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Borsa _Istanbul Review

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Borsa Istanbul Review 22-5 (2022) 1020–1032
http://www.elsevier.com/journals/borsa-istanbul-review/2214-8450

Full Length Article

The effect of institutionalization level on the relationship of corporate

governance with money laundering activity: An example of the BIST
Corporate Governance Index
Murat Çemberci a,*, Do

gan Başar b, Zuhal Yurtsever c
a
Yıldız Technical University, Faculty of Economics and Administrative Sciences, Business Department, Turkiye
b
Central Bank of the Republic of Turkiye, Turkiye
c
Yıldız Technical University, Turkiye
Received 16 May 2022; revised 18 July 2022; accepted 18 July 2022
Available online 6 August 2022

Abstract

The goal of this study is to analyze the impact of corporate governance (CG) principles on perceptions of anti-money-laundering effectiveness
(AMLE) based on data obtained from financial institutions that are and are not included in the Borsa İstanbul (BIST) Corporate Governance Index
(CGI). This study examines the relationship between CG and perceptions of AMLE through a survey of participants working at financial in-
stitutions, divided into two groups, conducted in April 2021. The results from testing the hypotheses show a significant relationship between CG
and AMLE across multiple subdimensions. However, in terms of the perceptions of AMLE, it is not found a significant difference between
financial institutions based on whether they are included in the BIST CGI.
Copyright © 2022 Borsa İstanbul Anonim Şirketi. Published by Elsevier B.V. This is an open access article under the CC BY-NC-ND license
(http://creativecommons.org/licenses/by-nc-nd/4.0/).

Keywords: Anti-money laundering effectiveness; BIST CGI; Turkey

1. Introduction a significant risk for businesses, countries, and societies

Technological development has caused significant changes
in many sectors, especially commercial business. This
advancement led to the disappearance of trade barriers, pro-
vided up-to-date solutions to problems, and thus is instrumental
in ensuring that enterprises can obtain a sustainable competi-
tive advantage. However, although the disappearance of
national borders for commercial business increased social well-
being and developed trade, technological advancements can
sometimes be used for harmful purposes (Shelley, 1998). For
example, technological developments can be misused, allowing
organized crime and money laundering to increase and posing
* Corresponding author.
E-mail addresses: cemberci@yildiz.edu.tr (M. Çemberci), doganbasar@
gmail.com (D. Başar), zuhalyurtsever@gmail.com (Z. Yurtsever).
Peer review under responsibility of Borsa İstanbul Anonim Şirketi.
(Yetim, 2000). Money laundering is carried out by concealing
the proceeds of crime. In general terms, it is defined as all
activity that aims to portray dirty money as legitimate. Money
obtained from illegal arms sales, drug trafficking, bribery,
cyber fraud, and activities involving technological illusions,
human trafficking and migrant smuggling are the major sources
of money-laundering crimes (Sohn, 2003). The risk of financial
crimes, which poses a significant danger to the commercial
activities of businesses, has increased with globalization and,
as a result, of the extent of risk and so has the need to use all
tools at hand to control that risk.
Nowadays, money-laundering operations involve organiza-
tions that operate in more than one country, so it is critical for
the fight against them to be primarily global; at the same time,
it is also crucial for policies created at a global scale to be
adopted and implemented at a national scale in each country,
too. If this process is to be effective, it is vital for the fight to be

