ODINE “Major Heist” Allegation: 21 People Referred to Prosecutors, Billion-Lira Transactions and Unanswered Questions

The record

Odine Solutions Teknoloji went public in March 2024 at 30 Turkish lira per share. In August 2026, the price reached 3,512.50 lira — 117 times the flotation price. By the afternoon of 9 October, it was trading at its daily lower limit of 95.60 lira. Since the peak, the company’s calculated market capitalisation had fallen from approximately 388 billion to 10.6 billion lira.

Amid this rise and collapse, Türkiye’s Capital Markets Board (SPK) decided on 7 October to refer 21 people to prosecutors over alleged market manipulation. Yet the file’s most basic question remains unanswered: who holds ODINE?

Read together, the current KAP ownership table, the company’s 2024 and 2025 annual reports and share disclosures reveal three layers. First are two founders whose privileged shares give them a majority of the votes. Second is a 19% block transferred outside the exchange. Third are a handful of investors holding a large proportion of the exchange-traded shares.

The current picture

Source: KAP ownership table, October 2026. Issued capital: 110.5 million Turkish lira.

Seven shareholders hold 82.71% of the capital. Concentration is even greater in exchange-traded shares. According to the 2025 annual report, 47.5 million shares were exchange-traded, representing 43% of capital. If that number is unchanged, the PCS fund, Cengiz Avcı, Hasan Kaytan and Feridun Geçgel together hold approximately 60% of the exchange-traded shares.

Of the names in the table, only Cengiz Avcı appears in the SPK’s 7 October criminal-referral list. Two other names on that list stand out: Muhammed Yarız, identified in KAP records as chairman of Pusula Portföy, which manages PCS, and Halil İbrahim Ege, identified as deputy chairman.

37.64% of capital, 62.70% of votes: who actually controls the company?

At ODINE, capital ownership and corporate control are not the same. Only 16.8% of the 110.5 million lira capital — 18,564,000 shares — belongs to class A. These shares are not traded on the exchange. Each carries five votes at general meetings and gives its holders privileges in nominating board members. Class B shares have no privileges. Thus class A alone carries more than half the votes, 50.24%, despite accounting for roughly one-sixth of capital.

KAP voting percentages show that all class A shares are held by the two founders, Alper Burak and Fırat Kerim Ersoy. Together, their 37.64% capital stake controls 62.70% of votes. Burak’s 33% stake carries 52.62% of votes, giving him a majority at general meetings on his own. Ersoy’s 4.64% capital stake corresponds to 10.08% of voting power. By contrast, Geylan Zapsu, the second-largest shareholder with 19.15%, has only 11.45% of votes. The PCS fund and Avcı each have less than 6% of votes.

The founder’s holding has declined over time. Annual reports show Burak’s stake falling from 36%, or 39,780,000 shares, at the end of 2024 to 33%, or 36,466,000 shares, at the end of 2025. The difference of 3,314,000 shares exactly matches the increase in exchange-traded shares over the same period. On 16 April 2026, Burak applied to the SPK to sell a further four million shares on the exchange. On 19 June he withdrew the application, citing regulatory time restrictions. Burak is not named on the SPK list.

The Zapsu connection: from 19.36% to 19.15%

One of the most conspicuous clusters in the ownership structure centres on the Zapsu surname. The story begins with the flotation. According to the SPK’s approval, 18,384,129 shares belonging to Hidayet Didem Zapsu Bilyay and her two children were offered at 30 lira each. Gross proceeds amounted to approximately 551.52 million lira.

The family retained a substantial block. The 2024 annual report lists Hidayet Didem Zapsu Bilyay’s stake at 4.84%, and those of Deniz Han Bilyay and Doğu Kaan Bilyay at 7.26% each. Together they held 21,395,871 shares, or 19.36% of capital.

2025: Hidayet Didem Zapsu Bilyay (4.84%) + Deniz Han Bilyay (7.26%) + Doğu Kaan Bilyay (7.26%) = 19.36%.

