoring, alert investigation and escalation procedures.
A low-risk customer may be subject to simplified measures only where permitted. However, where there is suspicion of money laundering or terrorist financing, simplified measures should not be used. MASAK materials emphasize that suspicious circumstances require reporting and more careful review rather than simplified treatment.
6. Suspicious Transaction Reporting to MASAK
Suspicious transaction reporting is one of the most important obligations under Turkish AML law. Law No. 5549 provides that if there is any information, suspicion or reasonable ground to suspect that assets subject to transactions carried out or attempted through obliged parties were acquired illegally or used for illegal purposes, these transactions must be reported to MASAK.
The obligation is not limited to completed transactions. Attempted transactions may also be reportable. This is critical because a customer may attempt to perform a suspicious transaction and abandon it when asked for documents. The institution may still be required to evaluate and report the attempt.
MASAK General Communiqué No. 13 sets out principles and procedures for suspicious transaction reporting. It defines suspicious transaction reporting in connection with information, suspicion or reasonable grounds to suspect that assets have been acquired illegally or used for illegal purposes, terrorist activities or persons connected with terrorist financing. It also states that suspicious transaction reports can be submitted electronically through MASAK.ONLINE.
In practice, suspicious indicators may include:
Unusual transaction volume inconsistent with customer profile, unexplained cash deposits, rapid incoming and outgoing transfers, frequent transfers to unrelated third parties, use of many accounts without economic reason, reluctance to provide documents, inconsistent explanations, transactions involving high-risk countries, use of personal accounts for business activity, sudden high-value transactions after account opening, crypto-related layering, suspected mule accounts, fake invoices, trade-based manipulation and use of shell companies.
The reporting decision should be based on reasonable suspicion, not proof of crime. Financial institutions are not courts or prosecutors. They are expected to detect suspicious patterns and report them to MASAK where legal conditions are met.
7. Confidentiality and Prohibition of Tipping-Off
A core rule in AML compliance is the prohibition of tipping-off. Law No. 5549 provides that obliged parties must not disclose to anyone, including parties to the transaction, that they have reported suspicious transactions to MASAK, except for examiners assigned for supervision and courts during legal proceedings.
The Regulation on Measures also contains detailed confidentiality rules. It states that persons and institutions reporting suspicious transactions, members of their boards, managers, legal representatives and personnel who know that suspicious transactions have been reported are covered by confidentiality obligations. It also provides that obliged parties must not disclose to affiliated units abroad that a suspicious transaction has been reported in relation to their customers.
This rule is extremely important in practice. A bank employee, compliance officer or customer representative should not tell a customer that “we reported you to MASAK.” Such disclosure may undermine an investigation, create legal liability and violate AML rules.
Financial institutions must train their staff on how to communicate with customers during suspicious transaction reviews. Employees may request documents, ask questions or delay a transaction where legally appropriate, but they must avoid language that reveals the existence of a suspicious transaction report.
8. Protection of Reporting Persons and Institutions
Turkish AML law protects persons and institutions that comply with suspicious transaction reporting obligations. The Regulation on Measures states that natural and legal persons, compliance officers, legal representatives, managers and personnel who comply with the suspicious transaction reporting obligation shall not be held judicially or criminally responsible for reporting.
This protection is important because financial institutions may hesitate to report transactions due to fear of customer complaints, lawsuits or reputational concerns. The legal framework encourages reporting by protecting those who act in accordance with AML obligations.
However, this protection does not mean that reports should be arbitrary or malicious. Financial institutions should maintain proper internal documentation showing the facts, red flags, analysis and reasoning behind the suspicious transaction report.
A good internal file should include customer profile, transaction records, documents requested, customer explanations, risk indicators, compliance officer assessment and reporting decision. This helps demonstrate that the institution acted lawfully and professionally.
9. Recordkeeping and Retention Obligations
Recordkeeping is another major AML obligation. Law No. 5549 requires obliged parties to retain documents, books, records and identification documents relating to their transactions and obligations for eight years starting from the relevant date, such as the date of preparation, last record date or last transaction date.
For financial institutions, recordkeeping should be systematic and audit-ready. It should cover customer identification documents, beneficial ownership records, account opening forms, transaction documents, internal review notes, suspicious transaction analysis, correspondence, payment instructions, contracts, invoices, corporate documents, risk assessments, monitoring alerts and compliance approvals.
Digital recordkeeping should also ensure integrity, accessibility and security. Financial institutions should be able to retrieve records quickly when MASAK, examiners, courts or other authorized authorities request them.
