Turkish Probe Highlights Alleged Laundering Through Licensed Fintech and Insurance Firms

Turkish investigators are scrutinising how a licensed electronic money institution and an associated insurance company allegedly enabled criminal proceeds from illegal betting operations to seep into the country’s financial system. The inquiry centres on corporate entities tied to fintech entrepreneur Ozan Özerk, whose broader business network includes firms previously connected to payment streams linked to a sprawling online fraud operation exposed by investigative journalists. Authorities in Istanbul have frozen assets, detained staff members, and installed a court-appointed trustee to assume control of one company, illustrating how non-bank financial institutions—despite formal regulation—can become vehicles for laundering when exploited by illicit networks. This report details the money laundering aspects of the Turkish investigation based solely on facts publicly confirmed to date.

According to the Istanbul Chief Public Prosecutor’s Office, Ozan Elektronik Para A.Ş., an authorised electronic money institution, was allegedly utilised to funnel proceeds from illegal betting into the regulated economy. Prosecutors indicated that transaction patterns showed signs of placement and layering activity consistent with known money laundering techniques in high-risk payment settings. These patterns reportedly encompassed swift fund movements, large incoming transfers that did not match customer profiles, and commercial payments lacking legitimate economic basis. Officials executed asset freezes totalling roughly 72 million Turkish lira and issued detention orders for several employees as part of the investigation. A separate action one week earlier saw the seizure of an estimated 9.6 million dollars and the arrests of multiple executives associated with the same entity.

Ozan Elektronik Para A.Ş. publicly acknowledged that a trustee had been appointed pursuant to a court order issued on 31 October, a step aimed at stabilising the institution during the probe. The move reflects concerns that internal governance and compliance mechanisms may not have sufficiently curbed misuse of the platform. The company stated that customer and merchant funds would be returned once legal and compliance reviews allowed. The imposition of a trustee—a rare enforcement measure within the sector—signals the gravity with which authorities view the alleged laundering channels.

Investigators further observed that cross-border transactions tied to illegal betting networks entered accounts linked to the institution, reinforcing suspicions that the platform served as an access point for criminal funds. While public communications have not named the beneficial owners as direct subjects of the case, the enforcement actions highlight the vulnerability of electronic money institutions when due diligence, monitoring, or governance safeguards fail to intercept high-risk inflows.

Another element of the probe focuses on Aveon Global Sigorta A.Ş., a majority-owned insurance firm within the same corporate network. Prosecutors allege that the company was used to mask illicit earnings as insurance premium payments, enabling deeper integration of unlawful proceeds into the financial system. Insurance-based laundering—a documented typology—can involve fictitious premiums or reimbursement mechanisms to create the appearance of legitimate activity, particularly in situations where beneficial ownership checks or inter-company data sharing are weak. The allegations suggest that funds may have been cycled through the insurance business to fabricate an authentic-looking transaction trail. Aveon Global Sigorta A.Ş. has not publicly addressed the accusations.

Taken together, the case underscores how electronic money institutions and insurers operating under shared ownership can inadvertently become conduits for laundering when internal controls fall short. The layering of financial services within related entities can obscure transaction origins, complicating detection for compliance teams and regulators alike. Turkish authorities’ actions underscore the need for independent governance, strict beneficial ownership oversight, and segmented risk management to mitigate cross-entity AML exposures.

Earlier this year, findings from the investigative project Scam Empire—produced by a global consortium of journalists including OCCRP—revealed that two additional companies owned by the same entrepreneur handled payments connected to a vast online fraud scheme. The scheme relied on call centres that persuaded thousands of victims worldwide to transfer hundreds of millions of dollars, with payments moving through myriad companies across jurisdictions, including European-registered payment institutions and banks. Records indicated that companies within the same ownership framework processed some of these transactions.

One payment provider in the network appeared in leaked materials showing more than two million euros passing through an account associated with suspected fraudulent online investment platforms. The institution stated at the time that it monitored activity for red flags and maintained preventative controls, while acknowledging that fraud attempts continue industry-wide despite such measures. It also emphasised that its ultimate beneficial owner did not engage in management or oversight, asserting that operational teams retained independent control over compliance decisions.

Another entity in the structure, a small European bank, said it could not discuss client transactions due to legal confidentiality obligations but confirmed awareness of the Turkish investigation. The bank described the matter as a reputational concern requiring internal handling aligned with regulatory expectations. Public statements stressed that the bank was not part of the Turkish probe and that the allegations related solely to the electronic money institution under investigation.