Off-exchange transfer at 138.20 lira per share.

Today: Geylan Abdülaziz Zapsu is ODINE’s second-largest shareholder, with 19.15%.

According to Hidayet Didem Zapsu Bilyay’s KAP disclosure, the transfer occurred on 15 September 2025 at 138.20 lira per share. The disclosed consideration totals approximately 2.957 billion lira. Including the flotation sale, gross proceeds from the two stages reach approximately 3.51 billion lira. This is only the sum of sale proceeds: it does not represent net profit, investor losses or established unlawful gains.

Two discrepancies in the documents require explanation. The first concerns the date: the individual transaction disclosure says 15 September, while the company’s 2025 annual report gives 5 September for the same transfer. The second concerns share numbers: the transferred block comprised 21,395,871 shares, but the 2025 annual report records Geylan Zapsu’s holding as 21,161,885. Public documents do not identify who holds the remaining 233,986 shares. These discrepancies alone do not prove wrongdoing, but they are details the company should explain.

The Zapsu surname also appeared on the board. Kerim Pertev Zapsu is listed as a director in the 2024 and 2025 annual reports. He resigned voluntarily by letter dated 8 May 2026. The company’s deputy general manager for finance, Ali Yöney, was appointed in his place, subject to general-meeting approval. Public documents do not establish whether Kerim Pertev Zapsu is related to Geylan Zapsu or the Bilyay family.

Geylan Abdülaziz Zapsu’s brother, Hasan Cuneyd Zapsu, is chairman of Balsu Gıda. The relationship is also stated on Cuneyd Zapsu’s own website. Pusula’s investments connect the two companies at this point. The funds held 19.24% of BALSU on the morning of 10 August 2026. That day they bought 153.6 million shares and sold approximately 249 million, reducing their holding to 10.66%. After transactions on 17 August, it fell to 1.84%. In comments reported on 20 September, Cuneyd Zapsu attributed Balsu’s share-price decline to fund movements and selling outside the company’s control.

Family relationships, or the same fund manager investing in two companies, are not evidence of a joint criminal organisation. The three Bilyay family members, Geylan Abdülaziz Zapsu, Hasan Cuneyd Zapsu and Kerim Pertev Zapsu are not on the SPK’s ODINE criminal-referral list.

Cengiz Avcı: nearly half the publicly traded shares in one holding

Cengiz Avcı’s ODINE stake grew rapidly a few months after the flotation. KAP disclosures show that between 24 October and 27 November 2024 he bought 2,776,000 shares at prices between 78 and 117.40 lira, taking his stake to 17.26%. On 17 January 2025, his holding reached 21.4 million shares, or 19.37% of capital. That represented approximately 48% of the exchange-traded shares at the time. Avcı was then the company’s largest individual shareholder after founder Burak.

The 2025 annual report lists Avcı’s stake at 18.50%, equivalent to approximately 43% of the exchange-traded shares reported in the same document. The current KAP table puts his stake at 8.54%. That decline of about ten percentage points corresponds to roughly 11 million shares.

The question is clear: when were those approximately 11 million ODINE shares transferred, at what prices, and to whom? The public documents we could access do not show this. During that period, the stock traded across a broad range from below 100 lira to above 3,500 lira. Without transaction dates and prices, the proceeds cannot be calculated.

Avcı is one of the 21 people referred to prosecutors and banned from trading for two years by the SPK’s 7 October decision. Diken reported on 29 September that he had made approximately 15 billion lira from ODINE shares in one year, cashed out 12 billion, and was the subject of an arrest warrant. We could not obtain the transaction records underlying those figures. The SPK bulletin also provides no individual profit or investor-loss figures. The 15 billion lira must therefore be read as a news allegation attributable to its source. The available documents do not establish whether it is connected with the reduction in Avcı’s holding. The SPK decision is not a conviction; Avcı retains the presumption of innocence.

