Türkiye has established a comprehensive AML regulatory framework for cryptocurrency and digital asset service providers, with the legal foundation set by the Law on the Regulation of Crypto-Assets, published in the Official Gazette on July 2, 2024, which requires all crypto-asset service providers to obtain a license from the Capital Markets Board (CMB) and comply with AML obligations under the Financial Crimes Investigation Board (MASAK) supervision. Turkey (Türkiye) - United States Department of State

The primary regulator for AML compliance is MASAK, operating under the Ministry of Treasury and Finance, while the CMB, as the capital markets regulator, oversees licensing and operational requirements for crypto-asset service providers, with the Central Bank of the Republic of Türkiye also playing a role in payment-related matters. Turkey (Türkiye) - United States Department of State

Licensing is mandatory for crypto-asset service providers (platforms, custodians, and intermediaries), and while the regulatory framework has been established and the first applications were received throughout 2024–2025, as of the latest available information, only a limited number of entities have been granted full licenses, with the CMB continuing to process pending applications and many platforms operating under provisional approval status during the transition period. Turkey (Türkiye) - United States Department of State

The practical reality is that the regulatory regime is evolving rapidly as Türkiye aligns with FATF standards, having been placed on the FATF grey list in 2021 and subsequently removed in 2024 after demonstrating progress, and the full enforcement of the new crypto-asset law is a critical component of maintaining that improved standing. Turkey (Türkiye) - United States Department of State

Financial Crimes Investigation Board (MASAK) — the primary AML/CFT regulator and financial intelligence unit (FIU) of Türkiye, operating under the Ministry of Treasury and Finance, responsible for receiving and analyzing suspicious transaction reports, setting AML compliance standards, conducting AML inspections of crypto-asset service providers, and imposing administrative fines for AML violations. Turkey (Türkiye) - United States Department of State

Capital Markets Board of Türkiye (CMB/Sermaye Piyasası Kurulu — SPK) — the capital markets regulator designated as the licensing authority for crypto-asset service providers under the Crypto-Asset Law, responsible for issuing operating licenses, overseeing platform operations, establishing capital requirements, and coordinating with MASAK on AML supervision. Turkey (Türkiye) - United States Department of State

Central Bank of the Republic of Türkiye (CBRT/TCMB) — the central bank that issued the Regulation on the Disuse of Crypto-Assets in Payments (published in Official Gazette No. 31009 on April 16, 2021), prohibiting the direct or indirect use of crypto-assets for payments and the development of payment infrastructure based on crypto-assets. Turkey (Türkiye) - United States Department of State

Ministry of Treasury and Finance — the parent ministry that oversees MASAK, sets national AML/CFT policy, coordinates with international bodies including FATF, and issues secondary legislation related to financial crime prevention. Turkey (Türkiye) - United States Department of State

Law No. 7518 on the Regulation of Crypto-Assets — the primary law governing crypto-assets in Türkiye, published in the Official Gazette No. 32585 on July 2, 2024, which defines crypto-assets, establishes the licensing requirement for crypto-asset service providers through the CMB, creates the legal basis for MASAK AML oversight of the crypto sector, provides for investor protection mechanisms, and imposes sanctions including imprisonment and administrative fines for unlicensed operations. Turkey (Türkiye) - United States Department of State

Law No. 5549 on Prevention of Laundering Proceeds of Crime — the foundational AML law in Türkiye, which establishes the obligation for all financial institutions and designated non-financial businesses and professions (DNFBPs) to conduct customer due diligence, maintain records, report suspicious transactions to MASAK, and appoint compliance officers, with crypto-asset service providers explicitly brought within its scope. Turkey (Türkiye) - United States Department of State

Regulation on the Disuse of Crypto-Assets in Payments — issued by the CBRT on April 16, 2021 (Official Gazette No. 31009), this regulation prohibits using crypto-assets directly or indirectly as payment instruments and prevents payment service providers from developing or facilitating crypto-based payment systems. Turkey (Türkiye) - United States Department of State

