TRY 122 Million, Five Years, and the Warning Signs That Went Unnoticed 

According to recent media reports, an accounting manager at a company in Istanbul is alleged to have transferred TRY 122 million (approximately USD 4.6 million) from company accounts to his own accounts and those of other individuals between 2021 and 2026. 

Viewed through the lens of a fraud investigator, the case raises a number of important questions.   

Let us examine the case through these questions. 

What Does Five Years Tell Us? Could There Have Been Control Weaknesses?  

Perhaps the most important lesson from this case is not the size of the alleged fraud, but how long it appears to have continued without detection. 

The ACFE’s Occupational Fraud 2026: A Report to the Nations shows that financial losses increase significantly the longer fraud remains undetected. Therefore, the objective of an effective anti-fraud framework is not only to prevent fraud, but also to detect it as early as possible once it begins.  

The ACFE study also found that more than half of occupational fraud cases occurred due to a lack of internal controls or the override of existing controls. This highlights the importance of organizations having not only preventive controls, but also detective controls capable of identifying unusual transactions and behaviors at an early stage.

Based on the information currently available, it is not possible to determine which controls, if any, failed in this particular case.

However, in a fraud investigation involving allegations of this nature, areas such as payment and approval authorities, segregation of duties, bank reconciliations, management oversight, and controls for monitoring unusual transactions would typically warrant detailed examination.

Why Do Accounting and Finance Require Particular Attention?  

The fact that an accounting manager is at the center of the allegations should not be interpreted as meaning that accounting employees are inherently more likely to commit fraud. The key issues are access and opportunity. 

Accounting and finance functions naturally operate close to an organization’s cash flows, bank accounts, accounting records, payment processes, and related controls. This makes effective segregation of duties and independent control mechanisms particularly important in these functions. 

The ACFE’s 2026 data supports this perspective. In 13% of the cases, the primary perpetrator worked in accounting, making accounting—together with operations—the department with the highest frequency of cases. Fraud cases involving accounting personnel resulted in a median loss of USD 164,000. Finance accounted for only 6% of cases, but the median loss was USD 200,000.  

Fraud Leaves Traces Not Only in Transactions, but Also in Behavior  

Another noteworthy aspect of the case is the presence of potential behavioral red flags. According to media reports, the suspect allegedly spent approximately TRY 60 million in casinos, purchased a house and a car, transferred significant amounts to people close to him, and incurred substantial personal expenses. Reports also indicate that he was going through a divorce and had transferred certain assets to relatives.

The ACFE’s findings are particularly relevant in this context. In its 2026 study, 84% of fraud perpetrators displayed at least one behavioral red flag. The most common was living beyond one’s means (39%), followed by financial difficulties (29%). Divorce or family problems are also among the eight most common behavioral red flags tracked by the ACFE. Addiction-related issues, including gambling-related behavior where relevant, may also constitute behavioral warning signs.  

Importantly, none of these behaviors, on their own, constitute evidence of fraud. Their significance arises when they are considered together with transactional anomalies, access to assets, control weaknesses, or other risk indicators. 

Why Can Collusion Undermine Controls? 

Another striking feature of the case is that the alleged misconduct does not appear to have been limited to a single individual. 

From an investigative perspective, this is important because when two or more individuals act together, they may be able to circumvent controls, including segregation of duties. According to the ACFE 2026 study, 49% of cases involved two or more perpetrators acting in collusion, and median losses increased significantly as the number of perpetrators grew.  

What Can Companies Learn from This Case?  

While the criminal investigation remains ongoing, it would not be appropriate to draw definitive conclusions from publicly available information about which controls may have failed at the company. 

The case does, however, provide an opportunity for organizations to ask themselves some difficult questions: 

• If an employee attempted today to transfer company funds to their own account or to an account connected to them, how quickly would we detect it? 
• Do we have genuine segregation of duties within our accounting and finance processes, or can the same individuals effectively control multiple stages of a transaction? 
• Do we independently reconcile and verify bank payments against accounting records? 
• Do we analyze potential connections between bank accounts belonging to employees, vendors, and other third parties? 
• Do we treat behavioral red flags not as grounds for accusation, but as early-warning signals to be considered alongside other indicators? 
• Do our fraud risk management processes consider scenarios in which two or more individuals could collude to circumvent existing controls? 

Our experience at Cerebra in conducting fraud investigations in Türkiye shows that actual cases provide valuable lessons not only for understanding what happened in the past, but also for identifying how similar incidents can be detected earlier in the future.  

Fraudsters leave traces—in transactions, systems, relationships, and sometimes in their behavior. An effective anti-fraud framework should be designed to assess these traces not as isolated signals, but collectively. 

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