The Communiqué of the Financial Crimes Investigation Board (No. 29) ("Communiqué"), issued by the Ministry of Treasury and Finance ("Ministry") pursuant to Article 26/A of the Regulation on Measures Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism ("Measures Regulation") and Article 13 of the Regulation on Compliance Programs Regarding Obligations Related to the Prevention of Laundering Proceeds of Crime and Financing of Terrorism ("Compliance Regulation"), was published in the Official Gazette dated 28 June 2025 and numbered 32940, and entered into force on the same date.
The Communiqué introduces the following enhanced measures to be implemented by crypto asset service providers in their relations with clients, as determined by the Ministry:
- Crypto asset service providers are required to obtain a transaction description from clients of no less than 20 characters in length for each crypto asset transfer transaction.
- When establishing a business relationship with clients or during other identity verification procedures, crypto asset service providers must, at a minimum, implement the following measures listed under Article 13(1) of the Compliance Regulation:
i. Obtain information, to the extent possible, regarding the source of the assets and funds subject to the transaction,
ii. Obtain information on the purpose of the transaction, and
iii. Enhance the number and frequency of controls applied to the business relationship and identify transaction types that require additional controls, in order to maintain close monitoring.
- In crypto asset transfers which are
i. conducted through wallet addresses not registered with any crypto asset service providers, or
ii. involving foreign crypto asset service providers or financial institutions that are not obligated to share user information,
then, the crypto asset service providers must execute users' crypto asset withdrawal requests no earlier than 48 hours following the relevant purchase, swap, or deposit transaction.
For users performing their first withdrawal, this period must be at least 72 hours. These time frames also apply to transfers made to other platforms.
- For withdrawals of stablecoins (including transfers to other platforms), crypto asset service providers must apply a daily limit of USD 3,000 and a monthly limit of USD 50,000. If the "travel rule" stipulated under Article 24/A(1) of the Measures Regulation is applied, these limits may be doubled.
- Provided that crypto asset service providers verify the client's transaction is conducted for liquidity provision, market making, or arbitrage purposes, and obtain board approval, the above-mentioned withdrawal timeframes and limits may be waived for that client. However, such clients must be continuously monitored, and if it is determined that the transaction does not fall within these categories, the restrictions must be applied immediately. In all cases, crypto asset service providers are obligated to apply all customer due diligence measures, regularly obtain documentation including account details and source of funds and take steps to prevent circumvention of time and limit restrictions.
- Transfers carried out by custodians on behalf of platform clients are also subject to the enhanced measures outlined in the Communiqué.
- The measures listed in the Communiqué will not apply to transfers between platforms and custodians arising from capital markets legislation.
- In the event of non-compliance with the enhanced measures set out under the Communiqué, penalties stipulated in Law No. 5549 on the Prevention of Laundering Proceeds of Crime will be applied.
You may access the full text of the Communiqué 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.
