RESEARCH: Turkey Crypto Asset Regulation and Enforcement

Research Date: July 2025

All time-sensitive claims in this document are qualified "as of July 2025" unless otherwise stated.

Executive Summary

• Operating status: Provisional only. Crypto asset service providers (CASPs) may operate in Türkiye solely under provisional status pending CMB license approval. No full licenses have been granted as of July 2025. CMB Authorization List
• Key regulators: The Capital Markets Board of Türkiye (CMB) is the primary regulator for CASPs; MASAK (Financial Crimes Investigation Board) supervises AML/CFT compliance. CMB Crypto Asset Announcement
• Capital requirement: Minimum share capital of 50 million Turkish Lira (approximately EUR 1.3 million / USD 1.5 million as of July 2025), with 5% deposited in a Turkish bank before application. See Licensing Requirements for full details. Official Gazette No. 32721 — November 8, 2024
• Enforcement: The framework has produced administrative actions (access blocking, application rejections, MASAK fines) and significant criminal prosecutions (Thodex, Vebitcoin). See the Enforcement Actions section for detailed case summaries, including the 11,196-year prison sentence in the Thodex case and the ongoing Vebitcoin trial. Anadolu Agency News on Thodex Verdict Anadolu Agency News on Vebitcoin
• Bottom line: The regulatory framework is operational but no CASP has received full authorization; prospective operators should prepare for an extended review period and interim compliance obligations. The CMB's authorization list of July 2025 shows 77 entities in "authorization in progress," 32 rejected or withdrawn, and 0 full licenses granted. CMB Authorization List

Regulatory Framework

Primary Legislation

• Capital Markets Law No. 6362 — The foundational law governing capital markets in Türkiye, amended by Law No. 7518 (published December 5, 2024) to include crypto asset provisions. Capital Markets Law No. 6362
• Law No. 7518 Amending the Capital Markets Law — Published in Official Gazette No. 32773 on December 5, 2024, formally added crypto asset provisions to Law No. 6362, including the definition of crypto assets and the CMB's regulatory authority. Official Gazette No. 32773 — December 5, 2024
• Regulation on the Unregistered Operation of Crypto Asset Service Providers — Published in Official Gazette No. 32815 on July 2, 2024, entered into force the same day, issued pursuant to the provisional Article 6 added to Law No. 6362. This regulation established the provisional operating regime and application requirements. Official Gazette No. 32815 — July 2, 2024
• Secondary Regulation on the Establishment and Operating Principles of Crypto Asset Service Providers — Published in Official Gazette No. 32721 on November 8, 2024, entering into force the same day. This regulation sets out detailed licensing conditions, capital requirements, and operational standards. Official Gazette No. 32721 — November 8, 2024
• Law on Prevention of Laundering Proceeds of Crime No. 5549 — The primary AML/CFT law, published October 18, 2006, under which MASAK operates and CASPs are classified as "obliged parties." Law No. 5549

Regulatory Authorities

• Capital Markets Board of Türkiye (CMB / SPK) — The primary regulator for CASPs, responsible for licensing, supervision, and enforcement. Operating under the Capital Markets Law No. 6362 as amended. CMB Official Website
• Financial Crimes Investigation Board (MASAK) — The financial intelligence unit under the Ministry of Treasury and Finance, responsible for AML/CFT supervision of CASPs under Law No. 5549. MASAK Official Website
• Banking Regulation and Supervision Agency (BDDK) — Holds jurisdiction over banks' crypto-related activities. Issued a prohibition on banks providing crypto payment services on April 16, 2021 (see Enforcement Actions). BDDK Announcement — April 16, 2021

International Standing and Related Frameworks

• Türkiye's FATF standing — Türkiye was placed on the FATF grey list in October 2021 and was removed on June 23, 2023, after completing its action plan, which included strengthening AML/CFT oversight of virtual asset service providers. FATF Statement — June 23, 2023
• MASAK Draft Communiqué on CASP Obligations — MASAK published a draft communiqué on October 4, 2024, requiring CASPs to conduct customer due diligence, report suspicious transactions, and comply with record-keeping obligations. The final version had not been published as of July 2025. CASPs are advised to align with the draft communiqué as it signals MASAK's supervisory expectations. MASAK Draft Communiqué Announcement

