Currently in Turkey, almost all of the requirements for applying for the AEO status can be

satisfied by large and export/import intensive companies. Large companies that recognize the

necessity of AEO status have been awarded this certificate. However, small and medium-sized

firms have to invest heavily in order to satisfy the requirements and to make a structural

transformation in their modus operandi.

The benefits of granting the AEO status to the SMEs are twofold: (i) By meeting the

requirements of the AEO application, SMEs would experience a transformation in their

institutional structure, which certainly has ripple effects for the entire economy as these firms

make up almost 97 percent of all firms in Turkey. (ii) It is also valuable for large firms that

SMEs obtain the AEO status. Many large firms interact with SMEs in their supply chain. Having

AEO certification without business partners holding the same status would not bring the

anticipated benefits at the most desired levels.

At this point, it is necessary to note that, for the last decade, there have been extensive

amounts of subsidies given to boost the performance of SMEs in Turkey. However, Dincer and

Tekin-Koru (2018) show that the productivity of SMEs has been much lower than the large

firms without showing any improvements in spite of the subsidies. In other words, small and

medium size firms could not increase their productivity leading to the sustained gap with large

firms.

In conclusion, it is difficult for SMEs in Turkey to hold the AEO certification due to limited

benefits they would utilize and high costs they should undertake. However, it is important that

these firms should be included in a sub-program, as in the Jordanian Silver List, to increase

their capacity in terms of institutional standards with the purpose of satisfying compliance and

security requirements of the AEO program in a stepwise manner.

4.2.3.6. Training and Capacity Building

In order to process the AEO program, the Ministry set up new units in its Regional

Directorates. Moreover, training is provided to the staff of Regional Directorates by

Headquarters of the Ministry whenever there is an amendment in the legislation.

The Ministry of Trade employs the designated auditors of the AEO program, who were trained

for two weeks by the experts from Netherlands and France regarding the on-site inspection,

from the same group of auditors during the implementation. The aim is to develop

specialization of the auditors on AEO and deepen their information. However, specialized

auditor implementation is not supported by the legislation at the moment.

The Ministry has not designed any joint training activities with private sector at the moment.

However, they provide training to the private sector when requested.

4.2.4. Evaluation of the AEO Program

4.2.4.1. Audit of AEOs

AEO holders are required every year to "update the self-assessment questionnaire" and

"prepare the annual activity report".

The Ministry regularly monitors the validity of the conditions of the authorized operator

certificate and whether the conditions for granting the authorization and permissions of the