The Regulation Amending ("Amending Regulation") the Regulation on Program of Compliance with Obligations of Anti-Money Laundering and Combating the Financing of Terrorism ("Compliance Program Regulation"), prepared by the Ministry of Treasury and Finance ("Ministry"), was published in the Official Gazette dated 22 August 2025 and numbered 32994 and entered into force.
The Amending Regulation introduced significant amendments to the Compliance Program Regulation regarding the scope of obligors, the qualifications required for compliance officers and their deputies, as well as the procedures for their appointment, dismissal, and resignation.
1. Amendments Regarding the Compliance Program Obligors
Under the Amending Regulation, the scope of obligors required to establish a compliance program has been revised whereby development and investment banks have been included among the obligors, while İstanbul Takas ve Saklama Bankası A.Ş. has been excluded. In this regard, it has been set forth that development and investment banks shall appoint their compliance officer and deputy by 31 October 2025 and establish their compliance programs by 30 November 2025.
In addition, dealers conducting all games of chance and betting activities exclusively through electronic means have been required to appoint a compliance officer at administrative level by 31 October 2025, without the requirement of establishing a compliance program.
2. Written Notification to the Presidency in Case of Dismissal or Resignation of Compliance Officer
Pursuant to the Amending Regulation, it is required that in the event of dismissal or resignation of a compliance officer or deputy, such circumstance shall be notified in writing to the Financial Crimes Investigation Board Presidency ("Presidency") within 10 days, together with underlying reasons, both by the said compliance officer or deputy and by the relevant obligor.
3. Amendments to the Qualifications Required for Compliance Officers
Under the Amending Regulation, as of 25 December 2025, individuals authorized as compliance officers following a certain period of service at the Presidency shall not be eligible for appointment as a compliance officer or deputy at obligors that they had audited or inspected within 2 years prior to their appointment.
Additionally, effective as of 25 December 2025, individuals to be appointed solely as compliance officers, without the obligation to prepare a compliance program, are required to have graduated from higher education institutions in Türkiye (or from equivalent institutions abroad recognized by the Council of Higher Education – YÖK) providing at least 4 years of education. However, those who have served as compliance officers for a minimum period of 6 months without meeting this requirement shall be entitled to continue their duties for a period of 2 years, during which they will be entitled to take the authorization exam and, if successful, obtain a Compliance Officer License and continue their duties.
The full text of the Amending Regulation may be accessed through this link. (only available in Turkish)
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