https://doi.org/10.1016/j.bir.2022.07.006
2214-8450/Copyright © 2022 Borsa İstanbul Anonim Şirketi. Published by Elsevier B.V. This is an open access article under the CC BY-NC-ND license (http://
creativecommons.org/licenses/by-nc-nd/4.0/).
M. Çemberci, D. Başar and Z. Yurtsever
simultaneously national and global. The lack of global coop-
eration enables the location of money-laundering activities to
migrate to countries with gaps in their money-laundering reg-
ulations and audits (Yetim, 2000). Another important aspect of
the fight against money laundering at a national scale is that
when the fight remains within national borders, the measures
and practices are executed just by small groups and obliged
persons, so the issue is addressed only within a narrow scope.
Regardless of the size and field of activity, it is extremely
important for the risks to understood by the enterprises other
than the obligated groups, which are part of the financial and
trading system, and measures should be taken to protect these
enterprises as well. Enterprises that become a party to illegal
money transfers can be affected very negatively and pushed out
of the market (Yetim, 2000). The fact that stakeholders are also
global in terms of trade means that the effects of the crises and
scandals are reflected on international markets. In this context,
sustainability efforts in the context of challenging competitive
conditions for enterprises are closely linked to developing and
implementing new strategies and understandings to support
their corporate guarantees. Within the framework of these dy-
namics, firms can increase their reliability by increasing the
activities of enterprises that adopt corporate governance pol-
icies focused on the common good and the well-being of their
stakeholders, as well as their economic goals, and transparency
in their financial information (OECD, 2004). The concept of
corporate governance has been a common subject of research
in recent years, and the principles formed under this concept
were implemented by enterprises (Musteen et al., 2009).
Likewise, recent financial crises and risks in the world have
made corporate governance practices even more critical. After
the investment losses during the Asian financial crisis, corpo-
rate governance was at the heart of both investor rights pro-
tection and reforms in capital market development (Ararat &
Yurtoğlu, 2012). In this case, the lack of financial discipline
and effective audit policies led to the actualization of risk
(Capital Markets Board of Türkiye). Addressing the risk of
money laundering, which is an important element of the eco-
nomic and commercial system today, by creating and devel-
oping policies outside the context of corporate governance
would prevent the structure from being fully effective. The
corporate governance approach is an important tool in the
management and prevention of risk from financial crimes.
The existing literature mainly focuses on the regulations and
effects of the risk of financial crime at a global scale, its impact
on the economy, and research on this issue. However, further
research needs to be done not only on legal regulations but on
how to assess this issue as it relates to management and the
tools to control the risk at hand. Because of the extent of the
risk of financial crimes, the added value that corporate gover-
nance principles and practices provide for the adaptation of
legal regulations and the fact that employing only the measures
defined by official authorities will be insufficient for businesses
became a main topic of conversation. Based on a research
model that addresses these needs, this study investigates the
relationship between efforts to combat laundering (called anti-
money-laundering activity) and the level of institutionalization.
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Then, using a survey of employees at financial institutions, it is
investigated the perception of corporate governance and anti-
money-laundering activity. The employees are mostly at
financial enterprises in the BIST CGI and financial enterprises
outside this group. This research model was created using a
five-point Likert-type assessment scale, measuring variables
about the perception of anti-money-laundering policies and
corporate governance. The anti-money-laundering activity
variable uses a scale for the prevention and responsibility for
prevention, and the perception of corporate governance vari-
able measures fairness, equality and accountability, re-
sponsibility, and transparency. The questionnaire was applied
to a total of 350 participants.
Based on the analysis, it is concluded that corporate
governance and anti-money laundering effectiveness (AMLE)
have a significant relationship as shown by the scope of sub-
dimensions. However, it is not concluded that a significant
difference exists between the financial institutions included in
the BIST CGI and those that are not included in the BIST CGI
in terms of their effectiveness in fighting money laundering.
Following this introduction, the study is organized in five
sections. In Section 2 the conceptual framework was presented,
and in Section 3 the literature was reviewed. In Section 4, in-
formation about the data and methodology was provided, with
the results of the analysis. The study concludes with Section 5,
which offers comments on the findings.
2. Conceptual framework
2.1. The concept of money laundering and the activity of
fighting money laundering
According to the general definition used in society, dirty
money comes from criminal activity and illegal sources (Ergül,
2005). However, money laundering involves transactions
aimed at hiding the real source of the money to enable assets
obtained outside legal means to appear as if they were obtained
from legitimate sources (Aykın, 2010). Legitimization of in-
come from activities specified by law as crimes is the basis of
money laundering. In parallel with international practice and
standards, in Turkey “preliminary crimes” are defined under
Article 282 of the Turkish Criminal Code 5237 as “all kinds of
illegal activities subject to imprisonment for at least six
months.” From a legal perspective, money laundering and
obtaining dirty money are considered separate crimes. How-
ever, the basis of money laundering is dirty money (Yetim &
Dağtekin, 2016). Money-laundering methods vary based on
the tools in financial systems as well as practices in different
countries. In many cases, the people who obtain and launder
dirty money are different. Providers of money-laundering ser-
vices use quasi professional launderers, who have a solid
business background, have no connection to previous “pre-
liminary” crimes, and conduct their laundering business in
exchange for a certain premium or commission (Presentation,
TR Ministry of Treasury and Finance Official Portal).
Further, they are very creative in creating complex and
difficult-to-follow methods. When their methods are revealed
M. Çemberci, D. Başar and Z. Yurtsever
in an audit, the launderers become quite proactive in devel-
oping new methods. The various money-laundering methods
are constantly evolving and are often intertwined, making it
almost impossible to fully categorize and describe them. In
addition, these methods vary from country to country and are
affected by country-specific conditions, such as the domestic
economy, the structure of financial markets, anti-money-
laundering policies, and international cooperation (Schott,
2006).
2.2. The concept of corporate governance
In recent years, the concept of corporate governance has
developed and gained popularity due to developments in
management science. Corporate governance, which is used in
the management of enterprises so as to achieve the highest
benefits for their shareholders and other stakeholders, is one of
the frequently discussed topics in the literature. When an en-
terprise is managed by its owner, a direct relationship between
the owner's personal interests and the power of ownership by
the managers becomes visible. Linked with this, economic
theories state that the value of the firm and its profit increase to
the highest level when the manager is also the owner of the
enterprise. However, when business owners do not have con-
trol, the personal interests of the owner and the interests of
managers with control can lead to ineffective use and misuse of
business resources. Examples of this include scandals in the
2000s at companies such as Enron and WorldCom. In these
cases, the management and audit shortcomings have caused
giant companies to close down overnight. These examples have
increased interest in corporate governance, revealing the
management shortcomings and audit deficiencies that occur at
companies. Within this framework, corporate governance is a
concept that covers all the practices and principles governing
the communication and relations between those who manage
enterprises and those who provide resources (Luo, 2005).
Considering the concept of corporate governance from a broad
perspective, the OECD defines it as a concept that consists of
the management of enterprises, members of the board, and
relations between stakeholders and shareholders (Göçen,
2010). The OECD (2004) definition states: “Corporate
Governance is the set of relationships between senior man-
agers, the board, shareholders and other partners of a company.
Corporate governance also refers to a structure in which the
company's goals, the tools necessary to achieve them and to
evaluate the efficiency in achieving these aims are defined.”
The main purpose of corporate governance is to contribute to
the creation of an environment of trust, transparency, and
accountability necessary to improve investment, financial sta-
bility, and the integrity of enterprises (Shleifer & Vishny,
1997). There is no single model of good corporate gover-
nance, but good corporate governance models have some
common elements. The principles also reveal these common
elements.
The OECD corporate governance principles are divided into
six parts. The first part includes the basic principles for an
effective corporate governance framework. In the second part,
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the basic principles of the rights and fair treatment of share-
holders and the basis of the function of the ownerships are
explained. In the third part, institutional investors, market
share, and principles about other intermediaries are pointed out.
Linked with this, in the fourth part, the role of stakeholders in
corporate governance is described. Further, the fifth part deals
with disclosure and transparency. Lastly, the sixth section ex-
plains the principles of the responsibilities of the boards
(OECD, 2016). The first part of this grouping highlights ap-
proaches to the basic framework of effective corporate gover-
nance. The requirements related to the need for healthy
incentives in the investment chain are specified the titles named
corporate investors, equity markets and others.
The conceptual definitions related to the other four groups in
the research model in connection with the corporate gover-
nance principles are as follows:
1. Shareholders' Rights, Fair Treatment, and Basic Owner-
ship Transactions: The corporate governance framework
should protect the rights of shareholders, ensure that
exercising them is easy and that all shareholders, including
minority and foreign shareholders, are treated fairly. All
shareholders should have the opportunity for effective
compensation if their rights are infringed. This principle,
which is expressed in the literature as the principle of
equality, refers to the fact that business managers are
equidistant from all parties inside and outside the organi-
zation. Fairness is, again, the act of having the same atti-
tude and behavior toward all parties (Koç, 2015).
2. Public Disclosure and Transparency: The corporate
governance framework should ensure timely and accurate
disclosure on all important issues related to the company,
including the company's financial position, performance,
partnership structure, and management. Although public
statements made by enterprises have different applications
in different countries, they must all be made within mini-
mum annual periods on the basis of three- or six-month
periods or after significant developments that affect the
enterprise. In addition, bearing in mind the necessity of
providing equal conditions to shareholders, simultaneous
reporting to all shareholders is essential (OECD, 2016).
3. The Principle of Responsibility: This refers to the trans-
actions and activities performed by business administra-
tions on behalf of a legal entity performed in accordance
with legal regulations and legislation, articles of associa-
tion, company policies, and social and ethical values of
society. It also refers to the auditability of these principles
(Pamukçu, 2011). The principle of responsibility includes
the creation and implementation of proper actions in
accordance with law and legal regulations, as well as de-
cisions and practices in accordance with the value system
of the society (Engin & Abdioğlu, 2009).
4. Accountability: The management approach and framework
created at the enterprise should enable effective audits to be
conducted. An effective audit of managers by the board
fulfills the boards' obligation to be accountable to stake-
holders (Sebilcioğlu et al., 2011).
M. Çemberci, D. Başar and Z. Yurtsever
3. Literature review
The board and senior management have important re-
sponsibilities for the effectiveness of the fight against money
laundering and the financing of terrorism. In the literature re-
view conducted on this subject, it was seen that there are
numerous studies focusing on the connection of responsibilities
of the board and senior management with corporate gover-
nance. In the study of A Rahman (2015), on the analysis that
focuses on the banks, it is stated that the board and senior
managers have to act according to these responsibilities and
could face criminal liability if they fail to do so. In addition, it
is also stated that the preventive actions for money laundering
can affect the productivity of corporate governance, which is
seen as a key aspect for the bank to function safely and steadily
(A Rahman, 2015).
Likewise, Bruemmer and Alper (2013) approach the issue of
fighting money laundering from a corporate governance
perspective by emphasizing the lack of precautions outside
corporate governance and focusing on the responsibilities of
the board. Bruemmer and Alper (2013) state that the re-
sponsibilities of the board in the fight against money laun-
dering have increased while emphasizing that regulators expect
their boards to be rigorous. They also express the importance of
the board for understanding the risks of money laundering and
their responsibilities in establishing appropriate systems within
the institution. Among the areas highlighted in the study is that
they might face regulatory penalties if the boards do not
comply with these requirements. Vaithilingam and Nair (2007)
focuses on the factors that affect money laundering in 88
developed and developing countries, finding that an effective
legal framework with good corporate governance is effective in
reducing its prevalence (Vaithilingam & Nair, 2007). Shehu
(2010) explains that good governance is an important part of
fighting money laundering, stating: “Structural elements, such
as transparency and good governance, must be in place to
adjudge a AML/CFT programme as effective.”
To continue, Uğurlu (2018) investigates the impact of
corporate governance and ethical principles on anti-money-
laundering policies and finds a positive relationship be-
tween accountability, fairness, and transparent corporate
governance principles and anti-money-laundering policies
with responsibility for prevention and at a sufficient scale.
Further, although a positive relationship is seen between the
principles on the responsibility for corporate governance and
sufficient prevention, a positive relationship with the re-
sponsibility for prevention variable is not observed. In
addition, Jayasuriya (2009) examines anti-money-laundering
activities in the context of good governance and corporate
governance. In this study, Jayasuriya describes the preven-
tion efforts in terms of two vertical control groups and states
the possible benefits that can be gained in structures sup-
ported by good corporate governance norms. However,
Jayasuriya also mentioned that money laundering and
financing of terrorism can never be completely eliminated. In
addition, Jayasuriya described the supporting elements of the
models of good governance.
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This review of literature about the concept of corporate
governance shows that the concept is heavily analyzed through
its effect on firm performance. Accordingly, a focus on all
aspects of corporate governance, especially firm-level corpo-
rate governance, and its effect on the system for preventing
money laundering, is not sufficient.
4. Methodology
4.1. The purpose, scope and method of the research
The goal of this paper is to examine the relationship be-
tween the conceptual model proposal that is constructed and
the actual perception of corporate governance principles,
regarding anti-money-laundering activity, drawn from a sur-
vey. Using the model, the aim of this research is to identify any
differences between financial institutions based on whether
they are included in the BIST CGI with respect to perception of
efforts to combat money laundering; to do so, a categorical
variable is added to the model. The data on these institutions
are categorized and analyzed separately.
In order to explore and examine the relationships in the
research model, it is prepared a survey with questions using
scales obtained from various academic studies. A five-point
Likert scale was used to respond to the questionnaire. These
scales and the intelligibility of the questions were pretested
with a small number of participants (35), and corrections were
made after pretesting, and then the questions were presented to
the target audience. The first part of the questionnaire collects
descriptive information about the respondents through ques-
tions about their age, gender, sectoral experience, status, and
occupation. In the second part, respondents were asked to react
to statements about the perception of anti-money-laundering
activity and anti-money-laundering policies at enterprises.
The terms used in this section were taken from Uğurlu (2018)
and Law No. 5549 on the “prevention of laundering proceeds
of crime” and “regulations on the compliance program for
prevention of laundering proceeds of crime and financing of
terrorism” with some minor changes. The suitability of the
questions was discussed in the pretest, and they were posed to
the target audience after a factor analysis was performed. In the
final part, questions were posed to measure the perceptions of
corporate governance principles, adapted from the study by
Engin and Abdioğlu (2009).
4.2. Research model and hypotheses
In this research, it is investigated that the effects on anti-
money-laundering activity of the independent variable,
corporate governance principles discussed in the model. At the
same time, an analysis was conducted using the categorical
variable “BIST CGI” in order to evaluate the difference in
perceptions between financial institutions regarding the
effectiveness of the fight against money laundering, based on
whether they are included in the BIST CGI. Based on this
analysis, then it is constructed several hypotheses for testing
(see Table 1) (Fig. 1).
M. Çemberci, D. Başar and Z. Yurtsever _
Borsa Istanbul Review 22-5 (2022) 1020–1032