Regulation on the Establishment and Operations of Crypto-Asset Service Providers — the CMB secondary regulation implementing Law No. 7518, which sets out detailed licensing conditions, organizational requirements, capital minimums, operational standards, and administrative procedures for crypto-asset platforms, custodians, and intermediaries. Turkey (Türkiye) - United States Department of State

General Communiqué on Crypto-Asset Service Providers — issued by the CMB, this communiqué provides technical and operational guidance on areas including investor complaint mechanisms, transaction monitoring systems, listing standards for crypto-assets, and risk management requirements. Turkey (Türkiye) - United States Department of State

MASAK General Communiqué on Suspicious Transaction Reporting — establishes the obligation and procedures for crypto-asset service providers to report suspicious transactions to MASAK, including filing timelines, report content, and the obligation to report attempted suspicious transactions. Turkey (Türkiye) - United States Department of State

Türkiye's Anti-Money Laundering and Counter-Terrorist Financing Legislation — a comprehensive body of laws and regulations including the Criminal Code (Law No. 5237), the Law on the Prevention of Laundering Proceeds of Crime (Law No. 5549), and the Terrorist Financing Prevention Law — all applicable to crypto-asset service providers as financial institutions. Turkey (Türkiye) - United States Department of State

Türkiye was removed from the FATF grey list (list of jurisdictions under increased monitoring) in June 2024, following a successful on-site visit and demonstrating significant progress in addressing the strategic AML/CFT deficiencies identified in its 2019 Mutual Evaluation Report, including the regulation of virtual asset service providers. Turkey (Türkiye) - United States Department of State

Türkiye is an active member of the Financial Action Task Force (FATF), having been a member since 1991, and participates in global AML/CFT standard-setting, though the country's technical compliance and effectiveness ratings have been subject to ongoing FATF review. Turkey (Türkiye) - United States Department of State

Türkiye's 2019 FATF Mutual Evaluation Report identified significant deficiencies in the regulation of virtual asset service providers, which directly prompted the development of Law No. 7518 and the comprehensive regulatory framework now in place. Turkey (Türkiye) - United States Department of State

The removal from the FATF grey list in 2024 is conditional on Türkiye maintaining its regulatory momentum, including full implementation and enforcement of the crypto-asset law, effective supervision of crypto-asset service providers, and continued reporting of suspicious transactions related to virtual assets. Turkey (Türkiye) - United States Department of State

All crypto-asset service providers operating in Türkiye must obtain a license from the CMB, including cryptocurrency trading platforms (exchanges), crypto-asset custodians/wallet service providers, crypto-asset intermediaries or brokers, and any entity providing crypto-asset-related financial services. Turkey (Türkiye) - United States Department of State

Entities that were already operating in Türkiye before the enactment of Law No. 7518 were required to apply to the CMB for a license within one month of the law's effective date (by early August 2024) or cease operations, with the CMB publishing a list of approximately 47 platforms that submitted initial applications. Turkey (Türkiye) - United States Department of State

Both foreign and domestic crypto-asset platforms must obtain a Türkiye license to serve Turkish residents, with foreign platforms required to establish a legal presence (a joint-stock company) in Türkiye, appoint authorized representatives, and meet all CMB requirements. Turkey (Türkiye) - United States Department of State

Crypto-asset trading platforms (exchanges) — operating facilities for the purchase, sale, exchange, or transfer of crypto-assets and for the initial sale or distribution of crypto-assets. Turkey (Türkiye) - United States Department of State

Crypto-asset custody services — providers that hold or control crypto-assets on behalf of customers, including wallet providers and institutional custodians. Turkey (Türkiye) - United States Department of State

Crypto-asset brokerage and intermediary services — entities that execute crypto-asset transactions on behalf of clients without operating a trading platform themselves. Turkey (Türkiye) - United States Department of State