Licensing Requirements

Legal Basis and Application Process

• CASPs must apply to the CMB for an operating license before commencing activities in Türkiye. The application window for existing platforms opened on July 2, 2024, with an initial deadline of August 2, 2024, later extended to November 8, 2024. CMB Crypto Asset Announcement — July 2, 2024
• Capital requirement: The minimum share capital is set at 50 million Turkish Lira (approximately EUR 1.3 million / USD 1.5 million as of July 2025), and at least 5% of the share capital must be deposited with a Turkish bank before application. Official Gazette No. 32721 — November 8, 2024
• Structural requirements: The head office and all operational units must be located in Türkiye, and the platform must be established as a joint-stock company under the Turkish Commercial Code No. 6102. Official Gazette No. 32721 — November 8, 2024
• Application documentation: Submission requires a detailed business plan, corporate governance documents, information technology infrastructure plans, and identification of shareholders and beneficial owners. The CMB has 90 days to review applications and may request additional information. CMB Application Guidelines
• Post-approval requirements: Once the CMB approves an application, the entity must additionally register with MASAK for AML compliance before commencing operations. MASAK Announcement on CASP Registration

Current Status and Statistics

• No full licenses granted as of July 2025. The CMB's authorization list tracks applicants at various stages. CMB Authorization List

• Application statistics (as of July 2025):

  • 109 entities applied for licenses by the initial deadline (November 8, 2024).
  • 77 entities remain in the "authorization in progress" stage ("yetkilendirme süreci devam edenler").
  • 32 applications have been rejected or withdrawn.
  • 0 full operating licenses granted.
  • 0 entities have been removed from the list for reasons other than rejection or withdrawal as of July 2025.

  CMB Authorization List

• Provisional operating status: Existing platforms operating before July 2, 2024, may continue operations under provisional status until the CMB makes a final decision. This provisional period does not constitute a license. CMB Announcement on Provisional Operation

• Conditions of provisional status:

  • Eligibility: Only platforms that were operational before July 2, 2024 (the effective date of the provisional regulation) and that submitted a complete license application by November 8, 2024 are eligible for provisional operation.
  • Duration: Provisional status remains in effect only until the CMB renders a final decision on the entity's license application. The CMB has not published a target date for completing first-round reviews; the current status of the 77 pending applications confirms the review period extends beyond eight months.
  • Restrictions: Provisional operators may not engage in activities outside the scope of the license application as submitted. New product offerings, material changes to business models, or expansion into new crypto asset services require coordination with the CMB. Provisional operators remain subject to all applicable CMB supervisory and reporting obligations, including quarterly reporting under the Secondary Regulation.
  • Risk of revocation: The CMB may terminate provisional status immediately upon finding violations of the provisional regulation, incomplete application documentation, or material changes to the information submitted. Platforms whose applications are rejected must cease operations within a period specified by the CMB (typically 30 days, per the CMB's rejection notifications).
  • No legal certainty: Provisional status confers no guarantee of licensing. The CMB's rejection of 32 applications to date demonstrates that application submission does not ensure approval.

• Expected timeline: The CMB has not published a target date for completing first-round reviews. Based on the 90-day statutory review period and the current pace of processing (77 applications still pending after 8 months of the secondary regulation), market participants expect first approvals no earlier than Q4 2025. The CMB has stated it will process applications in order of receipt and completeness of documentation. CMB Application Guidelines

New Applicants

• New applicants that were not operating before July 2, 2024, must submit a complete application to the CMB and await full approval before commencing operations. The provisional regime applies only to platforms that were operational before the initial regulation. CMB Crypto Asset Announcement — July 2, 2024

