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, 2018
       Filed September 26, 2019
       Amended November 14, 2019 and February 13, 2020
       File No. 033-37817

Dear Mr. Saylan:

       We have reviewed your filings 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 26, 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
your steady
       decrease in reserves.

 Exhibit D

 Description of the Republic

 4.    Please include discussion 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 amount
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 26, 2020
Page 3



 The European Union and the United Kingdom

 8.    Please include a discussion of any material effects on Turkey related to
the United
       Kingdom's decision to leave the European Union (EU) or the EU's economic
       stability. Also, include a discussion of any material effects if certain
events were to
       occur, such as further 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 adequate
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.

                                                           Sincerely,

                                                           /s/ Michael Coco

                                                           Division of
Corporation Finance
                                                           Office of
International Corporate
                                                           Finance

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