According to the announcement of the Financial Crimes Investigation Board ("MASAK") dated 30 September 2025 (the "Announcement"), the "Guide for Crypto Asset Service Providers" (the "Guide") — prepared to clarify the obligations of crypto asset service providers ("KVHS") within the framework of Law No. 5549 on the Prevention of Laundering Proceeds of Crime, Capital Markets Law No. 6362 and the relevant legislation— has been updated and published.
The Guide sets out comprehensive provisions regarding:
- Customer due diligence (CDD), including customer identification and verification (KYC) processes;
- Remote identification methods and enhanced due diligence (EDD) measures;
- Implementation of the "Travel Rule";
- Timeframes and amount thresholds applicable to crypto-asset transfers;
- Measures to be taken in business relationships with politically exposed persons (PEPs);
- Obligations on suspicious transaction reporting, the provision of information and documents, and compliance programs.
Furthermore, the Announcement emphasizes that it is of critical importance, for the prevention of the misuse of the financial system for illicit activities, that KVHS fully implement the obligations and measures set out in the Guide within the framework of a risk-based approach.
Video Call Requirement for Onboarding New Customers
In the Guide, the technical requirements for the remote identification process are defined as follows:
- The process must be conducted online, uninterrupted, by video, and in real time.
- Methods must be used to verify the authenticity of the identification document and the liveness of the individual.
- The entire process must be recorded, remain auditable, and be retained.
Accordingly, a video-based, live, interactive verification process has been established as the standard for remote identity verification.
You may access the CASP Compliance Guide here and the MASAK updates here.
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.
