NEWSLETTER-2020-metin

166 NEWSLETTER 2020 dertakings, in the performance of its duties that is given by Law on Protection of Competition numbered 4054 (“Law No. 4054”). For the same reason, the Board may request written or oral explanations from undertakings or associations of undertakings on certain topics during on-site inspections. Otherwise, an administrative fine will be imposed in line with Article 16 paragraph (c) of Law No. 4054. The Requested Information and Documents and the Responses of the Undertakings to the Requests This Decision is based on the fact that some undertakings did not provide some information and documents within the scope of the preliminary investigation initiated by the Board. Such preliminary in- vestigation was initiated to determine whether or not the banks, finan- cial institutions, and their representatives that are operating in Turkey are violating Law No. 4054 in their operations related to deposits, credit, foreign currencies, bills, bonds, stocks and brokerage services. Within the scope of the preliminary investigation, on-site inspections were carried out at several banks and financial institutions, includ- ing Citibank A.Ş. (“Citibank”), Goldman Sachs TK Danışmanlık A.Ş. (“Goldman Sachs”), ING Bank A.Ş. (“ING ” ), JPMorgan Chase Bank, National Association Merkezi Colombus Ohio Istanbul Turkey Branch (“JPMorgan”), and Türkiye Garanti Bankası A.Ş. (“Garanti”). Following these inspections, two information requests were sent to such undertakings. The first information request was to submit recordings of all the correspondence made by the traders of the undertakings on the Bloom- berg and Reuters platforms within a certain period of time. The second information request was on the submission of the correspondence of the top 10 traders with the highest Turkish Lira (“TRY”) quoted trans- action volume amongst the traders of the undertakings and their parent companies, who are employed in the USA and England, and trading in TRY on Bloomberg and Reuters platforms, within a certain period of time. JPMorgan, Citibank, Garanti and ING did not provide the relevant documents requested by the Competition Authority (“Authority”) by claiming certain reasons. Firstly, Goldman Sachs stated that it does