Table 1 Table 2
Research hypotheses. Descriptive statistics.
H1: There is a significant relationship between fairness and equality with the Characteristics Detail Frequency %
perception of sufficient preventive action. Gender Female 205 58,6
H2: There is a significant relationship between transparency and the perception Male 145 41,4
of sufficient preventive action.
Total 350 100
H3: There is a significant relationship between accountability and the Age (Year) >25 5 1,4
perception of sufficient preventive action. 26–36 131 37,4
H4: There is a significant relationship between responsibility and the perception 37–45 139 39,7
of sufficient preventive action.
46–55 73 20,9
H5: There is a significant relationship between fairness and equality with the <56 2 0,6
perception of responsibility for prevention. Total 350 100
H6: There is a significant relationship between transparency and the perception
Status Personnel 166 47,5
of responsibility for prevention. Supervisor 151 43,1
H7: There is a significant relationship between accountability and the Senior manager 33 9,4
perception of responsibility for prevention. Total 350 100
H8: There is a significant relationship between responsibility and the perception
Department Sales and 94 26,9
of responsibility for prevention. marketing
H9: There are significant differences between the perception of financial Operation 84 24
institutions on money laundering in the context of financial institutions in the Support Services 13 3,7
BIST CGI, and financial institutions outside of the index.
(HR, Finance ect.)
H10: The difference in the level of education on the activity fighting money Audit, Internal 105 30
laundering has a significant impact on the perception of this activity in Control,
institutions that are included in the BIST CGI and financial institutions not Compliance
included in it.
Other 54 15,4
Total 350 100
Experience (year) 1–5 104 29,7
4.3. The method used in the analysis of data 6–10 84 24
11–15 80 22,9
SPSS, statistical package programs for social sciences were 16–20 43 12,3
used to evaluate the data obtained within the scope of the research 20+ 39 11,1
Total 350 100
model. Frequency distribution was used for the data obtained Categorization of The financial 105 30
within the scope of the demographic section. Descriptive sta- Corporate institutions
tistics, factor analysis, Bartlett's test, correlation analysis, reli- Governance included in the
ability, and Mann-Whitney analysis were used for the data Index BIST CGI
obtained from the second and third sections (see Table 2). The financial 245 70
institutions not
included in the
4.4. Basic statistical information on participants BIST CGI
Total 350 100
Among the participants, 58.6 percent were female, and 41.4
percent were male; 98 percent were 26–55 years old; 47.4
percent are lower-level managers/employees, 43.1 percent are
middle-level managers, and 9.4 percent are senior managers; The definition by Hammersley (1987) is as follows: “it is
26.9 percent are in sales and marketing, 24 percent are in valid if the measurement figures for a particular phenomenon
operational units, 30 percent are in audit, control, and accurately reflect the phenomenon, accurately describe it, or
compliance units, 3.7 percent are in support units, and 15.4 correctly give theoretical explanations.” Since the 1990s,
percent are in other (information processing, Treasury, etc.) broader definitions of the concept of validity have been
teams; 46.3 percent declared that they have worked at their generated, and “classical definitions of validity” and “modern
institutions for eleven years or more; 30 percent work at en- definitions of validity” have been used separately in the liter-
terprises in the BIST CGI. ature. Although the classical definitions of validity focus on the
content, criteria, and structural validity evidence, modern def-
4.5. Validity and reliability analysis of the variables used initions of validity highlight six other aspects: content, actu-
in the study ality, structure, generalizability, external factors, subsequent
outcomes. With this approach, which was put forward in the
Although the concept of validity has no single agreed-on research conducted by Messick, a unitary concept that gives
definition, three points stand out in the current definitions: importance not only to the results but also to how the test is
(1) whether the measurement tool specified in the research used, was brought forward (Şencan, 2005).
model corresponds to the particular characteristics of the phe- Confirmatory Factor Analysis (CFA) was used in this study,
nomenon to be measured, (2) whether the measurement was which made use of ready-made scales. In addition, before the
performed correctly, and (3) whether the measurement data Confirmatory Factor Analysis, the Exploratory Factor Analysis
from the research actually reflects the real data to be measured. (EFA) was also used. Although accepted scales were used for