Although none of these institutions were accused of intentionally facilitating fraud or laundering, their involvement in related payment flows highlighted systemic exposure to illicit activity when controls are bypassed or overloaded. Reporting from the Scam Empire project demonstrated how global fraud networks depend on payment channels across borders to disperse funds, mingling victim payments with legitimate transfers to conceal their origins. These findings emphasise the necessity for enhanced monitoring when serving customers or partners linked to high-fraud sectors or jurisdictions.

The overlap between the Scam Empire disclosures and the Turkish investigation stems from the opacity of complex ownership networks. Corporate structures spanning payment institutions, insurers, banks, and multiple jurisdictions create environments in which criminal proceeds can pass through legitimate-looking entities when oversight is fragmented. Regulators in several countries are increasingly scrutinising such networks for weak points that allow exploitation without direct institutional complicity.

Information publicly released about the Turkish case mirrors long-recognised money laundering typologies. Illegal betting proceeds frequently involve fast-moving, high-value transactions, rapid fund conversions, and the use of intermediaries to obscure origin. Electronic money institutions offer efficient channels for these activities when connections with merchants, gateways, or insurance structures provide multiple layers for laundering.

Authorities noted that illicit funds were introduced into accounts as purported commercial payments lacking genuine economic purpose. Quick accumulation followed by transfers or cashouts aligns with early laundering stages. These behaviours often exploit gaps in monitoring systems designed for standard retail or merchant patterns but not attuned to anomalies tied to betting or cross-border fraud.

Insurance firms within shared ownership structures also pose risks. Premium inflows, reimbursement cycles, and contractual payouts can all serve as vehicles for integrating illicit funds. Criminal actors may feed money into insurance products to build a veneer of legitimacy. When inflows do not match risk profiles or underwriting logic, insurers’ AML systems should trigger escalated reviews. The allegations illustrate how criminals may exploit differences between AML rules in finance and insurance, especially when insurers rely on manual checks instead of real-time monitoring.

Movement of funds across related entities further obscures visibility. Breakdown in beneficial ownership transparency allows funds to travel through companies that appear unconnected. For this reason, regulators increasingly analyse corporate networks holistically rather than isolating entities. Structures spanning fintech, insurance, and banking create avenues for laundering across sectors, reducing visibility for teams confined to single institutions.

Measures such as asset freezes and trustee appointments show that authorities regarded the alleged laundering pathways as significant enough to require immediate intervention. These actions typically occur when officials suspect ongoing criminal exploitation that cannot be halted through standard supervisory measures. Trustee appointments, in particular, reflect concerns that internal management may lack the independence or capacity to correct deficiencies without external oversight.

The broader lesson from the Turkish case is how contemporary financial crime gravitates toward fast-moving non-bank financial entities. Electronic money institutions offer speed and reach, but those same characteristics create vulnerabilities when firms scale faster than their compliance frameworks. Criminal networks exploit this imbalance rapidly.

Insurance companies tied to payment ecosystems through beneficial ownership must adopt equally stringent AML practices. Divergent regulatory regimes can produce blind spots, especially when payment-derived funds are recharacterised as insurance inflows. Insurance AML rules require scrutiny of premium flows, identification of atypical patterns, and rigorous vetting of high-risk customers. When insurers receive payments that closely mirror patterns entering related payment institutions, cross-sector laundering risks escalate.

Entities operating across multiple jurisdictions face additional expectations. Even if individual firms satisfy local obligations, the wider ownership network may harbour risks originating beyond their direct supervision. Regulators increasingly demand group-wide AML governance, consolidated monitoring, and coordinated reporting—especially when networks include payment processors, insurers, and banks in different countries.

For AML professionals, the central takeaways include early detection of red flags, coordination across related entities, robust customer due diligence, and governance structures that eliminate internal blind spots. Flows tied to illegal betting, online investment fraud, or unverifiable commercial activity demand heightened attention. Firms servicing high-risk merchants must implement systems capable of blocking suspicious activity, identifying anomalies promptly, and escalating concerns without delay.

Ultimately, the Turkish investigation reinforces the need for unwavering consistency and governance depth. Regardless of whether institutions knowingly enabled illicit flows, exposure to laundering activity imposes significant reputational and operational consequences. Regulators may resort to drastic oversight tools, including trustee appointments and asset freezes, to halt ongoing abuse. The case serves as a clear reminder that AML is not a peripheral compliance task but a fundamental strategic obligation for every financial institution.

By fLEXI tEAM