Selling Gold to Turkiye

How cross-border gold transactions work in Turkey, what documents are required, why due diligence is non-negotiable, and how Bayraktar Attorneys facilitates legitimate bullion trade between international suppliers and licensed Turkish buyers

Turkey is one of the world's most significant markets for gold. It is among the largest consumers of physical gold globally, operates one of the most active domestic gold refining sectors in the region, and hosts a licensed precious metals exchange in Istanbul. For international gold miners and suppliers, particularly those operating in West Africa, East Africa, and other resource-rich regions, Turkey represents a serious and regulated destination market with real institutional demand.

At Bayraktar Attorneys, we assist international gold suppliers in navigating the Turkish regulatory framework for precious metals imports, facilitating introductions to licensed Turkish buying entities, and structuring the legal and contractual arrangements for cross-border gold transactions. We also conduct, on behalf of our Turkish buying partners, the due diligence process that must be completed before any purchase commitment can be made.

This guide explains how the Turkish gold import system works, what documentation an international gold supplier must be prepared to provide, why the verification process is rigorous, and what role our firm plays in bridging legitimate suppliers with Turkish institutional buyers.

1. Who Can Buy Gold in Turkey? The Licensed Buyer Framework

Turkey's precious metals import system is tightly regulated. The import of standard and non-standard unprocessed precious metals (including raw and bullion gold) can only be carried out by entities specifically licensed for this purpose. These are:

• The Central Bank of Turkey (TCMB)

• Precious Metals Intermediary Institutions (Kiymetli Madenler Araci Kuruluslari) that hold a license from the Ministry of Treasury and Finance and are members of Borsa Istanbul (Kiymetli Madenler ve Kiymetli Taslar Piyasasi)

• Banks operating as authorized precious metals trading entities

This is the fundamental starting point for any international supplier to understand: you cannot sell gold to a randomly identified Turkish company. The buyer must be a licensed entity within this defined framework. The licensing requirements are substantial, including minimum paid-in capital requirements, sector experience requirements for founders and management, comprehensive internal control systems, and annual compliance reporting obligations.

Bayraktar Attorneys maintains working relationships with licensed Turkish precious metals buyers. Where we receive an inquiry from an international supplier, our role is to conduct the necessary verification on behalf of the Turkish buyer, and to structure and document the transaction if the due diligence process produces a satisfactory result.

1. Why Due Diligence in International Gold Transactions Is Non-Negotiable

International gold trading, particularly involving suppliers from West Africa, East Africa, and parts of Southeast Asia, is one of the most fraud-prone sectors in global commodity trade. The patterns of fraud are well established and well documented: advance payment requests, falsified documents, misrepresented purity or weight, non-existent shipments, and elaborate social engineering schemes targeting buyers and intermediaries.

Our Turkish buying partners have direct experience of these patterns. Before we were involved, they had encountered situations involving false export declarations, manipulated assay reports, videos and photographs of gold that turned out to belong to entirely different transactions, and counterparties who disappeared after receiving partial payment.

1. The Due Diligence Process: What We Assess Before Facilitating Any Transaction

Before we introduce an international gold supplier to our licensed Turkish buying partner, we conduct a structured due diligence assessment. This assessment covers the supplier's legal status, their authorization to sell the gold they are offering, the authenticity of their prior transaction history, and the completeness and verifiability of their documentation.

The assessment is not optional and cannot be shortened. Our Turkish buying partners have instructed us that no transaction can proceed without a satisfactory due diligence outcome. This is both a business requirement and a legal compliance obligation: Turkish licensed precious metals entities are subject to Anti-Money Laundering (AML) regulations under Law No. 5549 and are required to verify the identity and legitimacy of their counterparties before any trade.

3.1. Initial Assessment: Source and Authorization

The first question we ask every international gold supplier is whether they hold a valid mining license in the country where the gold originates, or whether they are purchasing the gold from a third-party supplier. This distinction is fundamental:

• Licensed miners: a supplier who holds a valid mining license from the relevant national authority in their country of operation is in the strongest position. The license is official evidence that they are a recognized operator, that the gold has been lawfully extracted, and that they have the right to sell it.