Initial coin offerings (ICO/IDO) and token sales — the Law No. 7518 requires any entity conducting the initial sale or distribution of crypto-assets in Türkiye to register with the CMB, providing detailed disclosure documents and prospectus information. Turkey (Türkiye) - United States Department of State

Activities explicitly prohibited — using crypto-assets for payments (under CBRT regulation), and offering crypto-asset derivatives (options, futures, or other structured products based on crypto-assets) without separate CMB authorization. Turkey (Türkiye) - United States Department of State

The minimum capital requirement for crypto-asset service providers is set by the CMB in its Regulation on the Establishment and Operations of Crypto-Asset Service Providers, with the base requirement for trading platforms set at a specific amount that must be fully paid-in as cash capital (the exact figure is established in the CMB secondary legislation, approximately ₺200 million as of 2025). Turkey (Türkiye) - United States Department of State

Platforms operating in Türkiye must also maintain a security deposit or guarantee fund with the CMB or a designated Turkish bank, established at a percentage of trading volume or commission income, to protect customer assets in case of platform insolvency. Turkey (Türkiye) - United States Department of State

Custodians and intermediaries are subject to lower capital requirements than trading platforms, with the CMB establishing graduated capital thresholds based on the scope and risk profile of activities. Turkey (Türkiye) - United States Department of State

Applications must be submitted to the CMB through an electronic application system with comprehensive documentation including certificate of incorporation, articles of association, organizational structure, shareholder information, business plan, IT infrastructure documentation, AML compliance policies, and appointment of designated compliance officers. Turkey (Türkiye) - United States Department of State

The CMB is required to evaluate applications and issue a decision within six months of receiving a complete application file, though in practice the initial licensing process has taken longer due to the high volume of applicants and the CMB's simultaneous development of secondary regulations. Turkey (Türkiye) - United States Department of State

Applicants must also obtain MASAK compliance approval as part of the licensing process, demonstrating that they have adequate AML procedures, appointed a qualified AML compliance officer, and have operational KYC/AML systems in place. Turkey (Türkiye) - United States Department of State

Crypto-asset service providers must be established as joint-stock companies (anonim şirket) under Turkish law, with shares that must be issued in registered form, and with all shares held by shareholders who must meet fit-and-proper criteria established by the CMB. Turkey (Türkiye) - United States Department of State

Platforms must maintain an operational presence in Türkiye with employees, offices, and information technology infrastructure physically located in the country, and must submit periodic reports to the CMB and MASAK. Turkey (Türkiye) - United States Department of State

Corporate governance requirements include establishing risk management, internal audit, and compliance functions, with boards of directors having specific oversight responsibilities for AML compliance and consumer protection. Turkey (Türkiye) - United States Department of State

As of 2025, only a small number of crypto-asset service providers have been granted full operating licenses by the CMB, with the CMB continuing to review applications on a rolling basis; 47 platforms submitted initial applications in the one-month window following the law's enactment, and the CMB has processed these applications in batches. Turkey (Türkiye) - United States Department of State

The majority of applicants that submitted initial applications have been operating under a status of "continuing to process" — the transition regime that permits continued operations while the CMB evaluates their full license application, provided they comply with interim regulatory requirements. Turkey (Türkiye) - United States Department of State

Entities that did not submit an application by the deadline have been ordered to cease operations, and unlicensed operation after the law's effective date constitutes a criminal offense punishable by imprisonment. Turkey (Türkiye) - United States Department of State

Crypto-asset service providers must apply standard customer due diligence measures under Law No. 5549, requiring identification of customers based on official identity documents, verification of identity through reliable sources, and identification of any person acting on behalf of the customer. Turkey (Türkiye) - United States Department of State

CDD applies at the point of first business contact, meaning that a customer relationship is established when a user creates an account or wallet on a platform, and this relationship cannot begin until identity verification is completed. Turkey (Türkiye) - United States Department of State