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Borsa Istanbul Review 22-5 (2022) 1020–1032

Fig. 1. The research model.

research, it is necessary to look at the ways in which the
questions were perceived with Principal Component Analysis
(PCA) before creating a Confirmatory Factor Analysis (CFA)
model to see if the questionnaire was perceived correctly
(Civelek, 2018). In this context, statistical package programs
for social sciences were used for the analysis of the scales.
The suitability of each statement in the model for factor
analysis is measured by factor loadings (MSA). If the factor
loadings of the statements are less than 0.50, the statement is
excluded from the analysis (Durmuş et al., 2018). As seen in
Table 3, the factor loadings for the dimensions used in the
model declined, and the elements remaining with a factor
loading of 0.50 were extracted (those with reductions were
Fairness and Equality 2, Accountability 2, Responsibility 1,
3,6, Sufficient Prevention 8, 9, 10). In addition, the Kaiser-
Meyer-Olkin (KMO) values of the dimensions were >0.80
(Excellent).
Table 4 shows the Kaiser-Meyer-Olkin and Barlett test re-
sults in the context of Corporate Governance Principles and
Effectiveness of Anti-Money Laundering. In addition to the
interpretation of the KMO value, if the p-value provided by the
Bartlett globosity test is lower than the significance level of .05,
there is a proper and sufficient level of relationship for factor
analysis (Durmuş et al., 2013). Validity tests are used to
eliminate the hesitation about the scales used in the research
models to measure the phenomenon the research aims to focus
on. If the same conditions are met, meaning that if the same
value is reached repeatedly, reliability is ensured. These two
basic tests are conducted before the analysis of the research and
in the most basic sense, verifies the one-dimensionality aspect
of it. The variable in the measurement model is expected to
measure a single dimension. Since this verification is ensured
by the reliability and validity of the structure, two important
concepts emerge. The first of these is the convergent validity,
which refers to the high correlation between the statements
found under each factor. The other is the discriminant validity,
which shows a low correlation between the statements of
different factors of the research model. Confirmatory Factor

