28 Countries, 278 People, One Document: The Real Test of the Fund Investigation

The record

The real test

The real test of the fight against corruption is not how many people are detained or how many operations are conducted. It is whether the legal system can apply the same rule in the face of power, office, political proximity and economic influence.

This standard has three components. Investigations must be based on concrete evidence rather than identity. Political or economic power must not create de facto immunity from investigation. And the presumption of innocence, defence rights and judicial review must be protected at the same time.

The principle is not unique to Türkiye. Looking at how three different legal systems have institutionalised it provides a framework for assessing investigations now under way in Türkiye.

France: institutional expertise

France's specialised national financial prosecutor became operational in 2014: the Parquet National Financier (PNF). It investigates corruption, misuse of public funds, tax fraud and financial-market offences involving politicians and major companies alike. [1]

According to the PNF's 2025 overview, it had 771 ongoing cases at the end of that year and opened 249 new ones during it. Approximately 46% concerned integrity offences, including corruption and misuse of public funds; 48% concerned offences against public finances, including tax fraud; and 5% concerned financial markets. Fines awarded to the Treasury in 2025 amounted to €186.75 million; confiscation and damages brought the total to €345.67 million.

Just 20 prosecutors do this work. The point is the structure rather than the number: financial crime has become the core responsibility of a specialised institution instead of a secondary task for general prosecutors.

Luxembourg: independence across borders

The European Public Prosecutor's Office (EPPO), which investigates crimes against the EU's financial interests, has operated from Luxembourg since 2021. It is headed by Laura Codruța Kövesi, Romania's former chief anti-corruption prosecutor. [2]

Article 6 of its founding regulation explicitly establishes its independence: the European Chief Prosecutor and prosecutors must neither seek nor take instructions from anyone outside the EPPO. Member states and EU institutions must respect that independence. A member state's government therefore cannot simply stop a case concerning one of its nationals. [3]

The scale is substantial. The EPPO's 2025 annual report records 3,602 active investigations at year-end, with estimated damage exceeding €67.27 billion. It opened 2,030 new investigations in 2025, 35% more than the previous year, filed 275 indictments and obtained court orders freezing €1.13 billion in assets. Its remit includes corruption, misuse of public funds, money laundering and large-scale VAT and customs fraud. [2]

Singapore: investigating a serving minister

Singapore's Corrupt Practices Investigation Bureau (CPIB) opened an investigation into serving transport minister S. Iswaran in 2023. [4] It arose from information uncovered during the CPIB's own work and reported to the prime minister in May 2023. Following Prime Minister Lee Hsien Loong's approval on 6 July, the investigation formally began on 11 July, when Iswaran was also arrested. [5]

Minister Chan Chun Sing's parliamentary statement of 2 August 2023 summarised the institution's position: although the CPIB reports directly to the prime minister, it is functionally independent and does not require the prime minister's approval to conduct investigations. [6]

The process ran its course. Iswaran resigned as minister, MP and party member on 16 January 2024; two days later he appeared in court facing 27 charges. He pleaded guilty to five charges on 24 September and received a 12-month prison sentence on 3 October 2024. Singapore's message was clear: political office does not place someone beyond investigation.

Türkiye: the standard and the fund investigation

In Türkiye, a similar debate increasingly centres on economic crime. Akın Gürlek, appointed justice minister on 11 February 2026, previously served as a heavy penal court president, deputy justice minister from 2022 and Istanbul's chief public prosecutor from October 2024. [7] Politically sensitive cases he heard as a judge drew fierce opposition criticism. The European Commission's November 2025 Türkiye report reiterated concerns about the judiciary; Ankara rejected it as biased, prejudiced and unfounded. [8]

That contested record makes the standard Gürlek has set as minister all the more significant. In his speech opening the judicial year on 2 September 2026, he described a single direction for investigations: wherever they lead, the material truth must be established along the path shown by law and concrete evidence. [9] He also said that ensuring no unlawful act targeting the nation's shared resources goes unanswered is a requirement of the rule of law, and stressed that protecting the presumption of innocence is as much a duty of justice as punishing the guilty. [10]

The fund investigation that erupted in mid-September became a test of those words. Rapid sales in certain investment funds on 15–16 September drove Borsa Istanbul's index down by as much as 10%. The Capital Markets Board (SPK) ordered the liquidation of 131 funds belonging to seven portfolio management companies. Istanbul's public prosecutor's money-laundering investigations bureau is examining allegations of forming a criminal organisation, aggravated fraud, laundering criminal proceeds and breaches of capital markets law.

On 26 September, Gürlek said action had been taken against 76 suspects, 45 of whom had been remanded in custody, and that the assets of 46 legal entities, 18 funds and 42 individuals had been frozen. [11] A fifth wave on 30 September brought 34 detention orders and scrutiny of 26 stocks over suspected manipulation. The minister's overall figures were 217 suspects, 56 remanded in custody and 88 under judicial supervision. Assets identified as criminal proceeds were to be transferred to a fund within the Savings Deposit Insurance Fund (TMSF). [12]

Four institutions, one standard

When the investigation reaches power

A legal system's standard becomes apparent when an investigation reaches people with political or economic power. The fund investigation crossed that threshold on 7 October.

