Crypto Regulation and Compliance Advisory
The crypto-asset sector in Türkiye became comprehensively regulated through the 2024 amendment to the Capital Markets Law and is now supervised by the Capital Markets Board (CMB) and the Financial Crimes Investigation Board (MASAK). We provide ongoing compliance advice to crypto-asset companies and virtual asset service providers (VASPs) on monitoring the legislation, preparing internal rules and dealing with the regulators.
What is a crypto-asset service provider?
Crypto-asset service providers are crypto-asset platforms, institutions providing crypto-asset custody services and other institutions brought within this scope by the legislation. Internationally they are known as VASPs (virtual asset service providers). In Türkiye, these institutions must obtain authorisation from the CMB to operate.
Service providers are also obliged parties under the anti-money laundering legislation: they must meet obligations towards MASAK such as customer due diligence, suspicious transaction reporting, record keeping and passing on originator and beneficiary information in transfers.
Scope
- Regulatory and compliance advice for crypto companies and VASPs
- Monitoring CMB, MASAK and Central Bank of the Republic of Türkiye regulations and assessing their impact on the company
- Preparing customer due diligence, anti-money laundering and internal control policies
- Preparing user agreements, risk disclosures and personal data protection texts
How We Work
- Assessing the company’s business model, services and target users against the legislation
- Reporting the applicable obligations and gaps
- Preparing or updating policies, procedures and user-facing texts
- Support in correspondence with regulators and in inspections
- Regular monitoring of legislative changes and internal briefings
Team
Frequently Asked Questions
Can a crypto platform based abroad serve users in Türkiye?
Platforms based abroad are prohibited from providing services by opening a place of business in Türkiye, setting up a Turkish-language website or carrying out promotional activities aimed at people in Türkiye. A platform wishing to serve users in Türkiye must obtain authorisation from the CMB.
Can crypto-assets be used or accepted for payments?
No. Under the Central Bank of the Republic of Türkiye regulation, crypto-assets cannot be used directly or indirectly in payments; payment and electronic money institutions also cannot develop business models using crypto-assets or act as intermediaries for such platforms.
What are the MASAK obligations?
Crypto-asset service providers must identify their customers, report suspicious transactions to MASAK, keep transaction records for the period set by the legislation, and establish internal control and training programmes. Passing on originator and beneficiary information to the counterparty service provider in transfers is also among these obligations.
What is required to operate in the European Union?
In the European Union, crypto-asset services are regulated by the Markets in Crypto-Assets Regulation, known as MiCA. A service provider authorisation obtained in one member state allows the provider to operate in other member states through a notification procedure.
Would you like to discuss this service? Schedule a meeting with us — the first meeting is free of charge.
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