Pusula: from investor to major shareholder

Pusula Portföy’s PCS fund now holds 9.93% of ODINE’s capital, making it the third-largest shareholder in the table. The funds’ holding increased rapidly. KAP disclosures show that on 8 April 2026 Pusula funds bought one million shares at 896–900 lira, raising their combined stake from 4.36% to 5.27%. On 18 May, they bought 5,252,229 shares and sold 292,277 in a single day, at prices of 1,206–1,262 lira. Their combined holding reached 10.47% by the close. In the current table, only PCS appears as a separate fund entry.

There is a vast gap between those purchase prices and today’s 95.60 lira share price. If the position remains the same size, fund investors bear that loss in value. The current size of the position and losses borne by investors are among the first questions Pusula should answer.

The fund manager’s leadership also appears in the file. According to KAP’s information form dated 21 September 2026, Muhammed Yarız is Pusula Portföy’s chairman and Halil İbrahim Ege its deputy chairman. Both were elected on 24 October 2025; both appear on the SPK’s 7 October criminal-referral list. The bulletin does not, however, mention Pusula Portföy itself.

PCS and Avcı together hold 18.47%. But the documents in our possession contain no information showing that they acted together, and this article makes no such allegation. The question is how a major shareholder on the SPK list and a fund whose manager’s chairman and deputy chairman are on the same list built positions of this size in the same stock, and what investment decisions underpinned them.

The SPK file

The board’s 7 October bulletin records a decision to refer 21 people to prosecutors under Article 107/1 of the Capital Markets Law over transactions in ODINE shares. The same people received two-year trading bans. All capital-markets licences held by 16 of them were also revoked for the duration of the ban: most of those listed were licensed professionals. The decision concerns alleged market manipulation, not a final conviction. The bulletin does not disclose the period examined, transaction volumes or gains.

Questions awaiting answers

Clarifying this file requires looking beyond purchase and sale disclosures. On what dates, at what prices and to whom did Avcı’s approximately 11 million shares pass? Who holds the 233,986-share discrepancy in the Zapsu block, and which transfer date is correct? What transactions reduced founder Burak’s holding by 3.3 million shares in 2025? Which accounts were counterparties to Pusula’s purchases, and what is the funds’ position today? How was the alleged 15 billion lira gain calculated?

Answers require examining order and transaction records alongside bank movements. The public needs to know more than the scale of the alleged gains. The transactions that produced them, and who was left bearing losses in a stock that fell 97% from its peak, must also be explained.

Timeline

March 2024: Flotation at 30 lira per share; total 1.326 billion lira.

27 November 2024: Cengiz Avcı’s holding reaches 17.26%.

17 January 2025: Avcı holds 19.37%, approximately 48% of exchange-traded shares.

15 September 2025: The 19.36% Bilyay block passes to Geylan Zapsu outside the exchange; the annual report gives 5 September.

2025 annual report: Burak’s holding falls from 36% to 33%; Avcı holds 18.50%.

8 April 2026: Pusula funds reach 5.27%.

16 April 2026: Burak applies to sell four million shares.

8 May 2026: Kerim Pertev Zapsu leaves the board.

18 May 2026: Pusula funds reach 10.47%.

19 June 2026: Burak withdraws his sale application.

30 July–28 August 2026: Short-selling and margin-trading ban on the shares.

August 2026: The stock peaks at 3,512.50 lira.

10–17 August 2026: Pusula funds’ BALSU stake falls from 19.24% to 1.84%.

29 September 2026: Diken reports an arrest warrant for Avcı; the share price is 221.60 lira.

7 October 2026: SPK decides to refer 21 people to prosecutors.

9 October 2026: The stock trades at its daily lower limit of 95.60 lira.

This timeline records the sequence of events only; it does not establish a connection between them.

Based on reporting from: SPK Bulletin 2026/69, 7 October 2026; KAP: ODINE — ownership and voting rights; KAP: ODINE — disclosures; KAP: ODINE — annual report; CNBC-e: SPK decision on ODINE, October 2026.