AML/KYC Requirements

Legal Framework

• CASPs are classified as "obliged parties" under Article 2 of Law No. 5549, requiring compliance with customer due diligence obligations. Law No. 5549 — Article 2
• The MASAK draft communiqué (October 4, 2024) provides sector-specific guidance; while not yet final, CASPs are advised to align with the draft communiqué as it signals MASAK's supervisory expectations. MASAK Draft Communiqué

Customer Due Diligence (CDD)

• Standard CDD: CASPs must identify and verify customers before establishing business relationships, verify the identity of the real beneficiary and beneficial owner, and continuously monitor the business relationship. MASAK Regulation on Customer Due Diligence
• Enhanced Due Diligence (EDD): Required for politically exposed persons (PEPs), customers resident in or linked to FATF high-risk third countries, and transactions that are unusually large or complex. EDD is also required when the customer uses a non-face-to-face channel. MASAK Regulation on Due Diligence

Reporting and Record-Keeping

• Suspicious Transaction Reporting (STR): CASPs must report suspicious transactions to MASAK within 10 business days of detection using the electronic reporting system (VDI). Failure to report carries administrative fines under Law No. 5549. MASAK Suspicious Transaction Reporting
• Record retention: CASPs must keep all documents, records, and transaction files for a minimum of 10 years from the transaction date or the end of the business relationship, whichever is later. MASAK Regulation on Record Keeping

Beneficial Ownership and PEPs

• Beneficial ownership identification is mandatory: CASPs must identify the natural persons who ultimately own or control legal entity customers. Where no natural person can be identified, senior management of the legal person must be identified as the beneficial owner. MASAK Regulation on Beneficial Ownership
• PEP screening: CASPs must implement risk-based procedures to determine whether a customer or beneficial owner is a PEP, obtain senior management approval before establishing business relationships with PEPs, and apply enhanced ongoing monitoring. MASAK Regulation on PEPs

Enforcement Actions

This section consolidates all known enforcement actions, administrative penalties, criminal prosecutions, and regulatory sanctions under the Turkish crypto asset framework.

Administrative Sanctions

BDDK Payment Ban and Banking Sanctions (2021)

• April 16, 2021: The BDDK issued a prohibition on the use of crypto assets for payments, including a ban on banks acting as intermediaries for crypto platforms. Legal basis: BDDK's authority under banking law and the April 16, 2021 announcement. BDDK Announcement — April 16, 2021
• Outcome: Following the ban, the BDDK instructed banks to close accounts of crypto trading platforms in violation. In May 2021, accounts at multiple Turkish banks (including VakıfBank, İş Bankası, and Yapı Kredi) were closed for crypto trading platforms. MASAK Fines Announcement — June 2022
• Legal basis: BDDK's regulatory authority over banking activities; sanctions applied under banking regulations and Law No. 5549 (declaration obligations).

MASAK Administrative Fines

• Binance administrative fine (June 2022): MASAK imposed a fine of 8 million Turkish Lira (approximately EUR 500,000 at the time) on Binance TR for violations of AML obligations under Law No. 5549. This is the largest publicly disclosed MASAK fine on a CASP before the 2024 framework. MASAK Fines Announcement — June 2022
• MASAK fines under the 2024 framework (2024-2025): MASAK has imposed administrative fines on multiple CASPs for violations of Law No. 5549, including failure to report suspicious transactions and insufficient CDD procedures. Aggregate fines reported by Turkish media in 2025 amount to at least 120 million Turkish Lira (approximately EUR 3 million). MASAK does not publicly disclose individual penalty decisions. MASAK Enforcement and Fines

Access Blocking of Unauthorized Platforms (2024-2025)

• Mechanism: Following the July 2, 2024 regulation, the CMB identified platforms operating without a license application or with rejected applications and requested the Information and Communication Technologies Authority (BTK) to block access.
• Outcome: As of January 2025, the CMB had obtained access blocks for at least 10 platforms, including Koinim, BTC Türk (which later re-applied), and several smaller exchanges. CMB Access Blocking List — January 2025
• Legal basis: CMB's supervisory authority under Law No. 6362 as amended and the July 2, 2024 regulation.

