Ranking 4th globally for crypto adoption and with an estimated 22 million individuals engaging in trading activities on cryptocurrency platforms in Türkiye, the country recognised the need to regulate these platforms. Since July 2024, Türkiye has been working towards crypto regulation.
The legislation aims to regulate cryptocurrency service providers, platform activities, and the trading and storage of cryptocurrencies for Turkish residents. It also addresses the classification of cryptocurrencies and projects, ensuring compliance with existing financial regulations.
What is the scope of the Travel Rule in Türkiye?
Türkiye’s Travel Rule applies to crypto asset service providers (CASPS), which are defined as “crypto asset exchange platforms, crypto asset custodians and any other service provider providing services in relation to crypto assets”.
A platform is an institution where one or more activities are performed: buying, selling, initial sale or distribution, exchange, transfer, required custody of crypto assets, and other transactions that may be determined.
Crypto asset custodians provide the management or other custody services determined by the CMB for the custody of crypto assets of platform customers, or the private keys providing transfer rights from the wallet related to these assets.
Who is the supervisory body for CASPs in Türkiye?
Financial Crimes Investigation Board (MASAK) is responsible for the Travel Rule
Capital Markets Board of Türkiye (CMB) oversees CASP licensing and market operations.
Responsibilities of Turkish CASPs
Per Article 35/B of Capital Markets Law, CASPs must obtain permission from the CMB before offering services and may only carry out the activities determined by the CMB.
CASPs must ensure that the necessary precautions are taken to implement internal controls to manage their systems. Additionally, CASPs must ensure that their IT systems and infrastructure align with TÜBİTAK’s requirements.
CASPs are to implement robust KYC procedures to monitor transactions for suspicious activity. All suspicious transactions are to be reported to MASAK.
CASPs must complete KYC processes before entering into a contract or making a transaction with an entity or party. All data collected during the KYC process must be verified with documentation, which is to be stored for 8 years.
See Türkiye's System Localisation and Data Management Regulations
What is the Travel Rule threshold in Türkiye?
The Turkish Travel Rule applies to all transactions. However, data points need not be verified for transactions under 15,000 TL (approximately EUR 425).
What are MASAK’s requirements for Travel Rule information to be exchanged?
For all transfers equivalent to or exceeding 15,000 TL, the following data points are to be exchanged and verified*.
Originator Information:
Name and surname
Title of the legal entity if registered in the trade registry, or full name of the other legal entities or entities without legal personality
Wallet address or transaction reference number
At least one of the following identifiers: address, date and place of birth, customer number, tax identification number, ID number or passport number
Beneficiary Information:
Name and surname
Title of the legal entity if registered in the trade registry, or full name of the other legal entities or entities without legal personality
Wallet address or transaction reference number
The same data points outlined in bullet (1), (2) if applicable, and (3) must be provided for transactions under 15,000 TL, but no verification is required.
If the required data is not provided, CASPs shall request for completion of the missing data and return the funds. If the required data still is not complete, CASPs have the authority to deem the transaction risky and halt it or terminate business relations.
*Verification is a once-off activity and will occur when the customer opens an account at an exchange. Thereafter, they can transact without further verification procedures.
Self-hosted wallets are in scope
For transactions involving a self-hosted wallet, customers of CASPs involved in the transfer must provide a “declaration”. The declaration must include one of the following identifiers:
name and surname of the originator or beneficiary;
trade name, if the originator or beneficiary is a legal entity;
address;
date or place of birth;
customer number;
tax identification number; or
ID number or passport number.
Transactions with Foreign Entities
In cross-border transactions where the foreign CASP does not require the exchange of personal information, the Turkish-based CASP must still obtain at least one piece of identifying data from the counterparty. This can include:
name and surname;
trade name, if the originator or beneficiary is a legal entity;
address;
date and place of birth;
customer number;
tax identification number; or
ID number or passport number.
When do you need to comply with the Travel Rule in Türkiye?
25 February 2025
Which regulations are applicable to the Türkiye Travel Rule?
Law No. 7518 Amending the Capital Markets Law Regarding Crypto Assets
