The General Communiqué of the Financial Crimes Investigation Board numbered 29 ("Communiqué"), which was published in the Official Gazette dated 28 June 2025 and numbered 32940, sets forth the procedures and principles regarding a series of tightened measures to be implemented by crypto asset service providers.
With the introduction of the Communiqué, the primary aim is to prevent the use of crypto asset platforms for the laundering of criminal proceeds. In this context, new obligations have been introduced, particularly in the areas of withdrawal and transfer restrictions, source identification, and systemic risk control.
You can access the full text of the Communiqué here.
1. Time Restriction on Crypto Asset Withdrawal Transactions
With the Communiqué, it has been regulated that in crypto asset withdrawal transactions intermediated by platforms, including transfers to other platforms, the transfer of crypto assets may only be executed at least 48 hours after the purchase, exchange, or deposit of the crypto asset.
In cases of first-time crypto asset withdrawal transactions, this period shall be applied as at least 72 hours.
2. Limit Restriction on Stable Withdrawal Transactions
Pursuant to the Communiqué, for withdrawal transactions of crypto assets (stablecoins) that are designed to maintain a stable value by referencing one or more official currencies, other assets, rights, or a combination thereof, including transfers to other platforms, a limit of USD 3,000 per day and USD 50,000 per month has been established.
These limits may be doubled provided that the identification and verification obligations set forth in Article 24/A of the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism are fulfilled.
3. Requirement to Provide Transaction Details
Platforms are required to obtain a description of at least 20 characters explaining the nature of each crypto transfer from their customers.
4. Exception to Limit Restrictions
Platforms shall not be required to implement the tightened measures regarding withdrawal and transfer limit restrictions for crypto asset transfers that are confirmed to be conducted for the purposes of liquidity provision, market making, or inter-market arbitrage, provided that the following conditions are met and a separate board of directors' approval is obtained for each customer.
Within this scope, platforms are obliged to:
- to take all measures to identify the customer,
- Periodically obtain documentation, including information on the source of assets and account details held with banks or other platforms.
The Communiqué emphasizes that platforms that do not implement measures within this scope are under an obligation to continuously monitor and control their customers.
5. Custodian Institutions
The restrictions set forth in the Communiqué shall not apply to transfers carried out between platforms and custodian institutions arising from capital markets legislation; however, it is stated that transfers to be executed by custodian institutions on behalf of or for the account of platform customers shall be subject to these provisions.
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.