Table 3
The results of the explanatory factor analysis of the corporate governance principles and the Fighting against money laundering activity.
Corporate Governance Principles Anti-Money Laundering Activity
Factor Loadings Total Explained Variance % Factor Loadings Total Explained Variance %
Fairness and Equality Sufficient Prevention
Q1 0,834 53.215 Q1 0,585 58.189
Q3 0,818 Q2 0,712
Accountability Q3 0,757
Q1 0,828 64.258 Q4 0,841
Q3 0,864 Q5 0,796
Responsibility Q6 0,744
Q2 0,819 73.720 Q7 0,646
Q4 0,752 Responsibility for Prevention
Q5 0,793 Q1 0,644 71.586
Transparency Q2 0,621
Q1 0,838 81.149 Q3 0,758
Q2 0,811 Q4 0,778
Q3 0,757 Q5 0,708
Extraction Method: Principal Component Analysis.

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Borsa Istanbul Review 22-5 (2022) 1020–1032

Table 4 that the statement is loaded into the factor on which it is

Corporate governance principles, anti-money laundering activity and KMO- dependent (Fornell and Larcker, 1981). As shown in Table 5,
Bartlett's test results.
the critical ratio values of all statements in the model are above
Anti-Money Laundering Activity 2, which means that they are loaded into the factor on which
Kaiser-Meyer-Olkin 0,917
Sampling Adequacy Test
they are dependent. In addition, the significance level for all
Bartlett's Test Approximate Chi-Square 3244.833 statements is < 0.001.
df 66 Table 6 shows the goodness of fit values of Corporate
Sig. 0.000 Governance Principles and Anti-Money Laundering Activity
Corporate Governance models. When the value of the model is examined, CMI/DF
Principles
Kaiser-Meyer-Olkin 0,868
(The Likelihood Ratio Chi-Square Test/Degree of freedom)
Sampling Adequacy Test ratio being between 2 and 5, the comparative fit index (CFI),
Bartlett's Test Approximate Chi-Square 1981.675 tucker lewis index (TLI) and adjusted goodness of fit index
df 45 (GFI) values being above 0.90, the standardized root mean
Sig. 0.000 square residual SRMR value being below 0.08, and the root
mean square error of approximation (RMSEA) value being
Analysis is used to determine the validity of convergence/ 0.056, indicates to the suitability of the model.
divergence. The factor loadings evaluated by this analysis are Another indicator of the suitability of the convergent val-
expected to be at least 0.5 (Civelek, 2018). Confirmatory idity is the average variance values described in AVE (average
Factor Analysis (CFA) is used to determine the latent variable variance extracted). The AVE value is above 0.50, which
(factor) based on the variables determined through a previously makes it possible to verify the validity of convergence (Fornell
created model. In basic use, validation of a previously deter- & Larcker, 1981). The AVE values were calculated by taking
mined scale model is used for validity analysis as well as scale factor loadings of Table 6 into account, and for all factors the
development (Yaşlıoğlu, 2017). The results of the analysis are AVE value is above 0.50. Measurements are expected to be
presented in Table 5. made only in their related fields with questions about their own
Table 5 lists the standardized factor loadings and non-
standardized factor loading values for all entries under corpo- Table 6
rate governance principles and anti-money-laundering activity The goodness of fit values of corporate governance principles and anti-money
that were obtained through CFA. The standardized regression laundering activity model.
weights are above 0.50, which indicates the convergence val- CMIN DF CMIN/DF CFI TLI GFI RMSEA RMR
idity of the scale. As a result of CFA, the t-critical ratio value of 402.558 194 2.075 0,964 0953 0,910 0056 0,494
the statements is above the absolute value of 2, which indicates
Table 5
Results of confirmatory factor analysis of corporate governance principles and anti-
money laundering activity.
Statement The Path Factor β₀ β₁ Standard Error t-Value is the
Standard Factor Non-Standard Critical Ratio
Loadings Factor Loadings
Accountability 1 ← Accountability 0.851 1.105 0.07 15.785
Accountability 3 ← Accountability 0.831 1
Fairness and Equality 1 ← Fairness and Equality 0.884 0.931 0.046 20.201
Fairness and Equality 3 ← Fairness and Equality 0.828 1
Responsibility for Prevention1 ← Responsibility for Prevention 0.717 1
Responsibility for Prevention2 ← Responsibility for Prevention 0.677 1.041 0.069 15.118
Responsibility for Prevention3 ← Responsibility for Prevention 0.84 0.91 0.062 14.773
Responsibility for Prevention4 ← Responsibility for Prevention 0.818 0.774 0.054 14.409
Responsibility for Prevention5 ← Responsibility for Prevention 0.739 0.715 0.055 12.932
Responsibility 2 ← Responsibility 0.59 1.013 0.091 11.129
Responsibility 4 ← Responsibility 0.828 1
Responsibility 5 ← Responsibility 0.854 1.052 0.063 16.638
Sufficient Prevention 6 ← Sufficient Prevention 0.93 1.046 0.064 16.24
Sufficient Prevention1 ← Sufficient Prevention 0.676 0.845 0.065 13.055
Sufficient Prevention2 ← Sufficient Prevention 0.779 1
Sufficient Prevention3 ← Sufficient Prevention 0.695 0.862 0.051 16.978
Sufficient Prevention4 ← Sufficient Prevention 0.882 1.026 0.057 17.929
Sufficient Prevention5 ← Sufficient Prevention 0.876 0.984 0.055 17.746
Sufficient Prevention 7 ← Sufficient Prevention 0.757 0.745 0.05 14.978
Transparency 1 ← Transparency 0.801 1.328 0.088 15.149
Transparency 2 ← Transparency 0.838 1.352 0.086 15.742
Transparency 3 ← Transparency 0.784 1
For all values p < 0,001.