• Third-party sourcing: a supplier who is sourcing gold from other miners or local traders is not necessarily problematic, but the compliance requirements are more complex. They must be able to document the chain of title from the point of extraction, demonstrate that the sourcing complies with the relevant laws of their country (including any conflict minerals or chain of custody regulations), and confirm that the gold has not been subject to any export restrictions at the point of origin.

3.2. Prior Transaction History

Turkish licensed buyers require evidence that the supplier has successfully completed similar transactions in the past. This is not about minimum transaction size: even relatively small prior transactions are useful if they are properly documented. What the buyer needs to see is that the supplier has conducted real, verifiable gold trade, not simply that they claim to have done so.

Evidence of prior legitimate trade activity includes, but is not limited to, official documentation from previous transactions such as export declarations, shipping documents, import records at the destination, and assay reports from recognized laboratories. Informal evidence such as photographs, videos, or testimonials from unverifiable counterparties is not sufficient.

1. Complete Documentation Requirements

The following is the full set of documents that our Turkish buying partner requires before any transaction can proceed. We request these documents from every supplier regardless of the quantity or value of the proposed transaction. Providing a partial or incomplete document set will delay the process; providing falsified documents will immediately terminate our engagement.

4.1. Supplier Identity and Authorization Documents

• Valid government-issued mining license: issued by the relevant national authority (Ministry of Mines, Ministry of Natural Resources, or equivalent) in the country where the gold originates. The license must confirm the holder's name or entity name, the geographical area covered, the mineral(s) authorized for extraction, and the validity period.

• Corporate registration documents: for company sellers, the certificate of incorporation or equivalent company registration document, showing the company's legal name, registration number, country of registration, and authorized representatives.

• Identity documents of the beneficial owner(s): government-issued photo identification (passport) of the individual who ultimately owns or controls the selling entity, and of any authorized representatives who will sign transaction documents.

• Export license or authorization: where the country of origin requires an export license for gold, a copy of the valid export authorization issued by the relevant national authority.

4.2. Documents Relating to the Specific Gold Being Offered

• Assay (Purity) Report from an accredited laboratory: an official assay report confirming the purity (fineness) of the gold being offered, issued by a recognized and accredited assay laboratory. The report must identify the specific consignment, state the purity level, and be dated within a reasonable period of the proposed transaction.

• Weight certificate: an official certificate confirming the gross and net weight of the gold consignment, issued by a recognized weighing authority or the assay laboratory.

• Certificate of origin: confirming the country and, where required, the specific geographical area of extraction.

• Kimberley Process equivalent or conflict-free declaration: where the gold originates from a jurisdiction subject to conflict minerals regulations or where there is a relevant chain of custody certification requirement, the applicable compliance documentation must be provided.

4.3. Prior Transaction Documentation

• Official export declaration from a prior transaction: a copy of the official export declaration filed with the customs authority in the country of origin for a prior gold transaction, demonstrating that the supplier has successfully exported gold through official channels.

• Import declaration or entry record at the destination country: the official import entry document or customs clearance record from the destination country of a prior transaction. For example, where a prior shipment went to Hong Kong, the Hong Kong customs entry declaration would be the relevant document.

• Official shipping document from a prior transaction: an airway bill (AWB), bill of lading, or equivalent official shipping document from a prior transaction, issued by a recognized freight or courier company, confirming the origin, destination, contents, and weight of the shipment.

4.4. Banking and Payment Documentation

• Bank account details in the seller's name: confirmation of the bank account to which payment is to be made, together with evidence that the account is registered in the name of the selling entity or individual (as applicable).

• Bank reference letter: a letter from the seller's bank confirming the existence and good standing of the account, and ideally confirming that the account has been used for commercial precious metals transactions.

• Prior payment receipt: where available, a bank receipt or SWIFT confirmation of payment received in connection with a prior gold transaction, as evidence of the financial side of a prior completed trade.