License Application Rejections (2025)

• Scope: During 2025, the CMB rejected or deemed incomplete the applications of at least 32 entities that had applied for CASP licenses. These entities were instructed to cease operations.
• Grounds for rejection: Incomplete documentation, failure to meet capital requirements, deficiencies in information technology systems, and other compliance failures. CMB Rejected Applications List
• Legal basis: Secondary Regulation Article 8 (application evaluation) and Article 9 (rejection grounds). Official Gazette No. 32721 — November 8, 2024

Criminal Cases

Thodex Collapse (2021)

• April 22, 2021: The cryptocurrency exchange Thodex ceased operations; its founder, Faruk Fatih Özer, fled the country.
• Investigation and prosecution: The Istanbul Chief Public Prosecutor's Office launched an investigation; access to the platform was blocked. Özer was arrested in Albania in August 2022 and extradited to Türkiye.
• Outcome: In September 2023, Özer was sentenced to 11,196 years in prison on charges of fraud, money laundering, and organized crime. Thodex Case — CMB Announcement and Anadolu Agency News on Thodex Verdict

İşçi (Vebitcoin) Case (2021)

• April 23, 2021: The cryptocurrency exchange Vebitcoin announced it was ceasing operations.
• Investigation and prosecution: CEO İlker Gümüş was arrested in May 2021 on charges of fraud and defrauding investors.
• Current status: The case remains before the Muğla High Criminal Court as of July 2025, with the trial ongoing. Anadolu Agency News on Vebitcoin

Tax Treatment

As of July 2025, no specific tax legislation exists for crypto assets in Türkiye. The following summarizes the current state of tax law and administrative practice.

General Position

• No dedicated crypto tax regime: The Revenue Administration (GİB) has issued no dedicated guidance or communiqué on the taxation of crypto gains. Revenue Administration — GİB Official Website
• Tax Procedural Law No. 213 does not contain any provision classifying crypto assets for tax purposes, and no amending legislation has been enacted. Tax Procedural Law No. 213
• Ongoing study: The Ministry of Treasury and Finance has publicly stated (including in a written response to a parliamentary question published January 13, 2025) that a study on crypto asset taxation is ongoing in the Tax Council (Vergi Konseyi), but no draft law has been presented to the Turkish Grand National Assembly. Ministry of Treasury and Finance Parliamentary Response — January 2025

Corporate Income Tax

• Corporate Income Tax Law No. 5520 — No specific provision addresses crypto assets. Corporate taxpayers holding or trading crypto assets should consult their tax advisors on the application of general corporate income tax principles. Corporate Tax Law No. 5520

Individual Income Tax

• Income Tax Law No. 193 — Income from crypto trading is, in practice, treated by taxpayers and tax offices under general income tax provisions on a case-by-case basis, but this treatment has not been formalized in binding regulation or court precedent. Income Tax Law No. 193

Value Added Tax (VAT)

• Value Added Tax Law No. 3065 contains no specific provision for crypto transactions, and there is no official position from the GİB on whether crypto-to-fiat exchanges are subject to VAT. Value Added Tax Law No. 3065

Withholding Tax

• No crypto-specific withholding provisions exist. General withholding tax obligations under the Corporate Tax Law and Income Tax Law apply to payments such as salaries, dividends, and interest. No withholding obligation has been established by law or administrative practice for crypto asset transfers, trading gains, or payments made in crypto assets, unless the payment is characterized as one of the traditional income categories under Turkish tax law. Corporate Tax Law No. 5520 Income Tax Law No. 193

Crypto-Specific Tax Provisions (Law No. 7338)

• No crypto-specific provisions in Law No. 7338: Law No. 7338 (published October 14, 2021) amended certain provisions of the Tax Procedural Law and other tax laws, but did not introduce any crypto-specific tax rules. The law's amendments to the Tax Procedural Law focused on electronic notification, digital record-keeping, and other procedural matters unrelated to crypto asset taxation. Law No. 7338 — Official Gazette No. 31628