Failure to retain records may create serious problems. Even if a transaction was lawful, the institution may be unable to prove compliance if documents are missing.
10. Providing Information and Documents to MASAK
Law No. 5549 requires public institutions, natural and legal persons and unincorporated organizations to provide all requested information, documents and related records fully and accurately when requested by MASAK or examiners. The law also states that those from whom information and documents are requested cannot avoid providing them by relying on special law provisions, provided that the right of defense is reserved.
The Regulation on Measures repeats this obligation in detail and states that requested information, documents, records and necessary access information must be provided without delay and in the required form.
This obligation is highly relevant for banks and financial institutions because customer data, transaction records and account information are often central to money laundering investigations. Banking confidentiality does not allow a financial institution to refuse lawful MASAK requests.
Financial institutions should therefore have internal procedures for handling MASAK requests. The procedure should define who receives the request, how it is verified, which departments collect records, how deadlines are monitored, how confidentiality is maintained and how the response is approved.
11. Compliance Program Obligations
Certain financial institutions must establish formal AML/CFT compliance programs. The compliance program framework includes the appointment of a compliance officer, risk management policy, monitoring and control activities, training, internal audit, written policies and board-level oversight.
MASAK’s official materials identify the Regulation on Program of Compliance with Obligations of Anti-Money Laundering and Combating the Financing of Terrorism as a key source for these obligations.
A strong AML compliance program should include:
Written AML policy, customer acceptance policy, risk assessment methodology, transaction monitoring procedures, suspicious transaction escalation process, sanctions screening, politically exposed person policy, enhanced due diligence rules, recordkeeping procedures, training program, internal audit plan, reporting lines, compliance officer authority and board reporting.
The compliance officer should have sufficient authority, independence, access to information and ability to escalate concerns. If the compliance function is treated as a symbolic position without real operational power, the institution’s AML program may fail.
The board of directors and senior management should also be involved. AML compliance cannot be delegated entirely to a junior employee or external consultant. Financial institutions must demonstrate governance ownership of financial crime risk.
12. AML Training Obligations
Training is a core component of AML compliance. Employees who interact with customers, process transactions, onboard merchants, approve transfers, monitor alerts, manage digital systems or handle complaints should understand AML risks and MASAK obligations.
Training should be tailored according to role. Branch employees, call center staff, compliance analysts, relationship managers, IT personnel, senior management and board members do not need identical training. Each group should understand the red flags relevant to its responsibilities.
Training should cover customer identification, beneficial ownership, suspicious transaction indicators, tipping-off prohibition, recordkeeping, sanctions, politically exposed persons, fraud typologies, crypto risks, trade-based laundering, payment services risks and internal reporting channels.
Training should also be documented. Attendance records, training materials, test results and periodic updates should be retained to prove compliance during inspections.
13. Transaction Monitoring and Alert Investigation
Transaction monitoring is the operational heart of AML compliance. Financial institutions must monitor whether customer transactions are consistent with the customer’s profile, source of funds, business activity and expected behavior.
Transaction monitoring systems may generate alerts based on rules such as high-value transfers, structuring, rapid movement of funds, multiple unrelated counterparties, high-risk country exposure, sudden activity after dormancy, repeated failed transactions, cash-intensive activity, unusual crypto-related transfers and inconsistent merchant volumes.
However, generating alerts is not enough. Alerts must be reviewed, documented and closed with proper reasoning. If an alert shows suspicious behavior, it should be escalated to the compliance officer for further review and possible MASAK reporting.
Poor alert governance is a common compliance weakness. Too many alerts may overwhelm compliance teams, while too few alerts may indicate weak system design. Financial institutions should calibrate monitoring rules according to customer risk and business model.
14. AML Compliance for Banks
Banks are at the center of Turkey’s AML framework. They provide accounts, loans, transfers, cash services, foreign exchange, trade finance, cards, digital banking and correspondent banking. Because they handle large transaction volumes, they face significant money laundering and terrorist financing risks.
Banks should maintain advanced KYC, sanctions screening, transaction monitoring, correspondent banking due diligence, trade finance review, cash transaction monitoring, private banking controls, non-resident customer controls and suspicious transaction reporting systems.
Banking products such as letters of credit, guarantees, foreign exchange transfers, cash deposits, safe deposit boxes and corporate accounts may be misused for financial crime. Therefore, bank compliance teams must understand both ordinary banking operations and criminal typologies.