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M. Çemberci, D. Başar and Z. Yurtsever _
Borsa Istanbul Review 22-5 (2022) 1020–1032

extents in the research model. At this stage, it is important for
the scales and the statements given under them to have a
suitable structure (discriminant and convergent validity).
Average Variance/Average Variance Extracted (AVE) value is
used to assess the scales and the statements found under the
scales that only measure the dimension to which they are
relevant and do not affect different dimensions. This value is
expected to be 0.50 and above. In addition, validation is also
considered if the square root of the AVE and the value found in
that dimension is greater than the correlation coefficients of
other dimensions (Civelek, 2018). Calculated by dividing the
sum of the squares of the factor loadings of each statement
under the AVE (Average Variance Extracted) factors shared in
Table 7 by the number of statements. It is observed that the EV
value of each dimension is above the expected value of 0.50.
The convergent validity of the model is provided in this
context.
4.6. Reliability of the scale
Reliability of the scale analysis is first applied to each factor
separately, and then they are evaluated as a whole. In this
context, the Cronbach Alpha value is calculated separately for
each dimension and values above 0.7 indicate that the scale
reliability is at a sufficient level. Cronbach Alpha is based on
the correlation between statements and has a value between
0 and 1. Another value included in the reliability of the scale is
the combined reliability coefficient. This value, expressed in
English as CR (Composite Reliability), is obtained by the
calculation of the CFA factor loadings, and values of 0.70 and
higher, confirm that the combined reliability is achieved
(Yaşlıoğlu, 2017).
In Table 8, the alpha values of all factors are above 0.70,
which shows that the scale provides internal reliability. Like-
wise, the CR coefficients are above 0.70. Therefore, the
constructional reliability of the scale is validated.
4.7. Hypothesis testing and constructional model
analysis
Structural Equation Modeling (PLS SEM) was performed to
test the research hypotheses when the final point was reached
after reliability and validity tests were made on research
models.
The t-values give the statistical significance of the indicators
for each factor. If this value is greater than 1.96, the indicator is
considered significant for the factor (Çakir, 2019). Table 9 lists
the results of the path model, which shows whether the re-
lationships established in the research model are also supported
by the model. For H1, H3, H4, H5, H6, and H7, the t-statistics

Table 7
Average variance extracted (AVE) and explained construct reliability coefficients.
Variables AVE (Average Construct Variables AVE (Average Variance Construct
Variance Obtained) Reliability Obtained) Reliability
Fairness and Equality 0,734 0846 Sufficient Prevention
Q1 Q1 0,647 0927
Q3 Q2
Accountability Q3
Q1 0,707 0829 Q4
Q3 Q5
Responsibility 0,588 0807 Q6
Q2 Q7
Q4 Responsibility for Prevention
Q5 Q1 0,579 0872
Transparency 0,653 0849 Q2
Q1 Q3
Q2 Q4
Q3 Q5

Table 8
Consolidated correlation/reliability/validity statistics.
Variables Avr Std.Err. 1 2 3 4 5 6
1 Fairness and Equality 4.67 0,013 (0,857)
2 Accountability 4.03 0,210 0571** (0,841)
3 Responsibility 4.11 0,136 0467** 0,553** (0,767)
4 Transparency 4.33 0,400 0534** 0,450** 0,559** (0,808)
5 Sufficient Prevention 4.26 0,490 0561** 0,545** 0,405** 0,362** (0,804)
6 Responsibility for Prevention 4.71 0,190 0573** 0,410** 0,388** 0,425** 0,541** (0,761)
Cronbach's Coefficient Alpha Reliability 0,843 0836 0,772 0844 0,931 0870
Composite Reliability 0,846 0829 0,807 0849 0,927 0872
Average Variance Extracted (AVE) 0,734 0707 0,588 0653 0,647 0579
(): The square root of the AVE value.
**: p < 0,01.

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Borsa Istanbul Review 22-5 (2022) 1020–1032

Table 9
Path coefficients of hypothesis and evaluation results.
Relations Between Hypotheses Path Coefficient Std. Error T Statistics P Value Decision
H1: Fairness and Equality → Sufficient Prevention 0.477 0.065 7.306 0.000 Supported
H2: Transparency → Sufficient Prevention −0.040 0.044 0.896 0.371 ———
H3: Accountability → Sufficient Prevention 0.225 0.070 3.226 0.001 Supported
H4: Responsibility → Sufficient Prevention 0.130 0.060 2.157 0.031 Supported
H5: Fairness and Equality → Responsibility for Prevention 0.758 0.055 13.835 0.000 Supported
H6: The Principle of → Responsibility for Prevention 0.111 0.044 2.592 0.010 Supported
Transparency
H7: Accountability → Responsibility for Prevention −0.117 0.047 2.508 0.012 Supported
H8: Responsibility → Responsibility for Prevention 0.056 0.044 1.282 0.200 ———