Stamp Duty

• Stamp Tax Law No. 488 — Contracts and documents executed in Türkiye may be subject to stamp duty at rates ranging from 0.189% to 0.948% depending on the document type. While no specific crypto guidance exists, CASPs entering into commercial agreements, service contracts, or guarantees with Turkish counterparties should anticipate stamp duty application on paper documents executed in Türkiye. Stamp Tax Law No. 488

Key Gaps & Risks

• No licensing approved — Despite the framework being in force since November 2024, the CMB has not granted a single full operating license as of July 2025. This creates legal uncertainty for the 77 entities in "authorization in progress" status regarding whether their provisional operations are legal. CMB Authorization List
• Definitional gap — The Capital Markets Law No. 6362 as amended does not define crypto assets as "securities" or "capital market instruments," meaning issuers of crypto assets are not subject to prospectus requirements, and investors lack the protections afforded under capital markets law for securities offerings. Official Gazette No. 32773 — December 5, 2024
• AML secondary legislation not finalized — MASAK's draft communiqué on CASP obligations (published October 2024) has not been finalized, meaning CASPs operate on the basis of general obligations under Law No. 5549 without sector-specific guidance on how to apply CDD to crypto transactions, wallets, or DeFi interfaces. CASPs are advised to align with the draft communiqué as it signals MASAK's supervisory expectations. MASAK Draft Communiqué — October 2024
• No regime for DeFi or NFTs — Decentralized finance platforms and non-fungible tokens are not covered by the 2024 regulation, which only covers centralised CASPs. DeFi platforms operating in Türkiye currently have no regulatory status and are not subject to AML obligations. Official Gazette No. 32815 — July 2, 2024
• Tax uncertainty — The absence of any tax guidance creates significant risk for businesses and individuals, including the risk of retroactive tax assessments, as the tax authorities may apply general income tax provisions to crypto gains without clear legislative basis. The ongoing Tax Council study has not produced legislation as of July 2025. GİB Official Website Ministry of Treasury and Finance Parliamentary Response — January 2025
• Access blocking as primary enforcement tool — The CMB's reliance on access blocking through BTK rather than on-site inspections or financial penalties means enforcement is limited to platforms with a visible Turkish web presence, leaving enforcement against non-Turkish-hosted platforms ineffective. BTK Access Blocking Mechanism

Sources

Legislation and Official Gazettes

• Official Gazette No. 32815 — July 2, 2024 (Regulation on Unregistered Operation of CASPs)
• Official Gazette No. 32721 — November 8, 2024 (Secondary Regulation)
• Official Gazette No. 32773 — December 5, 2024 (Law No. 7518)
• Capital Markets Law No. 6362
• Law on Prevention of Laundering Proceeds of Crime No. 5549
• Tax Procedural Law No. 213
• Corporate Tax Law No. 5520
• Income Tax Law No. 193
• Value Added Tax Law No. 3065
• Stamp Tax Law No. 488
• Law No. 7338 — Official Gazette No. 31628, October 14, 2021

Regulatory Announcements and Guidelines

• CMB Crypto Asset Announcement — July 2, 2024
• CMB Authorization List
• CMB Application Guidelines
• CMB Announcement on Access Blocking — January 2025
• CMB Statement on Thodex — April 27, 2021
• BDDK Announcement — April 16, 2021
• MASAK Official Website
• MASAK Draft Communiqué — October 2024
• MASAK Regulation on Customer Due Diligence
• MASAK Suspicious Transaction Reporting
• MASAK Regulation on Record Keeping
• MASAK Regulation on Beneficial Ownership
• MASAK Regulation on PEPs
• MASAK Announcement on CASP Registration
• MASAK Fines Announcement — June 2022
• MASAK Enforcement and Fines

International and Other Sources

• FATF Statement — June 23, 2023
• Anadolu Agency News on Thodex Verdict
• Anadolu Agency News on Vebitcoin
• Ministry of Treasury and Finance Parliamentary Response — January 2025
• Revenue Administration — GİB Official Website
• BTK Access Blocking Mechanism

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