1. What We Cannot Accept as Verification

To save time for all parties, we want to be explicit about what does not constitute acceptable verification in our due diligence process. The following types of material are commonly provided by suppliers but are not accepted as evidence of the legitimacy or authenticity of a gold transaction:

• Generic videos of gold or mining operations, including videos widely circulated on social media or messaging platforms

• Photographs of gold bars, nuggets, or mining sites without accompanying official documentation

• Self-produced or informally prepared export declarations, calibration reports, or quality certificates that have not been issued by a recognized official authority

• References from unverifiable individuals or companies who cannot be independently confirmed

• Claims of prior transactions without supporting official documentation

• Documents that cannot be verified with the issuing authority

We understand that obtaining comprehensive official documentation can be challenging in some jurisdictions. Where a supplier has genuine gold but is encountering difficulty obtaining specific documents, we encourage them to contact us to discuss what alternative verification routes may exist in their specific country and context. We cannot, however, accept undocumented claims or informal materials as substitutes for official verification.

1. The Turkish Regulatory Framework: What Happens on the Turkey Side

Once we have completed due diligence on an international supplier and the buyer is satisfied, the Turkish regulatory framework governs how the transaction is structured and executed.

6.1. Notification to Borsa Istanbul

Before each unprocessed gold import, the licensed Turkish buying entity must notify Borsa Istanbul at least one business day before the customs declaration is finalized. The notification must include information on the payment method and the purpose of the import.

6.2. Customs Declaration

A customs declaration must be filed electronically through the Ministry of Trade system. The declaration requires the correct commodity code (GTI P), the declared value of the gold, and all supporting documents including the invoice, certificate of origin, and assay report. Certain customs regimes also require the gold to be sent to an assay house for independent analysis before the declaration is finalized.

6.3. Delivery to Borsa Istanbul

Imported standard and non-standard unprocessed precious metals must be delivered to Borsa Istanbul within three business days of customs clearance. The gold cannot simply be held by the importing company without this delivery step.

6.4. VAT and Customs Duty

Gold is exempt from customs duty in Turkey (zero rate). However, VAT at the rate of 20% applies to the declared value of the imported gold. For an international supplier, understanding this tax structure is important when negotiating the transaction price, as the VAT cost falls on the Turkish importing entity and will be factored into the price they are willing to pay.

6.5. Monthly Import Quota

As of August 2023, Turkey operates a monthly quota system for unprocessed gold imports. The total monthly quota is 12 tonnes, allocated among licensed buyers based on their transaction history and bids at Borsa Istanbul. This means that even a verified and documented transaction may need to be scheduled to fit within the buying entity's quota allocation. Large consignments may need to be phased across multiple months.

1. How Bayraktar Attorneys Facilitates the Transaction

Our role in cross-border gold transactions is to serve as the legal intermediary between the international supplier and the licensed Turkish buying entity. We do not purchase gold ourselves, and we do not provide advance payments or financial guarantees on behalf of the buyer. Our specific services include:

• Due diligence review: we conduct the full due diligence assessment described in this guide on behalf of the Turkish buying partner, reviewing all submitted documents and assessing whether the supplier meets the compliance requirements.

• Communication and coordination: we manage all communication between the international supplier and the Turkish buyer, ensuring that information is exchanged accurately and efficiently and that both parties understand what is required at each stage.

• Contract drafting and review: once due diligence is complete and both parties are ready to proceed, we draft or review the transaction contracts, including the sale and purchase agreement, any escrow arrangements, and any ancillary documentation required for the Turkish regulatory framework.

• Regulatory compliance: we advise the Turkish buyer on compliance with the applicable Turkish regulations, including Borsa Istanbul notification requirements, customs declaration requirements, and AML obligations.

• Data protection: all personal data and commercial information submitted by international suppliers to our firm is handled in strict compliance with our professional obligations as attorneys and with the applicable data protection legislation. We do not share supplier information with third parties other than the specific licensed Turkish buying partner involved in the transaction.

