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23 June 2025

Recent Developments In The Banking & Finance Sector In Türkiye

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Herguner Bilgen Ucer Attorney Partnership

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Hergüner Bilgen Üçer is one of Türkiye’s largest, full-service independent corporate law firms representing major corporations and clientele, and international financial institutions and agencies. Hergüner not only provides expert legal counsel to clients, but also serves as a trusted advisor and provides premium legal advice within a commercial context.
With Presidential Decree No. 9595 published in the Official Gazette on 15 March 2025, amendments were made to Decree No. 32 on the Protection of the Value of Turkish...
Turkey Finance and Banking

Amendments to Decree No. 32 on the Protection of the Value of Turkish Currency and Related Communiqués

With Presidential Decree No. 9595 published in the Official Gazette on 15 March 2025, amendments were made to Decree No. 32 on the Protection of the Value of Turkish Currency regarding precious metal transactions, derivative transactions, collateral practices, and Turkish lira that may be taken abroad. Some of the changes are as follows:

  • With the amendment to Article 6 of Decree No. 32, forward transactions, option contracts, and other derivative instruments based on foreign currency and precious metals may now also be traded by banks.
  • With the amendment to Article 18 of the Decree, flexibility has been introduced regarding collateral for loans in foreign currency or precious metals obtained domestically. From now on, the domestic group companies of a Turkish-resident company receiving such a loan, or the real/legal person shareholders who directly hold shares in that company, may provide a guarantee or surety in foreign currency or precious metals for the relevant loan.
  • Within the scope of Article 3 regarding the export of Turkish currency abroad, the upper limit for the amount of Turkish lira cash that may be taken abroad has been increased from TRY 25,000 to TRY 185,000.

The Ministry of Treasury and Finance of the Republic of Türkiye (“MoTF”) announced on 6 March 2025 that a key amendment to Communiqué No. 2008-32/34 under Decree No. 32 on the Protection of the Value of Turkish Currency now allows Turkish residents to denominate payment obligations under sale agreements for movable property, excluding vehicle sales, in foreign currency or FX-indexed terms. The announcement clarifies that the amendment extends to security sale agreements and invoices for which payment remains outstanding, and permits settlement in either Turkish lira or foreign currency, subject to mutual agreement. The move is framed as a measure aimed at easing the foreign exchange burden on companies engaged in cross-border trade, smoothing the mechanics of commercial transactions, and dampening inflationary pressures across the broader economy.

Updated Discount Rate Applicable in Rediscount Transactions

As of 8 March 2025, the Central Bank of the Republic of Türkiye (“CBRT”) announced the annual discount interest rate to be applied in rediscount transactions based on bills with a maturity not exceeding three (3) months as 43.25%, and the interest rate to be applied in advance transactions as 44.25%.

A New Phase in the Digital Turkish Lira: R&D and Legal Framework by the CBRT

The CBRT, in a statement published within its official publication series, “Merkezin Güncesi,” announced that Phase-2 has been initiated in the Digital Turkish Lira Project and that R&D activities are ongoing. In this context, the focus is on usage models that do not require a bank account, system architectures operating independently from existing payment infrastructures, and programmable digital money designs.

With the transition to Phase-3, the completion of comprehensive pilot tests and preparations for the limited circulation of the Digital Turkish Lira are expected. The CBRT's approach in this area points to both independent and redundant systems on the technology side and a sustainable transformation within the financial system.

Foreign Exchange Sale Requirement for Export Proceeds Reduced to 25%

The CBRT reduced the obligation ratio for the sale of export proceeds to the CBRT in foreign exchange from 30% to 25% as of February 2025. The ratio, which had been increased from 25% to 40% in April 2022, was reduced to 30% in June 2024. With this change, which entered into force as of February 2025, the Export Circular and the Invisible Transactions Circular have been updated once again.

CBRT Signs Memorandum of Understanding with the State Bank of Pakistan

A Memorandum of Understanding was signed between the CBRT and the State Bank of Pakistan on 13 February 2025 to lay the groundwork for enhancing cooperation on central banking matters. The agreement aims to strengthen cooperation between the two central banks and to facilitate technical studies in the field of central banking.

Opening and Renewal of FX-Protected Deposit Accounts by Legal Entities Terminated

CBRT announcement No. 2025-12, dated 15 February 2025, announced that as of 15 February 2025, the opening of new accounts and the renewal of existing accounts by legal entities under all FX-Protected Deposit (“KKM”) accounts, including YUVAM accounts, will be terminated.

Implementation Guide on Financial Reporting in Hyperinflationary Economies Updated

The Public Oversight, Accounting, and Auditing Standards Authority has updated its Implementation Guide on Financial Reporting in Hyperinflationary Economies.

With this update, a new sample disclosure has been added for companies adjusting their financial statements for inflation effects under TMS 29 or BOBİ FRS Section 25. In line with the Board Resolution dated 26 October 2024, the update aims to guide practitioners through an example on how to present footnote disclosures regarding the Net Monetary Position Gains (or Losses) item.

The example regarding the presentation of footnote disclosures for the Net Monetary Position Gains (Losses) item can be accessed here.

The updated version of the guide can be accessed here.

New AML Compliance Regime for Online Marketplaces

As of 25 February 2025, a new regulation by Türkiye's Financial Crimes Investigation Board (“MASAK”) designates medium, large, and very large online marketplaces (electronic commerce intermediary service providers) as “obliged parties” for the first time. Under this regime, marketplaces are now responsible for verifying seller identities and tracking transactions. This includes confirming tax and trade registry records. Subject to certain conditions, such as payments processed through banks and identity verification via official databases, simplified, signature-free identity checks may be conducted electronically. The move marks a significant step in integrating e-commerce platforms into Türkiye's anti-money laundering framework.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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