SecProbe.io

March  26, 2020

Via E -mail

Onur Saylan
Treasury and Financial Counselor
Turkish Embassy
Office of the Counselor for Treasury and Financial Affairs
2525 Massachusetts Avenue, N.W.
Washington, D.C.  20008

Re:  Republic of Turkey
Registration Statement under Schedule B
Filed  February 27, 2020
File No. 333-236683

Form 18 -K for Fiscal Year Ended December 31, 201 8
Filed September 26, 2019
Amended November 14, 2019 and February 13, 2020
File No. 033-37817

Dear  Mr. Saylan :

We have reviewed your filing s and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter by  amending your documents and providing the requested
information.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment  to your registration statement and the information you
provide in response to these comments, we may have additional comments.

General
1. To the extent  possible,  please  update  all statistics  and information  to provide  the most
recent  data.   Additionally, to the extent practicable, please include substantive
explanatory discussions for material statistical variances in your economic data.  We
note, for example, the significant changes from 2018 to 2019 in your economic data
in your Form  18-K.

Onur Saylan
March 2 6, 2020
Page 2

 2. Please update your disclosure or include a recent developments section, as
necessary, to discuss the material economic, political and other effects of the
coronavirus pandemic  or the Republic’s response to it .

Form 18 -K

General

3. We note reports of the recent increase in relative debt affecting your credit rating.
Please include a discussion of any material risks related to any increase in debt that
you may incur.   We note also that you should discuss any material risks related to the
steady depreciation of the Lira, your taxing and credit strategies, and y our steady
decrease in reserves.

Exhibit D

Description of the Republic

4. Please include discus sion of any material risks  relate to recent earthquakes  in eastern
Turkey .

International Lending

5. Please revise the chart on page 79 to include the interest rates and maturity dates for
each  loan.

Banking System

6. Please revise your disclosure  on page 106 to include the total amou nt owed by each
shareholder .

Amendment No. 2 to Form 18 -K

Exhibit D -2

Foreign Policy and International Relations

7. Please update this section throughout to include any material recent  developments in
relations with Russia, Syria, the United States,  or related matters .

Onur Saylan
March 2 6, 2020
Page 3

 The European Union and the U nited Kingdom

8. Please include a discussion of any material effects  on Turkey related to the United
Kingdom’s decision to leave the European U nion (EU) or the EU’s economic
stability.   Also, include a discussion of any material effects  if certain events were to
occur, such as f urther bailouts of EU countries or  another credit crisis .

9. Please revise your discussion to include any material findings of the  European
Commission’ s 2019 report on Turkey .

Closing Comment

We remind you that you are responsible for the accuracy and adequacy of the disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequa te
time for us to review any amendment prior to the requested effective date of the registration
statement.

Please contact  Corey Jennings, Special Counsel,  at (202) 551 -3258 or Michael Coco,
Chief,  at (202) 551 -3253 with any questions.

        Since rely,

        /s/ Michael Coco

        Division of Corporation Finance
Office of International Corporate
Finance

cc: Christopher Peterson , Esq.
Arnold & Porter Kaye Scholer LLP