Turkey Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Ministry of Treasury and Finance, Turkish Revenue Administration
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
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).
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.
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: 2026-09-22. View full profile