Turkey Compliance Report

Generated 2026-10-23

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Banking Regulation and Supervision Agency, Scientific and Technological Research Council of T, Treasury and Finance Ministry
Risk Level: medium
Primary Legislation: Crypto Assets Law (2024), CBRT regulation, April 2021, Law No. 7518: Official Gazette No. 32590, July 2, 2024 (establishes CASP status,, Banking Regulation and Supervision Agency (BRSA): Oversees banking activities re, Central Bank Regulation on Prohibition of Payments with Crypto Assets: Published, Law on Amendments to the Capital Markets Law: Entered into force July 2, 2024; m
Travel Rule: Adopted — Threshold: Implemented
Tax Reporting: Tax framework under development; crypto payments banned (CBRT regulation, April 2021). Very high trading volumes despite restrictions.

Key Facts

aml 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
cross border The Turkish regulatory framework for cryptocurrencies and digital assets is evolving, with key developments in licensing, AML/KYC obligations, enforcement actions, tax treatment, and identified gaps and risks. Türkiye Cross-border | ReliefWeb Response Turkey's Financial Crimes Control and Prevention Agency (AFCP) oversees cryptocurrency activities under the Law on Money Laundering Prevention No. 6099, imposing AML/KYC requirements on digital asset service providers. Türkiye Cross-border: Protection | ReliefWeb Response Digital asset exchanges and custodial services require licenses from the Capital Markets Board (CMB) under Turkey's Securities Market Law No. 6203, necessitating compliance with AML/KYC standards. Türkiye Cross-border: Gender-based violence | ReliefWeb Response Licensed entities must implement robust customer due diligence (CDD) measures, including identity verification and ongoing monitoring to prevent illicit financing. Türkiye Cross-border - Data | ReliefWeb Response The AFCP has initiated enforcement actions against unlicensed crypto operators engaging in money laundering or terrorist financing activities. Penalties include fines and operational shutdowns. Integration of the Securities Market Infrastructure in the European... Cryptocurrency transactions are subject to a 10% income tax on gains, with specific reporting obligations for digital asset service providers. Managing Copyright in the Digital Art Industry: A Cross-Border Licensing Model for China and the EU Regulatory divergence between Turkey and European jurisdictions poses challenges for cross-border crypto businesses, highlighting the need for harmonized standards. Regulatory Delegation as Cooperative Control: The U.S. Sanctions Framework and Compliance Consolidation in Cross-Border M&As Türkiye Cross-border | ReliefWeb Response
custody Minimum capital for custodians: TRY 500 million (~$13.7 million). Platforms must register in the CMB's “kurum kaydı” (institutional ledger) system and comply by June 30, 2025, for existing operators. Only authorized banks or institutions may provide custody; foreign CASPs face restrictions. CMB Resolution dated September 19, 2024, further details prohibitions like lending. At least 95% in cold wallets managed by authorized custodians (max ~5% in hot wallets for operations). Use TÜBİTAK-compliant secure hardware modules for private keys. Integration with MKK (Turkish Central Securities Depository) for reconciliation and reporting.
enforcement Regulator/Prosecutor: Turkish prosecutors Regulator: Turkish authorities (likely law enforcement)
general Utility tokens provide access to goods and services that projects will launch, potentially including discount or premium access Security tokens (asset tokens) represent fixed assets or provide investment returns, similar to traditional securities Law on Amendments to the Capital Markets Law (effective as of July 2024): Requires all crypto asset service providers to obtain an operating license from the CMB. Central Bank Regulation (published in Official Gazette No. 31456 on April 16, 2021): Prohibits using cryptocurrencies for payments. Obtain authorization from the CMB with minimum capital thresholds: TRY 150 million ($4.1 million) for exchanges and TRY 500 million ($13.7 million) for custodians Comply with AML/KYC rules enforced by MASAK Pay annual fees of 2% total (1% each to CMB and the Scientific and Technological Research Council) Report all transactions to tax authorities
licensing SPK/CMB — Crypto Asset Service Provider licensing, prudential oversight MASAK — Financial crimes, AML/CFT Crypto Assets Law (2024) — CASP licensing, investor protection, criminal penalties for unlicensed operation. Came after Thodex fraud (2021, CEO fled with ~$2B). VASP: Crypto Asset Service Provider License from SPK under Crypto Assets Law (2024). TRY 50M (~$1.5M USD) minimum paid-up capital. Must establish Turkish entity with Turkish-resident board members. 6-12 months. One of world's highest crypto adoption rates. CUSTODY: Included under CASP license; customer asset segregation required EXCHANGE: CASP license — TRY 50M minimum. Crypto PAYMENTS banned (CBRT regulation, April 2021) — ban remains despite licensing framework. Criminal penalties for unlicensed operation. Law No. 7518: Official Gazette No. 32590, July 2, 2024 (establishes CASP status, CMB licensing, segregation). CMB Resolutions/Communiqués: Govern licensing, capital (TRY 500M/~$13.7M for custodians), prohibitions (e.g., Sept 19, 2024).
marketing Issuance of Digital Asset Service Provider License by [Ministry of Industry and Technology], subject to compliance with strict operational standards. Implementation of AML Policy & Procedure Manual, ensuring thorough customer due diligence (CDD) and ongoing monitoring for suspicious activities. Regular audits to verify compliance with established standards; fines imposed for non-compliance, reaching up to 5% of annual turnover. Türkiye Financial Market Regulation Authority conducts inspections and investigations, potentially revoking licenses or imposing substantial penalties. Cooperation with international anti-money laundering organizations is mandatory to maintain regulatory compliance. Cryptocurrency transactions are taxed at flat rates (10-25%) as income; exclusions for charitable donations and business expenses exist. Türkiye Revenue Administration provides clear guidelines on reporting, record-keeping, and potential penalties for non-compliance. Regulatory Uncertainty: Insufficient clarity in licensing requirements may lead to ambiguity for operators; continuous policy updates are necessary.