Banks must also balance AML compliance with customer rights. A bank may request documents or restrict transactions where necessary, but it should avoid arbitrary, indefinite or disproportionate measures unless there is a legal basis.
15. AML Compliance for Payment and Electronic Money Institutions
Payment institutions and electronic money institutions face unique AML risks due to digital onboarding, fast transfers, wallets, merchant networks, prepaid balances and high-volume low-value transactions.
These institutions should pay special attention to mule accounts, fake merchants, synthetic identities, stolen identities, rapid wallet loading and emptying, suspicious refunds, high-risk merchant categories, chargeback patterns, use of personal accounts for business activity and cross-border digital transactions.
Unlike traditional banks, fintech companies may grow quickly and onboard large numbers of users with limited physical contact. This makes automated KYC, device intelligence, behavioral monitoring, transaction rules and fraud controls essential.
Payment and e-money institutions should ensure that AML controls are built into the product architecture. Compliance should not be added after launch as a separate manual process. If a digital wallet or payment platform scales without adequate controls, remediation may become costly and legally risky.
16. AML Compliance for Crypto Asset Service Providers
Crypto asset service providers are increasingly important in Turkish AML compliance. Crypto transactions may involve rapid transfers, cross-border movement, pseudonymous wallet addresses, layering risks and interaction with decentralized platforms.
Turkey has strengthened its AML/CFT framework in recent years, including crypto-related reforms. Legal updates in 2025 noted that crypto asset service providers were brought more clearly into MASAK’s AML framework and that they must implement compliance programs, appoint compliance officers and comply with core obligations such as customer identification, monitoring and suspicious transaction reporting.
Crypto asset service providers should adopt enhanced procedures for customer identification, wallet screening, transaction monitoring, travel rule compliance where applicable, sanctions screening, suspicious activity escalation, high-risk jurisdiction exposure and internal reporting.
A crypto platform that treats AML as a mere formality may face serious regulatory consequences. Given the international focus on virtual assets, crypto AML compliance should be designed to meet both Turkish requirements and global risk expectations.
17. Targeted Financial Sanctions and Terrorist Financing
AML compliance is closely connected to counter-terrorist financing and targeted financial sanctions. Law No. 6415 on the Prevention of the Financing of Terrorism and Law No. 7262 on the Prevention of the Financing of Proliferation of Weapons of Mass Destruction are part of Turkey’s broader framework for preventing the misuse of the financial system.
Financial institutions must screen customers, beneficial owners, counterparties and transactions against applicable sanctions lists and freezing measures. They should also monitor transactions that may indicate terrorist financing, even where amounts are small. Terrorist financing often differs from money laundering because the funds may originate from lawful sources but be used for unlawful purposes.
Sanctions screening should be continuous, not limited to account opening. Lists may change, and existing customers may become subject to restrictions. Institutions should have procedures for freezing, rejecting, escalating or reporting matches in accordance with applicable law.
18. FATF Standards and Turkey’s International AML Position
Turkey is a member of the Financial Action Task Force, known as FATF, since 1991. FATF’s country page states that Turkey has been subject to mutual evaluation and follow-up processes, and that it has made progress in addressing technical compliance deficiencies. FATF currently notes that Turkey has only one recommendation left rated partially compliant and no recommendations rated non-compliant in the technical compliance framework shown on its Turkey page.
Turkey was removed from the FATF grey list in June 2024, according to the official press release of the Ministry of Treasury and Finance. This removal was important for the country’s financial reputation, but it does not mean that AML compliance has become less important. On the contrary, financial institutions are expected to maintain and demonstrate effective AML/CFT controls after delisting.
For foreign investors and international banks, FATF status matters because it affects correspondent banking, investor confidence, due diligence expectations and perceived jurisdictional risk. Turkish financial institutions that maintain strong AML compliance are better positioned in cross-border relationships.
19. Administrative Sanctions and Regulatory Consequences
Non-compliance with MASAK obligations may lead to administrative fines and other regulatory consequences. Sanctions may arise from failure to identify customers, failure to report suspicious transactions, breach of recordkeeping duties, failure to provide information and documents, violation of compliance program obligations or breach of confidentiality rules.
Recent legal commentary on amendments to the Compliance Program Regulation notes that, as a general rule, a written warning may be issued and a period may be given to remedy deficiencies; if deficiencies are not remedied, significant administrative fines may be imposed, followed by further warnings and possible notification to the relevant authority for suspension, restriction or revocation of operating licenses. The commentary also states that administrative fines are subject to annual revaluation.