of the path coefficient values are greater than the T value of
1.96 with a 95 percent reliability level. In addition, the p values
of the path coefficient values being less than .05 for the same
hypotheses shows that they are supported. H2 and H8 were not
supported because their T value is less than 1.96, and the p
values are higher than the significance value of 0.05.
In order to evaluate the differences between the financial
institutions that are or are not in the CGI in perceptions of the
effectiveness on the fight against money laundering, a cate-
gorical variable was added to the model and constructed H9.
This hypothesis is tested with the Mann-Whitney U Test in
SPSS, and the results are in Table 10. To compare the two
groups, the Mann-Whitney U Test was applied to the
nonparametric data of the t-test. This test converts the values of
the groups into sequential order and evaluates the differences in
this order. The fact that the p-value is less than 0.05 means that
the median values of the groups compared are not equal. In
addition, the average of the sequential values can be monitored
through the descriptive statistics provided by the test (mean
rank values in Table 10). These values are not the arithmetic
average, but new values that the sequence values gained after
their conversion from average group values to sequential order
(Durmuş, Yurtkoru, & Çinko, 2013). When the test results in
Table 9 are evaluated in this context, although there is no
positive difference, there is a significant divergence in the
perception of anti-money-laundering activity of the participants
working at financial institutions in the BIST CGI and partici-
pants working in an institution outside the BIST CGI. The
significance value of the test is less than 0.05, and H9 is
accepted.
The perception of anti-money-laundering activity is higher
among participants who work at enterprises that are not in the
BIST CGI, according to this research. In order to interpret this
statistical result better, it is also examined the dimensions of
corporate governance perceptions by financial institution par-
ticipants in the BIST CGI, and the test results are in Table 11.
According to Table 11, as a result of the Mann-Whitney U test
conducted for the dimension of the perception of corporate

Table 10
The results of the BIST CGI categorical variable assessment of anti-money laundering activity.
Dimension BIST CGI Category N Mean Rank Sum of Ranks Mann-Whitney U P
Anti-Money Laundering Yes 105 158.6 16,653 11088.000 0.039
Activity
No 245 182.74 44,772
350

Table 11
Perception of Corporate Governance Principles BIST CGI Categorical Variable Evaluation Results.
Dimension BIST CGI Category N Mean Rank Sum Of Ranks Mann-Whitney U P
Corporate Governance Yes 105 180.4714 18949.5 12340.500 0.545852
Principles
No 245 173.3694 42475.5
350

Table 12
Perception of the education level and BIST CGI categorical variable evaluation results.
Dimension BIST CGI Category N Mean Rank Sum Of Ranks Mann-Whitney U P
Sufficient_Prevention2 Yes 105 155.8143 16360.5 10795.500 0.011971
No 245 183.9367 45064.5
350

1028
M. Çemberci, D. Başar and Z. Yurtsever
governance principles, it is concluded that no statistically sig-
nificant difference exists between enterprises based on whether
they are in the BIST CGI (U = 12, 340; p > .05) (see Table 12).
The results of the Mann-Whitney U test (Table 11) reveal
statistically significant differences between enterprises that are
or are not in the BIST CGI (U = 10,795; p < .05), in terms of
the adequate level of education for the fight against financial
crime. The level of education is higher at enterprises that are
not included in the BIST CGI than those that are in it. Based on
this analysis, it is concluded that the level of educational
qualifications can have a positive effect on the perception of
effectiveness of anti-money-laundering activities.
5. Conclusions
In this study, the relationship between anti-money-
laundering activity and corporate governance principles is
investigated with several variables. The results regarding the
relationship between corporate governance principles, in terms
of the subdimensions of corporate governance principles, and
anti-money-laundering activity, reveals a positive relationship
between fairness, equality, accountability, and responsibility
with the perception of sufficiency, fairness, equality, trans-
parency, accountability, and responsibility for prevention. It is
not founded a significant relationship between transparency
and the perception of sufficient prevention and the principle of
responsibility and the principle of responsibility for prevention.
It is also examined the differences between the perceptions of
anti-money-laundering activity by enterprises that are and are
not in the BIST CGI and found significant differences. This
difference is positive for enterprises that are not in the BIST
CGI.
In addition, the differences in the education levels of the
employees, based on whether their firm was included in the
BIST CGI and their impact on their perceptions about the fight
against money laundering was analyzed. In this context, it is
concluded that the high level of education among business
employees has a significant effect on their perception of the
effectiveness of anti-money-laundering activity.
Uğurlu (2018) investigates the impact of corporate gover-
nance and ethical principles on anti-money laundering policies
in his study and explains that there is a positive relationship
between accountability, fairness, and transparent corporate
governance principles and anti-money laundering policies with
responsibility for prevention and scales of sufficient prevention
(Uğurlu, 2018). Further, while a positive relationship is seen
between principles of responsibility, under corporate gover-
nance principles, and sufficient prevention, a positive rela-
tionship with the responsibility for prevention variable is not
observed.
A Rahman (2015) in his study investigates the importance
of corporate governance for the prevention of money laun-
dering in the field of banking and reveals that corporate
governance involves the basic principles for enterprises to
function efficiently and safely, while it also supports the bank
boards' responsibilities towards stakeholders (A Rahman,
2015). Likewise, Bruemmer and Alper (2013) examines the
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Borsa Istanbul Review 22-5 (2022) 1020–1032
issue of fighting money laundering from a corporate gover-
nance point of view in their research and highlight the in-
adequacy of the precautions taken outside of corporate
governance and points out the responsibilities given to the
boards in this regard (Bruemmer & Alper, 2013). Related with
this Mohammadi emphasizes in the research called “Impact of
Board on Characteristics on Laundering” that there is a strong
relationship between CEOs or boards and the fight against anti
money laundering. It is also stated in this research that there is
an immense amount of different variables that needs to be kept
in mind that affect how institutions fight with such crimes
(Mohammadi et al., 2020).
In addition, Jayasuriya (2009) examines anti-money laun-
dering activities in the context of good governance and
corporate governance. In this study, Jayasuriya puts the pre-
vention efforts as two vertical control groups and states the
possible benefits that can be gained in structures supported by
good corporate governance norms (Jayasuriya, 2009). How-
ever, it is also mentioned that money laundering and financing
of terrorism can never be completely eliminated. In addition,
the supporting elements of the models of good governance are
also mentioned.
In this research, the relationship between corporate gover-
nance principles and anti-money laundering effectiveness' sub-
dimensions has been analyzed and, generally, a significant and
positive relationship has been found in these sub-dimensions.
In addition, the differences in the perception of anti-money
laundering activity of financial enterprises included in the
BIST CGI and financial enterprises other than the BIST CGI
were examined and a significant difference was found. It has
been observed that this difference is positive in the direction of
enterprises that are not included in the BIST CGI. However, it
has been concluded that the high level of education of the
employees has a significant effect on how they perceive the
anti-money laundering activity. This study shows that being
included in the BIST CGI is not the main determining factor
alone for the overall anti-money laundering activity. The re-
sults of this study reveal the need to investigate the factors that
ensure the effectiveness of the fight against money from a
broader perspective. It is believed that this study will form an
important basis for academic research that will be conducted in
this field in the future.
In this context, it is crucial for the anti-money laundering
policies and activity to be addressed on a global scale, for the
inter-country agreements to be implemented and for the policies
about the anti-money laundering activity that were shaped
within the national extent to be improved by each country
separately for, again, implementation. However, in order for the
fighting activity to be fully effective, these measures remain too
general. Regardless of the field of their activity and size, it is
extremely critical to form awareness and to educate the em-
ployees to protect the enterprises. Additionally, it was examined
that embracing the principles of corporate governance, when the
precautions that were to be taken within enterprises were being
analyzed, had a positive effect on the anti-money laundering
activity. Also, while the research made on corporate governance
was mainly on firm performance, there were additional
M. Çemberci, D. Başar and Z. Yurtsever _
Borsa Istanbul Review 22-5 (2022) 1020–1032