Frequently Asked Questions

1. I am a gold miner in West Africa. Can I sell gold directly to a Turkish company?
2. I am a gold miner in West Africa. Can I sell gold directly to a Turkish company?

Only if the Turkish company is a licensed Precious Metals Intermediary Institution (Kiymetli Madenler Araci Kurulusu) that is a member of Borsa Istanbul. You cannot sell unprocessed gold to an unlicensed Turkish buyer. If you contact Bayraktar Attorneys, we will assess whether you meet the documentation and compliance requirements and, if so, introduce you to our licensed Turkish buying partner.

1. What is the minimum transaction size that your Turkish buying partner considers?
2. What is the minimum transaction size that your Turkish buying partner considers?

There is no absolute minimum, but smaller parcels (below approximately half a kilogram or $50,000 USD equivalent) are at the lower threshold of what institutional buyers typically process given the fixed compliance costs per transaction. Our Turkish buying partner has expressed interest in establishing long-term relationships with verified suppliers, which means that smaller initial transactions can be a starting point if the documentation is complete and the due diligence is satisfactory.

1. Why do you need documentation from prior transactions? I have not sold to Turkey before.
2. Why do you need documentation from prior transactions? I have not sold to Turkey before.

Prior transaction documentation from any destination country is acceptable, not only Turkey. If you have previously exported gold to a buyer in Hong Kong, the UAE, India, or any other market, the official export declaration, shipping document, and import entry record from that transaction are exactly what we need. The purpose is to verify that you have conducted real, official gold trade in the past, which significantly reduces the risk of fraud for the buyer.

1. Can I provide a video or photographs of my gold as initial verification?
2. Can I provide a video or photographs of my gold as initial verification?

No. Videos and photographs are not accepted as verification and cannot substitute for official documentation. This is not a reflection of doubt about your personal credibility: it is because generic gold videos and photographs are widely circulated and cannot be verified as belonging to a specific seller or a specific consignment. Official documents issued by recognized authorities can be verified. Videos and photographs cannot.

1. Who pays the shipping and insurance costs for the gold?
2. Who pays the shipping and insurance costs for the gold?

The allocation of shipping and insurance costs is a matter for the transaction contract and is negotiated between the parties. In standard international bullion trade, costs are typically allocated on standard Incoterms terms. We assist in structuring these terms as part of our contract drafting service.

1. Is my personal and commercial information safe with Bayraktar Attorneys?
2. Is my personal and commercial information safe with Bayraktar Attorneys?

Yes. As a law firm, we are subject to strict professional confidentiality obligations. All personal data and commercial information you provide to us is processed in accordance with our obligations under applicable data protection law. We do not share your information with any party other than the specific licensed Turkish buyer involved in the transaction you have initiated with us, and only to the extent necessary for the due diligence and transaction process.

1. How long does the due diligence process take?
2. How long does the due diligence process take?

Where a complete document set is provided from the outset, we are typically able to complete our initial assessment within a few business days and provide feedback to both the supplier and the Turkish buyer. Where documents are missing or need to be obtained from national authorities, the timeline depends on how quickly those documents can be obtained. Incomplete document submissions are the most common cause of delay.

Conclusion

Turkey is a serious and regulated market for international gold trade. For miners and suppliers operating in Africa and other gold-producing regions, it represents a genuine institutional demand channel, but one that can only be accessed through licensed buyers and with a complete, verifiable documentation package.

Bayraktar Attorneys serves as the legal bridge between international gold suppliers and licensed Turkish buying entities. We conduct the due diligence, manage the compliance requirements, and structure the transaction contracts. We do not facilitate undocumented transactions and we do not work with suppliers who cannot meet the documentation standards described in this guide.

If you are an international gold miner or supplier with a valid mining license, a documented track record of prior legitimate gold transactions, and the official documentation described in this guide, we welcome your inquiry. Please contact us with a brief description of your operation, your country of origin, and the quantity and purity of gold you are seeking to sell, and we will conduct an initial assessment of whether your profile meets the requirements of our Turkish buying partner.