A. Introduction
On 1 August 2025, the Financial Crimes Investigation Board ("MASAK") announced that a Draft Communiqué ("Draft Communiqué") has been prepared with the objectives of enhancing transparency in Electronic Funds Transfers (EFT), domestic money transfers, and cash transactions conducted through financial institutions; preventing unrecorded economic activities; strengthening the security and integrity of the financial system; and ensuring alignment with the standards of the Financial Action Task Force ("FATF").
The Draft Communiqué introduces a tiered approach to cash transactions conducted through financial institutions, starting with a declaration and, for high-value transactions, requiring submission of a Cash Transaction Declaration Form together with supporting documentation. The Draft Communiqué can be accessed here.
B. Key Provisions of the Draft Communiqué
1. Obligation to Provide Transaction Purpose Options in Electronic Funds Transfers and Domestic Money Transfers
Pursuant to the Draft Communiqué, banks as well as payment and electronic money institutions are required to offer customers, in electronic funds transfers and domestic money transfers, the most frequently used transaction types as selectable options for the purpose of declaring the nature of the transaction.
In addition, for electronic funds transfers and domestic money transfers, the options to be provided for the declaration of the transaction purpose shall, at a minimum, include the following, in addition to the headings determined by the Central Bank of the Republic of Türkiye for electronic transfers;
- Real estate purchase payment,
- Motor vehicle purchase payment,
- Lending / debt repayment,
- Gift / donation / aid,
- Tax / duty / fee payment,
- Compensation / insurance payment,
- Legal/consultancy/advisory service payment, healthcare payment
- Crypto / digital asset,
- Gambling / betting payment,
- Entertainment / social media payment
The inclusion of these headings is mandated.
In cases where the options presented to the customer include other general-purpose categories such as "other" or "personal payment" that do not contain specific information regarding the nature of the transaction, it is stipulated that a transaction description of at least 20 characters in length must be obtained concerning the nature of the transaction.
2. Obligation to Declare Transactions Categorized According to Transaction Limits
Pursuant to the Draft Communiqué, depending on the amount of the cash transaction, the Cash Transaction Declaration Form annexed to the Draft Communiqué must be completed by the customer.
Within this scope, the Cash Transaction Declaration Form may be approved by signing the transaction receipt, or via internet/mobile banking, SMS one-time password (OTP), digital link, or telephone banking. In cases where it is not possible to obtain documentation regarding the nature of the transaction, the form must be completed by the customer or the person conducting the transaction on behalf of the customer, and an explanation of at least 50 characters must be provided.
i) Cash Transactions Between TRY 200,000 and TRY 2,000,000
For cash transactions where the transaction amount, or the aggregate amount of multiple related transactions, is between TRY 200,000 and TRY 2,000,000, financial institutions are required to offer customers the most frequently used transaction types as selectable options for the purpose of declaring the nature of the transaction.
Where such options include general-purpose categories, such as "other" or "personal payment," that do not contain specific information regarding the nature of the transaction, and such categories are selected by the customer, it is stipulated that a transaction description of at least 20 characters in length must be obtained regarding the nature of the transaction.
ii) Cash Transactions Between TRY 2,000,001 and TRY 20,000,000
For cash transactions where the transaction amount, or the aggregate amount of multiple related transactions, is between TRY 2,000,001 and TRY 20,000,000, financial institutions are obligated to ensure that the Cash Transaction Declaration Form annexed to the Draft Communiqué is completed for the purpose of declaring the nature of the transaction.
Where the Cash Transaction Declaration Form includes general-purpose categories, such as "other" or "personal payment," that do not contain specific information regarding the nature of the transaction, and such categories are selected by the customer, it is stipulated that a transaction description of at least 20 characters in length must be obtained regarding the nature of the transaction.
iii) Cash Transactions Exceeding TRY 20,000,000
Pursuant to the Draft Communiqué, for cash transactions exceeding TRY 20,000,000, it is stipulated that the Cash Transaction Declaration Form must be completed with a detailed explanation and accompanied by the relevant supporting documentation.
3. Cases Where the Declaration Requirement Does Not Apply
The Draft Communiqué stipulates that the following transactions shall not be subject to the declaration obligation:
- Transactions conducted between a customer's own accounts within the same financial institution,
- Transactions where the customer is a public institution or organization,
- Transactions conducted between banks where the customer is a bank,
- Transactions carried out within the scope of correspondent banking,
- Electronic funds transfers and domestic money transfers conducted via ATMs not exceeding TRY 15,000,
- Cash transactions conducted via ATMs where the transaction amount, or the aggregate amount of multiple related transactions, does not exceed TRY 200,000.
4. Applicable Sanctions
The Draft Communiqué stipulates that, in cases of non-compliance with the provisions set out therein, the penalties provided for under the Law No. 5549 on the Prevention of Laundering Proceeds of Crime, dated 11 October 2006, shall be applied to the obliged parties.
C. Concluding Remarks
The Draft Communiqué aims to enhance transparency in high-value cash and electronic funds transfer transactions, prevent unrecorded economic activity, and combat the laundering of criminal proceeds; and, through the prescribed thresholds and declaration requirements, seeks to strengthen the reliability of the financial system and ensure compliance with FATF standards.
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.