For Turkish citizens, identity verification must be based on the national ID card (T.C. Kimlik Kartı) or passport, with the system cross-checked against the MERNIS national identity database maintained by the Directorate of Population and Citizenship Affairs. Turkey (Türkiye) - United States Department of State

For foreign individuals, CDD requires verification through a valid passport or national identity document, with additional verification steps required for customers from non-cooperative jurisdictions or jurisdictions with higher ML/TF risk. Turkey (Türkiye) - United States Department of State

For legal entities, due diligence must identify the entity's legal form, principal place of business, proof of incorporation/registration, corporate registration number, and authorized signatories, with the information obtained from official registries or certified extracts. Turkey (Türkiye) - United States Department of State

Enhanced due diligence triggers under MASAK rules include politically exposed persons (PEPs), customers from high-risk or FATF-listed jurisdictions, high-value or complex transactions, unusual transaction patterns, and customers that are legal entities with complex or opaque ownership structures. Turkey (Türkiye) - United States Department of State

For all customers, crypto-asset service providers must conduct ongoing monitoring of the business relationship, including scrutiny of transactions to ensure consistency with the customer's profile, known source of funds, and risk profile; transaction monitoring systems must be risk-based and automated. Turkey (Türkiye) - United States Department of State

The level of CDD may be adjusted based on a risk assessment, with simplified due diligence permitted only for clearly low-risk situations, and EDD required for medium and high-risk scenarios; providers must maintain a documented risk assessment methodology. Turkey (Türkiye) - United States Department of State

Turkish AML rules prohibit anonymous account opening in all circumstances, and all crypto-asset accounts (including non-custodial wallet integrations) must be tied to an identified, verified customer record. Turkey (Türkiye) - United States Department of State

Crypto-asset service providers must identify and verify the beneficial owner of all legal entity customers, where the beneficial owner is defined as the natural person(s) who ultimately own or control the legal entity, which under Turkish law means owning 25% or more of the entity or otherwise exercising ultimate control. Turkey (Türkiye) - United States Department of State

If no beneficial owner can be identified after exhausting all reasonable means, the provider must document the steps taken and treat the general manager or senior managing official as the customer for compliance purposes. Turkey (Türkiye) - United States Department of State

Beneficial ownership information is an important part of the AML risk profile used in transaction monitoring, and platforms must ensure this data is kept current through periodic reviews. Turkey (Türkiye) - United States Department of State

Politically exposed persons — both domestic and foreign — are subject to enhanced due diligence obligations, which must include obtaining approval from senior management before establishing or continuing the business relationship, taking reasonable measures to establish the source of wealth and source of funds, and conducting enhanced ongoing monitoring of the business relationship. Turkey (Türkiye) - United States Department of State

The PEP definition follows FATF standards, covering individuals who are or have been entrusted with prominent public functions (heads of state, senior politicians, senior government officials, military leaders, senior executives of state-owned corporations, important political party officials), their family members, and known close associates. Turkey (Türkiye) - United States Department of State

Screening must be conducted both at onboarding and periodically throughout the business relationship, as PEP status can change; the screening should compare the customer against databases of domestic and international PEPs. Turkey (Türkiye) - United States Department of State

Customers who become PEPs after account opening must not receive service until EDD measures have been applied and senior management approval has been obtained. Turkey (Türkiye) - United States Department of State

Suspicious transaction reports must be filed with MASAK under Article 4 of Law No. 5549, and crypto-asset service providers are explicitly designated as parties with reporting obligations. Turkey (Türkiye) - United States Department of State

The obligation to report arises when the provider knows, suspects, or has reasonable grounds to suspect that a transaction or attempted transaction involves proceeds of crime, is related to terrorist financing, or is otherwise suspicious based on the transaction's complexity, unusual nature, lack of economic rationale, or inconsistency with the customer's profile. Turkey (Türkiye) - United States Department of State

