Document Requirements and the Legal Opinion in an RJC Membership Application

An RJC membership application is a matter of documents. The Due Diligence Checklist, the official list published by the organisation, requires a declaration by a lawyer or a chartered accountant for five separate items. Notarisation, the common practice in Türkiye, is not the equivalent of this requirement; the two are different procedures.

The list is based on the organisation's customer due diligence (müşterini tanı) and anti-money laundering obligations under English law. The scope of the due diligence is broad: the applicant company, all parent companies up to the ultimate parent company, the ultimate beneficial owners, all group companies in scope, and all directors of those companies and their shareholders holding twenty per cent or more.

How Is the Organogram Prepared?

The organogram is the first and most detailed item on the list. It must contain: the names of all shareholders holding twenty per cent or more, up to the ultimate beneficial owner; the shareholding percentages of those shareholders; all companies in scope and any facilities; and the jurisdictions to which the companies are subject. In-scope companies, in-scope facilities and out-of-scope companies must be distinguished from one another, preferably by colour coding.

The distinction between a facility and a company matters. A facility is a separate unit that is not a separate legal entity but is located at a different address: a retail shop, a trading office, a production site or a warehouse falls within this scope. The concept of a shareholder covers not only a natural person but any company, natural person, foundation or trust holding twenty per cent or more in any company.

This is where the declaration requirement becomes concrete. The organogram is to bear a declaration by a lawyer, a solicitor or a chartered accountant, the declaration is to be dated within the last six months, and it is to carry a prescribed text: confirmation that it is a true and accurate representation of the organisational structure as it currently stands. The wording is not free; the list itself provides it.

Which Company Documents Are Required?

For each company in scope, a trade registry certificate (ticaret sicil belgesi) is required; the certificate must show the company's name, address and date of incorporation. Documents from European Economic Area countries and Switzerland are accepted in the original language. Non-English documents from other countries are submitted together with a translation bearing the declaration of a lawyer or a chartered accountant.

If a translation cannot be provided, there is an alternative: the original document is accepted with an annotation by a lawyer declaring in English that it is a trade registry certificate in accordance with local legislation. The practical consequence for Turkish companies is this: translation is not mandatory; the declaration is.

An official document showing the names and shareholding percentages of the shareholders is also required; however, if the trade registry certificate already contains this information, it is not required separately. A register of directors is also submitted for each company in scope; this document shows the current directors and the full legal name of the company, and again a lawyer's declaration is required.

What Is the Threshold for Identity Documents?

A passport or identity document is required for shareholders holding twenty per cent or more, all directors of the companies in scope, and ultimate beneficial owners holding twenty per cent or more. The document must have at least six months of validity remaining and must bear a lawyer's declaration. If a passport cannot be provided, an identity card or driving licence is accepted.

The threshold here is legally significant. The list does not require identity documents for shareholders below twenty per cent. Collecting identity documents from all shareholders would therefore be a personal data processing activity exceeding the standard's own requirement, and would conflict with the principle of being relevant, limited and proportionate to the purpose under Law No. 6698 on the Protection of Personal Data (6698 sayılı Kişisel Verilerin Korunması Kanunu). The threshold should be the basis when preparing the application file.

Are Notarisation and a Lawyer's Declaration the Same Thing?

No. A notary certifies a signature or that a copy conforms to the original; it does not declare that the content is accurate. What the list requires is a declaration about the content: confirmation that the structure is true and accurate, and that the document is a registry certificate in accordance with local legislation. The person giving the declaration is responsible for that content.

It should also not be overlooked that the two stages have separate requirements. In the membership application, a declaration by a lawyer or a chartered accountant is required for the organogram submitted to the organisation. In the audit application, by contrast, the structure organogram to be submitted to the audit firm is to be certified by a notary or an independent certified accountant. The same document is subject to two different procedures at the two stages.

How Is the AML Policy Submitted?

The applicant company's anti-money laundering policy is submitted on the company's letterhead or by means of the internet link where the policy is published. An alternative is also accepted: a declaration on letterhead, signed by a director or the owner of the company, stating that the company complies with the relevant requirements.

For Turkish companies, this item is not filled in from a blank page. Those who buy and sell precious metals, precious stones or jewellery, and those who act as intermediaries in these transactions, are already obliged parties (yükümlü) under Law No. 5549 on the Prevention of Laundering Proceeds of Crime and the Regulation on Measures (Tedbirler Yönetmeliği). The policy should therefore be prepared together with, and consistently with, the existing compliance (uyum) framework before the Financial Crimes Investigation Board (Mali Suçları Araştırma Kurulu, MASAK). Producing two separate texts comes back as a contradiction at audit.

File Arrangement and Determination of Scope

Formal requirements are also set out in the list. Each document is named in English and clearly; for each company a single compressed folder containing all of that company's documents is uploaded, and the folder is named after the company's legal name. Company names, director names, and the names and shareholding percentages of shareholders holding twenty per cent or more are highlighted in yellow.

Determining the scope of membership is a separate step. The organogram and a list of the companies and facilities under the parent company's control are sent to the organisation's applications team; the organisation advises which companies are in scope. Where necessary, national or regional licences relating to the export, import, trading or mining of precious stones or metals, and the company's published reports, may also be requested. The list expressly reserves the right to request additional information and documents during the review of the application.

What Should Be Done?

• Build the application file on the basis of the official checklist; do not treat the extended lists circulating in practice as the minimum requirement.
• Prepare the organogram by reference to the twenty per cent threshold; distinguish in-scope and out-of-scope companies by colour code and state the jurisdictions.
• Obtain the organogram declaration with the prescribed text and make sure the declaration is not dated more than six months earlier.
• For Turkish registry certificates, choose between a translation and a lawyer's annotation; in either case, ensure that the declaration is present.
• Do not collect identity documents from shareholders below twenty per cent; prevent unnecessary data processing through the way the file is structured.
• Structure the anti-money laundering policy as a single text with your existing MASAK compliance framework.
• Name documents in English, upload one folder per company and highlight the required fields to shorten the review time.
• Plan the declaration in the membership application and the certification requirement in the audit application separately; they are different procedures for the same document.

Warning. The information in this article is for general information purposes and does not constitute a legal opinion. Foreign exchange and precious metals legislation is a frequently changing area; the amounts, rates, thresholds, time limits and dates in this article may change in line with the legislation in force. Verify the latest version of the legislation before every application and transaction. Current texts are available at mevzuat.gov.tr.

Source: RJC Due Diligence Checklist 2026 (§ 01, § 02, § 03, § 04) · RJC Applications Guidance · RJC Member Certification Handbook v1.0, February 2025 (§ 4.1.6.1) · Law No. 6698 on the Protection of Personal Data · Law No. 5549 · Regulation on Measures regarding the Prevention of Laundering Proceeds of Crime and the Financing of Terrorism

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