examples on audit and accounting as well (Engin & Abdioğlu,
2009). So, the adoption of effective anti-money-laundering
policies and practices at an enterprise, as well as an adequate
level of personnel training on the topic, is extremely important.
In his study, Usman Kemal (2014) investigates the relationship
and effects of customer record-keeping, employee training and
suspicious transaction notifications in the field of banking with
the fight against money laundering and concludes that efforts to
increase the capacity of employees that emphasize the impor-
tance of education on the topic would increase the effectiveness
of the activity of anti-money laundering (Usman Kemal, 2014).
Shelley (1998) focuses on the impact of defrauders that use
technology and their impact on the quality of life of other
people in a study and highlights the victimizations that may
occur in regions that do not have expertise in detecting crime
(Shelley, 1998). For this reason, the development of educational
programs at the international level and international business
associations are highlighted. This research reveals a significant
and positive relationship between corporate governance prin-
ciples and practices and the effectiveness of anti-money-
laundering activity in certain aspects. On this (Premti et al.,
2021), emphasizes that there is a link between corporate
governance and the effectiveness of the methods used to fight
money laundering. Likewise (Mathuva et al., 2020), also
highlights the fact that anti money laundering activity is con-
nected with good corporate governance principles. Lastly
(Pavone & Parisi, 2018), also mentions the relationship between
anti-money laundering and corporate governance principles.
Thus, future research on the parallel between corporate gover-
nance principles and anti-money laundering activity should
highlight the importance of corporate governance in the fight
against money laundering. From this perspective, advanced
practices in the field of corporate governance at institutions will
also make a significant contribution to increasing the effec-
tiveness of anti-money-laundering programs and managing
risks in this area more effectively.
Conflict of interests
There is no conflict of interest.
Appendix.
The Effects of Corporate Governance on Fighting Financial
Crime Survey Form.

Anti-Money Laundering Activity Strongly Disagree Disagree Neutral Agree Strongly Agree
1-I have received at least one training on fighting
financial crimes in the last year.
2-Regardless of the level and department in the
institution where I work, the level of education of all
personnel in the fight against financial crime is
sufficient.
3-All the staff at the institution where I work have
sufficient information about the financial crimes
investigation agency (MASAK).
4-The institution where I work has provided me with all
the information I need to fight financial crimes.
5-All the equipment I need to fight financial crimes is
provided.
6-The technical tools and equipment used by the
institution where I work to fight financial crimes are
sufficient.
7-The effect of fighting financial crime is taken into
account in all commercial activities carried out at the
institution where I work.
8-When I notice any suspicious transactions, the
notification channels that I will use are clearly
described in advance and the institution is informed.
9-There are regulatory compliance, education, internal
audit and risk management functions and systems
aimed at preventing financial crimes in our company.
10-There are one or more monitoring/audit committees
in Senior Management organizations to prevent the
risk of financial crimes.
11- The institution where I work constantly informs the
financial crimes investigation institution (MASAK)
about transactions exceeding the amounts determined
by the ministry.
12-The rules established by the ministry to prevent the
risk of financial crimes are applied as part of my daily
work.

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Borsa Istanbul Review 22-5 (2022) 1020–1032

(continued )
Anti-Money Laundering Activity Strongly Disagree Disagree Neutral Agree Strongly Agree
13-The principles of customer identification have been
clearly and clearly defined and applied in the
institution where I work.
14-All necessary books, records and documents in our
institution are stored and maintained in accordance
with the period established by the ministry.
15-Our institution does not refrain from providing all the
information and documents if the audit staff requests
it.
Corporate Governance Principles
16-General meetings are held regularly and duly in the
institution where I work.
17- Attention is paid to the protection of minority rights
and there are practices accordingly in the institution
where I work.
18-The right to receive and review information is
respected in the institution where I work.
19-Public statements are often made in the institution
where I work.
20-The institution where I work do not hesitate to
disclose any related parties to the public.
21-Information about my institution is presented
electronically.
22-The institution where I work has an effective human
resources policy.
23-There are company policies for stakeholders in the
institution where I work.
24-Social responsibility is important for the institution
where I work.
25-There is a management committee in the institution
where I work.
26-All the financial rights granted to the board of
directors are known in the institution where I work.
27-Board of directors meetings are held regularly in the
institution where I work.
28-The committees established within the board of
directors of the institution where I work are
independent.
29-In the institution where I work, the dominant partners
behave professionally.
30-The managers of the institution where I work behave
professionally.

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