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20 October 2025

MASAK General Communiqué On The Compliance Officer License Has Been Published

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The Financial Crimes Investigation Board General Communiqué (No: 30) ("Communiqué") was published by the Ministry of Treasury and Finance in the Official Gazette dated September 9, 2025 and numbered 33012...
Turkey Corporate/Commercial Law
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The Financial Crimes Investigation Board General Communiqué (No: 30) ("Communiqué") was published by the Ministry of Treasury and Finance in the Official Gazette dated September 9, 2025 and numbered 33012, and entered into force as of its publication date.

The Communiqué sets forth regulations regarding the examination, training, licensing processes, and the Compliance Officer Registry, aimed at assessing the professional competence of those to be authorized as compliance officers or deputies before the obliged parties listed under Article 4 of the Regulation on Measures Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism.

Authorization Exam, Application Requirements and Criteria

Pursuant to the Communiqué, information regarding the scope of the authorization exam ("Exam") applicable to compliance officers and deputies, as well as the place and date of the Exam and the application period, will be announced on the official website of the Presidency of the Financial Crimes Investigation Board ("Presidency"). The Exam will be administered either directly by the Presidency or by other institutions and organizations designated by the Presidency.

To be eligible to apply for the Exam, candidates must:

  1. Be a citizen of the Republic of Türkiye,
  2. Not be deprived of public rights,
  3. Not have been convicted of the crimes specified under Article 4/5(c) of the Communiqué or of participation in such crimes,
  4. Have graduated from at least a four-year higher education institution in Türkiye or from a foreign institution of higher education recognized as equivalent by the Turkish Council of Higher Education ("YÖK").

The Exam will include questions on subjects falling within the scope of the Presidency's mandate, and the subject headings will be specified in the exam announcement. The Exam may be administered in multiple-choice format, either electronically or in person, and may consist of one or more modules. The minimum passing score for the Exam is 65 out of 100 in any case; in the event the Exam is held in multiple modules, candidates must score at least 50 points in each module, with the passing grade calculated on the basis of the average.

In addition, in cases of false statements, cheating, substitution, or violations of the rules, the candidate's exam will be deemed invalid. Candidates whose exams are annulled for reasons other than rule violations will be prohibited from taking the Exam for a period of 3 years.

Objections regarding invalidity and results may be filed within 7 days from the date of notification, and such objections shall be resolved within no later than 15 days from the date of application.

The first Exam will be administered by the Presidency on October 18, 2025, and information regarding the Exam has been announced on the Presidency's official website.

Compliance Officer License ("License")

Candidates who pass the Exam and meet the above-mentioned requirements shall be deemed authorized as compliance officers or deputies upon applying online to the Presidency and obtaining the License. However, individuals who have served for at least 4 years as administrators at the Presidency, or who have served for a total of 12 years either as Treasury and Finance Experts (including time spent as assistants) or as audit staff, shall be granted a License without taking the Exam.

In addition, License holders are required to undergo renewal training every 3 years and submit documents to the Presidency proving that they continue to meet the aforementioned requirements. Otherwise, their Licenses shall be suspended, and this status shall be recorded in the Compliance Officer Registry.

For renewal training to be deemed successfully completed, participation in at least 90% of the total training period is mandatory. However, those who have been granted a License without taking the Exam by virtue of serving at the Presidency for certain periods are not required to attend renewal training for as long as they remain employed at the Presidency.

Individuals whose Licenses have been suspended may reapply to the Presidency by completing the renewal training and fulfilling the requirements; however, in any case, the application period may not exceed 5 years from the date of the successfully passed Exam or the completion date of the last training.

In the event of suspension of the License, those who fail to apply within the 5-year period, lose the required qualifications, or are found to have engaged in acts contrary to the integrity and reputation required by the profession shall have their License revoked by the Presidency and removed from the Compliance Officer Registry, and this situation shall be notified to the obliged party employing the individual.

Compliance Officer Registry

The identity information of the license holder, license number, details regarding license renewal training, as well as information on the date, place, and results of the examination shall be recorded by the Presidency in an electronic registry. Obligated parties are required to check the registration and license status of individuals in this Compliance Officer Registry both prior to and during employment. Records in the Compliance Officer Registry shall be kept confidential in accordance with the legislation on the protection of personal data.

Confidentiality and Exam Participation Ban

Individuals involved in the examination, licensing, and registry processes are obliged to keep any personal information and secrets they obtain confidential, even after leaving their duties, and may not use such information for personal gain.

In addition, members of the Exam Committee and those who prepare exam questions are prohibited from taking the Exam during their term of duty and for a period of 2 years thereafter.

Exclusively Employed Compliance Officers

Finally, pursuant to Article 29 of the Regulation on the Compliance Program Regarding Obligations for the Prevention of Laundering Proceeds of Crime and Financing of Terrorism, those who are exclusively employed as compliance officers but have not graduated from at least a 4 year higher education institution in Türkiye or abroad recognized as equivalent by YÖK may sit for the Exams opened until 25 December 2025, provided that their employment is documented with Social Security Institution (SGK) records.

Those who, as of 25 December 2025, have been serving in this role for at least 6 months may sit for the Exams opened until 25 December 2027. Such candidates, if successful and fulfilling the other requirements set forth in the Communiqué, will be eligible to obtain the License.

The full text of the Regulation is available here. (Only Available in Turkish)

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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