The U.S. corporate compliance environment has become significantly more demanding for international businesses. The Corporate Transparency Act's beneficial ownership reporting requirements, new SEC disclosure mandates, emerging AI governance frameworks, and enhanced enforcement of existing compliance obligations have collectively created a compliance landscape that requires systematic management.

For Turkish companies operating in the United States — whether through subsidiaries, joint ventures, or direct operations — staying current with these developments is essential to avoiding penalties, maintaining business relationships, and protecting the company's reputation in the U.S. market.

The Corporate Transparency Act (CTA), enacted in 2021 and implemented through FinCEN regulations effective January 1, 2024, requires most U.S. companies to report information about their beneficial owners to the Financial Crimes Enforcement Network (FinCEN). The CTA is designed to combat money laundering, tax evasion, and other financial crimes facilitated by anonymous shell companies.

The CTA applies to "reporting companies" — corporations, LLCs, and similar entities formed under U.S. law or registered to do business in the United States. Exemptions exist for large operating companies (more than 20 full-time employees, more than $5 million in annual revenue, and a physical U.S. office), publicly traded companies, regulated financial institutions, and certain other categories.

Most Turkish-owned U.S. subsidiaries — particularly newly formed entities established for market entry purposes — will be reporting companies subject to the CTA.

Reporting companies must disclose:

• The company's legal name, trade names, address, jurisdiction of formation, and EIN
• Information about each beneficial owner (individuals who own or control 25% or more of the company, or who exercise substantial control over the company): full legal name, date of birth, residential address, and a copy of a government-issued ID

• Companies formed before January 1, 2024: initial report was due January 1, 2025
• Companies formed in 2024: initial report was due within 90 days of formation
• Companies formed after January 1, 2025: initial report is due within 30 days of formation
• Updates to reported information: due within 30 days of any change

Penalties for willful non-compliance: up to $591 per day (adjusted for inflation) in civil penalties, plus criminal penalties of up to $10,000 and two years imprisonment.

The CTA has been subject to significant litigation challenging its constitutionality. As of mid-2026, the Supreme Court has not definitively resolved the constitutional questions, and enforcement has been subject to court-ordered stays in certain jurisdictions. Turkish companies should consult legal counsel regarding the current enforcement status and their specific reporting obligations.

The Securities and Exchange Commission (SEC) adopted final rules in March 2024 requiring public companies to disclose climate-related risks and greenhouse gas emissions in their annual reports. While these rules apply primarily to SEC-registered issuers, they have significant implications for private companies — including Turkish subsidiaries of U.S. public companies — that are part of the supply chain or business relationships of public companies.

Scope 3 Emissions: The SEC rules require disclosure of Scope 3 emissions — emissions from a company's value chain, including suppliers and customers — for large accelerated filers. Turkish companies that supply goods or services to U.S. public companies may be asked to provide emissions data to their U.S. customers for Scope 3 reporting purposes.

Contractual Implications: U.S. public companies are increasingly including ESG representations and reporting obligations in their supplier contracts. Turkish companies should anticipate requests for emissions data, sustainability certifications, and ESG compliance representations from their U.S. business partners.

The rapid deployment of artificial intelligence in business operations has created a new compliance frontier. The U.S. federal government and several states have enacted or proposed AI governance frameworks that affect businesses operating in the United States.

Executive Order on AI (2023): The Biden Administration's Executive Order on Safe, Secure, and Trustworthy AI established requirements for AI developers and deployers, including risk assessments, transparency obligations, and safety testing for high-risk AI systems.

State AI Laws: Several states — including California, Colorado, and Illinois — have enacted AI-specific legislation addressing algorithmic discrimination, automated decision-making in employment, and AI transparency. Companies operating in multiple states must navigate a patchwork of state requirements.

Practical Implications for Turkish Companies: Turkish companies deploying AI systems in their U.S. operations — for hiring, credit decisions, customer service, or other applications — should assess their AI systems against applicable federal and state requirements. Companies that use AI systems developed by third-party vendors should review their vendor agreements for AI governance representations and warranties.

FinCEN's Customer Due Diligence (CDD) rule requires financial institutions to identify and verify the beneficial owners of legal entity customers. Turkish companies opening U.S. bank accounts or establishing relationships with U.S. financial institutions should be prepared to provide beneficial ownership information, organizational documents, and other KYC (Know Your Customer) documentation.

Enhanced due diligence requirements apply to customers from jurisdictions identified as high-risk for money laundering. Turkish companies should be aware that their U.S. banking relationships may be subject to periodic review and enhanced documentation requirements.

The Foreign Corrupt Practices Act prohibits U.S. companies and their foreign subsidiaries from bribing foreign government officials to obtain or retain business. Turkish subsidiaries of U.S. companies are subject to the FCPA; Turkish companies that are not U.S. persons may be subject to the FCPA if they take any action in furtherance of a bribe while in the United States.

Turkish companies operating in markets with elevated corruption risk — including certain Middle Eastern, African, and Central Asian markets — should ensure their FCPA compliance programs are robust and that their U.S. business partners' FCPA compliance requirements are understood and met.

1. Assess CTA reporting obligations for all U.S. entities — determine whether each entity is a reporting company and, if so, whether initial reports have been filed
2. Prepare for ESG data requests from U.S. public company customers — establish systems to track and report emissions data
3. Audit AI systems deployed in U.S. operations against applicable federal and state AI governance requirements
4. Review U.S. banking relationships and ensure KYC documentation is current and complete
5. Assess FCPA exposure for any operations in high-risk markets and ensure compliance programs are adequate
6. Establish a compliance calendar to track ongoing reporting obligations and deadlines

• The Corporate Transparency Act requires most Turkish-owned U.S. subsidiaries to report beneficial ownership information to FinCEN — penalties for non-compliance are substantial
• SEC climate disclosure rules are creating ESG reporting obligations that flow through supply chains to Turkish suppliers of U.S. public companies
• AI governance is an emerging compliance frontier — companies deploying AI in U.S. operations should assess applicable requirements now
• AML/KYC requirements for U.S. banking relationships are increasingly demanding — Turkish companies should maintain current and complete documentation
• FCPA compliance is essential for Turkish companies with U.S. affiliates operating in high-risk markets
• A proactive compliance calendar is the most effective tool for managing the growing U.S. compliance burden