On that day, former family and social services minister Fatma Betül Sayan Kaya and her husband İlyas Kaya gave statements as suspects at Istanbul's Çağlayan courthouse. Their names had surfaced over trading in Özata Denizcilik shares. Both said they had bought the shares in April 2026 and sold them in August and September, received neither guidance nor inside information, and transferred their profits to the account designated by the TMSF. [13]

On 29 September, prosecutors had written to the relevant institutions to freeze the couple's assets. Reuters, citing the Justice Ministry, reported that the SPK was expected to file a criminal complaint concerning them. Kaya said she had resigned from her party roles on the evening of 26 September; AK Party Secretary-General Eyüp Kadir İnan said she was no longer a party member.

Suspect status creates no presumption of guilt. What matters as a data point is that a former minister from the governing party could be brought within the investigation: a concrete example of political status alone not conferring immunity.

President Recep Tayyip Erdoğan’s address to the AK Party’s expanded provincial chairs’ meeting on 29 September 2026 also encapsulated this stance: he warned that anyone believing their mistake affected only themselves, or concerned only their own person, was seriously mistaken. [16]

The file crosses borders

On 14 October, the investigation crossed a second threshold: national borders. Deputy Treasury and Finance Minister İlhan Hatipoğlu said prosecutors in 28 countries had been contacted, with 48 separate requests seeking information about the foreign accounts and assets of 278 people. [14] The same day, AK Party Samsun MP Ersan Aksu gave updated figures: action against 282 people, 84 remanded in custody and warrants to locate 27 suspects. He said party affiliation would not determine treatment and that anyone disrupting markets or committing fraud would answer before the law.

At the other end of the file are investors. The 131 funds ordered into liquidation by the SPK have 455,578 unit holders; proposed legislation is expected to provide payments to approximately 350,000 investors. Each overseas request does more than trace the money: it tests how well Türkiye's evidentiary file stands up before a foreign prosecutor who is not a party to its domestic politics.

That is not the entire standard, however. Concrete evidence, defence rights, effective judicial review and a final decision by independent courts must all be present for the test to be passed. The subsequent course of the case will be where criticism of selective justice in Türkiye is tested.

The common denominator is the document

The common denominator of these four examples is the document, not the prosecutor. Major cases proceed through documents rather than rumours. The Iswaran investigation began with information uncovered by the CPIB itself. Türkiye's fund investigation expanded by tracing outflows between 1 July and 16 August, starting with the largest amounts. The Panama Papers began with a single anonymous message from John Doe asking whether a journalist was interested in data. [15]

That message brought Süddeutsche Zeitung 11.5 million documents and 2.6 terabytes of data. Under the ICIJ umbrella, 107 media organisations in 80 countries examined them for more than a year. The first reports, published on 3 April 2016, led to Iceland's prime minister's resignation; by 2019, governments had recovered more than $1.2 billion in taxes and penalties.

The other side of the same case is equally instructive. In June 2024, a Panamanian court acquitted all 28 defendants, including the founders of Mossack Fonseca, for insufficient evidence. Without an investigation to turn a document into evidence and a court to test it, the document remains paper.

This is the less visible side of the promise of evidence-based justice. Following concrete evidence is not just an instruction to prosecutors; it is a call to those holding documents: auditors, former employees, whistleblowers, journalists and ordinary citizens. Where prosecutors examine evidence, more people know that the document in their possession matters. The missing piece of a case is often in someone's drawer rather than an institution's archive.

Three tests for Türkiye

International experience points to one common principle: effective anti-corruption work requires the ability to keep the same distance from all political sides when necessary.

For Türkiye, the test now has three faces. First, the same rule must continue to apply when an investigation reaches people close to the government; 7 October supplied the first concrete data point. Second, the case must remain grounded in evidence, defence rights and independent judicial scrutiny through to its conclusion. That has yet to be tested.

Third comes the test beyond the border. Forty-eight requests to 28 countries carry Türkiye's domestic debate to 28 foreign prosecutors' desks. Those prosecutors are not parties to Turkish politics; what they have is the documentation Ankara sends. Whether a request succeeds depends on the quality of its evidence rather than the size of the operation. The standard illustrated by Paris and Luxembourg will now be applied to Türkiye's file.

The Ledgers will follow this process through the documents. A document is evidence where there is a prosecutor to read it and act upon it; otherwise it is only paper. This time, some of those prosecutors sit outside Türkiye.

Based on reporting from: PNF · 2025 activity report; EPPO · Annual report 2025; EPPO Regulation · Article 6: independence; S. Iswaran · Prosecution chronology; Singapore Prime Minister’s Office · CPIB investigation, 6 July 2023; CPIB · Minister Chan Chun Sing’s parliamentary statement, 2 August 2023; Akın Gürlek · Biography; Türkiye Ministry of Foreign Affairs · Response to the EU report; Sabah · Judicial year opening, 2 September 2026; Türkiye Gazetesi · Justice minister’s speech, 2 September 2026; Euronews · Fund investigation, 26 September 2026; NTV · Fund investigation, 30 September 2026; Euronews · Fatma Betül Sayan Kaya and İlyas Kaya, 7 October 2026; Ekonomim · Requests to 28 countries, 14 October 2026; Panama Papers · Background and outcomes; AK Party · Erdoğan’s speech, 29 September 2026.