For financial institutions, the greatest risk is not only the fine amount. AML failures may lead to loss of trust, termination of correspondent banking relationships, regulatory scrutiny, customer complaints, board liability, internal investigations and license risk.
Therefore, AML compliance should be treated as a strategic governance issue rather than a back-office formality.
20. Practical AML Compliance Checklist for Financial Institutions in Turkey
A financial institution operating in Turkey should maintain a structured AML compliance checklist.
First, the institution should identify whether it is an obliged party under Law No. 5549 and MASAK regulations.
Second, it should prepare written AML policies and procedures approved by senior management.
Third, it should implement customer identification and beneficial ownership procedures.
Fourth, it should establish risk classification for customers, products, services, channels and countries.
Fifth, it should implement enhanced due diligence for high-risk customers.
Sixth, it should establish transaction monitoring and alert investigation systems.
Seventh, it should create an internal suspicious transaction escalation process.
Eighth, it should report suspicious transactions to MASAK where required.
Ninth, it should maintain confidentiality and avoid tipping-off.
Tenth, it should retain documents and records for the required period.
Eleventh, it should provide information and documents to MASAK and examiners when requested.
Twelfth, it should appoint compliance officers where required and establish a compliance program.
Thirteenth, it should provide periodic AML training to employees.
Fourteenth, it should conduct internal audit and independent review of AML controls.
Fifteenth, it should update systems according to legal changes, new MASAK guidance and emerging typologies.
21. Common AML Compliance Mistakes
Financial institutions in Turkey often face compliance weaknesses in several areas.
The first mistake is treating KYC as a document collection exercise rather than a risk assessment process. Identity documents alone do not explain why a customer is using a financial service or whether transaction behavior is suspicious.
The second mistake is failing to identify beneficial ownership. Complex corporate structures may hide the real controlling person. Without beneficial ownership analysis, the institution may unknowingly serve high-risk persons.
The third mistake is poor transaction monitoring. Some institutions generate alerts but do not investigate them properly. Others rely on manual review even when transaction volume requires automated systems.
The fourth mistake is tipping-off. Staff may unintentionally disclose suspicious transaction reporting by using careless language with customers.
The fifth mistake is weak board involvement. AML compliance must be supported by senior management, budget, technology and authority.
The sixth mistake is failing to update AML procedures after regulatory changes. Turkey’s financial regulatory environment, especially fintech and crypto, changes quickly.
22. Why Legal Support Is Important in MASAK Compliance
MASAK compliance requires legal, operational, financial and technological analysis. A Turkish AML lawyer can assist financial institutions with regulatory classification, AML policy drafting, KYC procedures, suspicious transaction reporting processes, compliance program design, board governance, internal investigation support, MASAK information requests, administrative sanction defense, crypto AML compliance, payment institution compliance and cross-border transaction review.
Legal support is especially important when a financial institution receives a MASAK request, faces an inspection, detects suspicious internal activity, receives a warning, is exposed to regulatory sanctions or needs to design a new fintech or crypto product.
Early legal advice can prevent serious consequences. Once a compliance failure becomes the subject of inspection or enforcement, remediation may still be possible but the institution may already face reputational and regulatory damage.
Conclusion
Anti-money laundering compliance in Turkey is a central legal obligation for financial institutions. MASAK obligations under Law No. 5549 require obliged parties to identify customers, monitor transactions, report suspicious transactions, retain records, provide information and documents, maintain confidentiality, establish compliance programs and apply risk-based controls.
For banks, payment institutions, electronic money institutions, capital markets institutions, insurance companies, financing companies and crypto asset service providers, AML compliance is not optional. It is a fundamental condition for lawful and sustainable financial activity.
Turkey’s AML framework continues to evolve in line with FATF standards, digital finance developments, crypto asset risks and international compliance expectations. The removal of Turkey from the FATF grey list in 2024 was an important development, but it increases rather than decreases the need for strong ongoing compliance.
A financial institution that wants to operate safely in Turkey must combine legal compliance, technology, internal governance, staff training, transaction monitoring and strong documentation. The most effective AML programs are not those that merely exist on paper, but those that actively detect risk, support lawful reporting and protect the institution from misuse.
In Turkish financial law, MASAK compliance is therefore not only a regulatory duty. It is a core risk management function that protects the integrity of the institution, the stability of the financial system and the trust of customers, regulators and international partners.
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