By MASAK's rules, delayed reporting is a common violation — the deadline is 10 business days from the date the suspicion arises (not from transaction date), a long-standing feature of the Turkish reporting regime; the obligation covers both completed transactions and attempted transactions. Turkey (Türkiye) - United States Department of State

Reports must be submitted electronically through MASAK's online reporting system (SVYS — Veri Yönetim Sistemi), with the standard format and required data fields for virtual asset transactions prescribed by MASAK. Turkey (Türkiye) - United States Department of State

Tipping-off is prohibited — both the customer and other third parties must not be notified that a suspicious transaction report has been filed. Turkey (Türkiye) - United States Department of State

The failure to report suspicious transactions carries significant penalties, including administrative fines under Law No. 5549 and criminal liability in certain circumstances. Turkey (Türkiye) - United States Department of State

Under Turkish AML law, crypto-asset service providers must retain all CDD records and transaction records for a minimum of 10 years after the end of the business relationship or the transaction date, following the general retention period established in Law No. 5549. Turkey (Türkiye) - United States Department of State

Records related to suspicious transaction reports must be kept for the same 10-year period, including the report itself, supporting documentation and analysis, and records of the decision-making process, with the exact scope prescribed by MASAK rules. Turkey (Türkiye) - United States Department of State

Transaction records must include identifying information about both the sender and beneficiary (matching travel rule requirements for crypto-asset transfers), the transaction value, the date and time of the transaction, the IP addresses and device identifiers involved, and wallet/account addresses. Turkey (Türkiye) - United States Department of State

Records can be retained in electronic form but must be reproducible in a manner that can be presented to MASAK inspectors, the CMB, or other authorities upon request. Turkey (Türkiye) - United States Department of State

The obligation to retain records is not limited to the transaction itself: KYC documentation, risk assessments, PEP screening results, STR analysis records, and audit trails of compliance decisions must all be maintained. Turkey (Türkiye) - United States Department of State

As of early 2025, the CMB had ordered approximately 15 crypto-asset platforms that failed to apply for a license or that were deemed not to meet threshold requirements to suspend operations and cease service to Turkish customers, with the CMB publishing a list of these unauthorized platforms on its website. Turkey (Türkiye) - United States Department of State

Enforcement actions against cryptocurrency platforms in Türkiye predate Law No. 7518, with the prominent case being the 2021 collapse of Thodex (a Turkish crypto exchange), where the founder was arrested and the company was investigated for fraud and money laundering; the Founder of Thodex was later sentenced in 2024 to 11,196 years in prison for fraud and similar offenses. Turkey (Türkiye) - United States Department of State

Following the Thodex collapse, Turkish courts and prosecutors pursued related money laundering charges, with individuals involved in processing Thodex's crypto and fiat transfers prosecuted alongside those running the exchange, and the platform's assets frozen and confiscated. Turkey (Türkiye) - United States Department of State

The CMB has imposed administrative fines on crypto platforms for violations of the interim operating regime, including platforms that engaged in marketing to Turkish users without authorization or failed to meet information/notification requirements set during the licensing transition period. Turkey (Türkiye) - United States Department of State

The Law No. 7518 includes a two-year imprisonment sentence for engaging in crypto-asset services without a CMB license, which applies to platform operators, executives, and individuals who facilitate unlicensed operations. Turkey (Türkiye) - United States Department of State

MASAK has imposed administrative fines on crypto-asset service providers for AML compliance failures, including late-filed or missing suspicious transaction reports, incomplete CDD documentation, and failures to appoint or properly support compliance officers; the fines range from tens of thousands to millions of Turkish lira depending on severity, per the Law No. 5549 schedule. Turkey (Türkiye) - United States Department of State

