Türkiye regulator imposes two-year TRHOL trading ban: who is covered?

Capital Markets Board bulletin 2026/66 announced criminal referrals and two-year trading bans tied to transactions in TRHOL shares. The decision is not a liquidation, operating shutdown or blanket freeze on investor accounts.

FinRateX ResearchSeptember 29, 2026 · 1:12 PM TRTTürkçe oku

Institutional case file and red access gate symbolizing a capital-markets investigation and closed trading access — The two-year trading ban is a regulatory restriction on market access. Original visual: FinRateX.

Trading ban2 yılexchanges and organized markets

Individuals37listed in the decision table

Institutions2Tera Investment and Tera Portfolio

Bulletin date28 EylCMB bulletin 2026/66

Three critical developments

The regulator decided to make criminal referrals concerning 37 individuals over transactions in the TRHOL share market.
Two-year trading bans cover the same people plus Tera Investment and Tera Portfolio; for the institutions, the restriction is limited to proprietary trading in TRHOL.
Licences held by specified individuals were also cancelled for the ban period; the bulletin does not automatically suspend every investor or delist TRHOL shares.

Decision matrix: which measure applies to whom?

The table separates the distinct measures and limits stated in the regulator's bulletin.

Decision	Scope	Duration	Boundary
Criminal referral	37 individuals	Decision, not a stated term	Not a final conviction
Trading ban	37 individuals	2 years	Exchanges and organized markets
Trading ban	Tera Investment and Tera Portfolio	2 years	Proprietary TRHOL trading only
Licence cancellation	Specified licence holders	For the ban period	Cannot be generalized to all employees

The matrix summarizes the bulletin. Legal consequences should be read person by person and institution by institution in the official text; this is not a price target or investment recommendation.

What did the regulator decide?

Bulletin 2026/66 says the Capital Markets Board decided to make criminal referrals concerning 37 individuals over transactions in the TRHOL share market. It also imposed two-year trading bans on those individuals, Tera Investment Securities and Tera Portfolio Management.

What is the boundary for the two institutions?

The bulletin limits the institutional measure to transactions made in their own name and for their own account, and specifically to the TRHOL share market. It does not say all operations of the two institutions have stopped, customer accounts have closed or every licence has been cancelled.

How is the count of 37 derived?

The criminal-referral and trading-ban tables list 37 individuals. A separate section cancels all licences held by a subset of those people for the ban period. Because that licence table does not cover all 37 in the same way, we do not merge the two groups.

What does this mean for a TRHOL investor?

The decision raises the regulatory and legal-risk profile around the share, but it does not delist TRHOL, halt the company's operations or predetermine a price move. Investors should monitor new regulator bulletins, company filings and Borsa Istanbul session notices as separate evidence streams.

How can portfolio sensitivity be read?

If TRHOL is 5% of a portfolio, a 10% move in the share changes the total portfolio by about 0.5%, all else equal. At a 20% weight, the same move changes it by about 2%. This is a mechanical sensitivity, not a directional forecast; tax, commission, spread and liquidity are excluded.

Method and limitations

This report relies on the September 28 regulator bulletin and the issuer identity page on Türkiye's disclosure platform. We draw no conclusion of guilt; the presumption of innocence applies. The names are counted from the official table and are not unnecessarily republished. A later regulator, court or company notice may change the scope.

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