ongoing Source: Mutual Evaluation Report of Türkiye 2026 Source: Crypto Law in Türkiye: Process | CoinTR Source: Cryptocurrency Regulations in Türkiye - Sanction Scanner Crypto Law in Türkiye: Process | CoinTR Cryptocurrency Regulations in Türkiye - Sanction Scanner Mutual Evaluation Report of Türkiye 2026 Turkish Tax Administration (Maliye) guidelines on taxation of cryptocurrency incomes and capital gains. Implementing secure systems for trading platforms.
sanctions OFAC Compliance: Screen against the Specially Designated Nationals (SDN) list (sanctionssearch.ofac.treas.gov) for wallets, exchanges, and entities; non-U.S. VASPs risk secondary sanctions or penalties (e.g., Binance's $4.3B fine in 2023 for Iran/Cuba/Syria/Crimea transactions). EU/UK Compliance: Screen EU consolidated lists and UK OFSI lists if using EU/UK clearing or partners; EU sanctions apply to EU-origin goods/transactions. UN Compliance: No UN sanctions target Turkey, but universal enforcement is expected (though uneven globally). Mandatory real-time screening of counterparties, UBOs, and wallets against OFAC SDN, EU/UK lists before any crypto transaction. Ongoing monitoring required due to frequent updates (e.g., 2026 OFAC additions/removals of Turkish-linked entities). Crypto-specific: Block services to comprehensively sanctioned jurisdictions (Iran, North Korea, Cuba, Syria, Crimea/Donbas Ukraine). OFAC comprehensive programs (e.g., Iran, Cuba, Syria, Crimea). EU-targeted areas (e.g., Russian crypto for war financing, Cypriot waters drilling).
securities Crypto assets are legal in Turkey but not classified as securities under the Capital Markets Law; the Capital Markets Board (SPK) regulates crypto-asset service providers (CASPs) under a dedicated framework enacted in 2024–2025 Türkiye Introduces New Crypto Asset Regulations: A Landmark Development in Digital Finance. The SPK (Capital Markets Board of Turkey) is the primary regulator; it issues licences for CASPs and supervises compliance with the Communiqué on Operational Principles and Capital Adequacy Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA. Licensing is mandatory for exchanges, custodians, and other CASPs; as of early 2025 the SPK was conducting fit-and-proper assessments on applicants but no public list of fully licensed entities has been published Turkey – Blockchain & Crypto Assets – Country Comparative Guides. AML/KYC obligations fall under MASAK (Financial Crimes Investigation Board) and align with FATF standards; CASPs must perform CDD, EDD, STR filing, and beneficial-ownership checks Crypto in Turkey: Is It Legal? Updated Regulations (2025) | The Sumsuber. Tax treatment remains unclear: no specific tax guidance for virtual assets has been issued; gains may be subject to income tax under general provisions but capital-gains and VAT rules are not defined Cryptocurrency Regulations in Turkey: Legal Overview for Investors and Exchanges. Regulator: Capital Markets Board of Turkey (SPK / CMB) — website: https://www.spk.gov.tr/ Crypto Licensing in Turkey: Essential 2026 Guide to Secure Exchanges | TENHA LAW FIRM - TENHA. Primary legislation: Law No. 7518 on Amendments to the Capital Markets Law (published 2 July 2024) and the Communiqué on Operational Principles and Capital Adequacy of Crypto Asset Service Providers (Communiqué Serial: III, No. 35.1, effective 2025) THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review. Crypto assets are explicitly excluded from the definition of “securities” under the Capital Markets Law; they are regulated as a separate asset class under the new CASP regime THE QUALIFICATION OF CRYPTO-ASSETS AS SECURITIES UNDER TURKISH LAW: A COMPARATIVE ANALYSIS - The Boğaziçi Law Review.
stablecoin BRSA oversees banking activities, ensuring that stablecoin issuers comply with financial stability requirements. CMB regulates capital markets, focusing on transparency and investor protection in digital asset transactions. Reserve Requirements: Issuers must maintain a minimum reserve of 100 000 TRY (≈ 6 500 USD/5 300 EUR) per issued stablecoin unit to ensure backing by Turkish Lira or equivalent fiat currency. Citation: Stablecoin & Digital Asset Regulations in Türkiye — Compliance... Verification Process: Users must undergo Know Your Customer (KYC) verification through government-approved channels. Monitoring: Continuous transaction monitoring is mandated, with alerts triggered by deviations from typical user behavior. Citation: Stablecoins | Crypto Wealth Report 2026 | Henley & Partners Penalties: Fines up to 5 000 000 TRY (≈ 325 000 USD/265 000 EUR) for AML/KYC violations. Citation: Türkiye Stablecoin Regulation — Live | STRIDE Tracker License Suspension: Immediate suspension of operations pending compliance review. Tax Rates: Transactions classified as barter exchanges are taxed at 15 %, while sales/repurchases incur a 10 % rate.
tax Tax framework under development; crypto payments banned (CBRT regulation, April 2021). Very high trading volumes despite restrictions.
travel rule Travel Rule adopted — threshold: TRY 75,000 Official Gazette amendments (Dec 25, 2024): https://www.resmigazete.gov.tr/ (search MASAK communiqués) MASAK Regulation on Measures: https://www.masak.gov.tr/en/mevzuat/regulation-on-measures-regarding-prevention-of-laundering-proceeds-of-crime-and-terrorism-financing SPK/CMB and TÜBİTAK standards: Via respective sites (cmb.gov.tr, tubitak.gov.tr)

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-10-23. View full profile