No tax guidance has been issued for virtual assets in Türkiye — the tax treatment of cryptocurrency transactions remains ambiguous, with no specific legislation or official guidance from the Turkish Revenue Administration (Gelir İdaresi Başkanlığı) that addresses the income tax, corporate tax, or VAT treatment of crypto-asset disposals, exchanges, or mining activities. Turkey (Türkiye) - United States Department of State

The Grand National Assembly of Türkiye has publicly stated that it is working on a tax reform package that is expected to define the tax treatment of crypto-assets, but no such legislation has been enacted as of the latest available report. Turkey (Türkiye) - United States Department of State

Until specific legislation is enacted, crypto-asset gains would presumably be characterized under general income tax provisions if the taxpayer's activities constitute commercial trading, but the CMB has not yet issued a comprehensive guideline applying general tax law to crypto income in a comprehensive way. Turkey (Türkiye) - United States Department of State

Capital gains on certain securities and other financial assets are subject to income tax in Türkiye, but the specific application of these rules to crypto-assets has not been clarified by the Revenue Administration or the courts, and the economic characterization of crypto-assets for tax purposes remains an open question. Turkey (Türkiye) - United States Department of State

Value Added Tax (VAT/KDV) — there is significant uncertainty about whether crypto-asset transactions are subject to VAT, with the Turkish Revenue Administration having not issued formal guidance and only informal commentary suggesting that they may be exempt under financial services provisions. Turkey (Türkiye) - United States Department of State

The "provisional operation" period creates significant legal and operational risk for crypto-asset platforms, as the full licensing decision has been delayed for many entities, and they must operate in a legal grey area where their license status is not fully confirmed; this affects their ability to contract with institutional clients, open bank accounts, and hire international staff. Turkey (Türkiye) - United States Department of State

The travel rule for crypto-asset transfers has not been fully implemented, with MASAK guidance still in draft form; platforms therefore face inconsistent cross-border AML compliance expectations, and this gap has been identified as a technical shortfall in Türkiye's post-grey list monitoring. Turkey (Türkiye) - United States Department of State

The tax ambiguity creates a material compliance risk for both platforms and individual users, and may also hinder platform valuations and merger transactions, since the tax liability of crypto-asset holdings and transfers is not fully predictable. Turkey (Türkiye) - United States Department of State

There is no specific regulatory framework for Decentralized Finance (DeFi) applications or decentralized platforms, and it is not entirely clear whether a smart contract or DeFi technology provider may constitute a "crypto-asset service provider" subject to licensing; the CMB has not yet issued interpretative guidance on the distinction between a platform and a technology provider. Turkey (Türkiye) - United States Department of State

MASAK's capacity to supervise the rapid growth of the crypto sector is stretched, with a relatively small team dedicated to virtual asset cases, which may create a gap between expected enforcement and what the FIU can actually review, particularly for smaller platforms and foreign entities. Turkey (Türkiye) - United States Department of State

The lack of clear guidance on NFTs and other emerging crypto-asset types represents a compliance gap — the definitions in Law No. 7518 are asset-focused, but the CMB's application of these definitions to unique digital assets is not yet settled. Turkey (Türkiye) - United States Department of State

The relationship between the CMB and MASAK in terms of real-time supervision and information sharing is still being operationalized, and there is some overlap in inspection powers that could create practical confusion for platforms subject to dual examinations. Turkey (Türkiye) - United States Department of State

The CBRT's strict payment ban continues to be a constraint, as it prohibits the use of crypto in payment transactions, and while this addresses the FATF risk of money laundering through payments, it also limits the market for legitimate platforms and merchant services. Turkey (Türkiye) - United States Department of State

Enforcement has concentrated on prominent cases but the overall compliance culture and awareness at mid-sized platforms may lag, and the significant number of unlicensed offshore platforms continuing to serve Turkish customers remains a risk for authorities attempting to enforce Türkiye's sovereignty over the crypto market. Turkey (Türkiye) - United States Department of State

Turkey (Türkiye) - United States Department of State