Amendments To The General Communiqué Of The Financial Crimes Investigation Board

The Ministry of Treasury and Finance's Communiqué (Serial No: 31), amending the General Communiqué of the Financial Crimes Investigation Board (Serial No: 5) ("Communiqué"), has been published in the Official Gazette on 7 January 2026 and, entered into force as of the same date save for the exceptional obligations set out below.

With the amendments introduced under the Communiqué, the procedures applicable to customer identification have been updated, and new regulatory measures have been introduced in financial transactions to strengthen the framework for the prevention of money laundering and the financing of terrorism.

Measures Regarding the Risk of Money Laundering and Financing of Terrorism

Pursuant to the amendments introduced under the Communiqué, the simplified measures by means of applying the reduced customer identification, customer due diligence and monitoring obligations under the Regulation on Measures for the Prevention of Laundering Proceeds of Crime and Financing of Terrorism ("Regulation") in relation to customers and transactions assessed as in low risk of money laundering and financing of terrorism, shall not be applied to cases where the customer is a foreign politically exposed person in addition to the transactions assessed as risky.

Amendments Regarding Insurance Contracts

The Communiqué has been amended so as to extend its scope to cover insurance contracts other than life insurance. Accordingly, in relation to indemnity and compensation payments to be made by insurance and pension companies to third parties other than the policyholder or the insured:

• the identity information (name and surname, date of birth, nationality; Turkish identification number for Turkish nationals and foreign identification number for foreign nationals) must be verified through queries conducted via the database of the General Directorate of Civil Registration and Citizenship Affairs of the Ministry of Interior; and
• the payments must be made through a bank account consistent with the identity information of the relevant third party,

and where these conditions are satisfied cumulatively, the verification of identity information and the collection of a specimen signature in accordance with the procedures set out under the relevant provisions of the Regulation will not be required.

Amendments regarding Entities Exclusively Conducting Games of Chance and Betting Activities in Electronic Environment

The obliged parties conducting gaming and betting transactions precisely through electronic environment, are required to apply procedure for customer identity information verification prior to customer onboarding in order to commence the customer onboarding and the provision of services.

The regulations concerning such customer due diligence procedures will be effective as as of 1 February 2026.

In this context, fund transfer must be made from a bank account matching with the identity information of the prospective customer to a verification account established by the obliged party for this purpose. Customer onboarding and commencement of services may not be made until after such transfer has been carried out.

Furthermore, the principle that all collections and payments within the scope of gaming and betting transactions must be made via bank accounts held by verified customers and that are matching with their identity information has been established; and the previous practice allowing collections and payments to be made via credit card accounts has been abandoned.

Amendments regarding Electronic Commerce Intermediary Service Providers

A customer identity verification mechanism similar to the one introduced for obliged parties conducting gaming and betting transactions has also been adopted in respect of electronic commerce intermediary service providers. In this context, a fund transfer must be made from a bank account or credit card account matching with the identity information of the prospective customer to a verification account established by the obliged party for this purpose. Customer onboarding and commencement of services may not be made until after such transfer has been carried out.

As in the case of obliged parties conducting gaming and betting transactions, these obligations for electronic commerce intermediary service providers will enter into force as of 1 February 2026.

Identification Requirements for Bank Accounts Opened upon the Request of Public Authorities and Institutions for the Purpose of Making Mandatory Payments

Regarding the bank accounts opened upon the written request of public authorities and institutions for the purpose of making mandatory payments to beneficiaries pursuant to the relevant legislation, provided that customer identification is verified in accordance with the below mentioned relevant provisions of the Regulation no later than prior to the payment to the beneficiary:

• for real persons, the collection of the name and surname, date of birth and nationality, and the Turkish identification number for Turkish nationals or the foreign identification number for foreign nationals;
• for legal entities, the collection of the trade name, trade registry number and tax identification number; and
• the verification of identity information through queries conducted via the database of the General Directorate of Civil Registration and Citizenship Affairs of the Ministry of Interior,

the verification of identity information in accordance with the procedures set out under Article 6 of the Regulation and the collection of a specimen signature will not be required. Nevertheless, the use of such bank accounts will only be permitted once the customer identification process has been completed.

Also, it has been foreseen that in respect of such accounts that the obligations set out under Articles 17 and 17/A of the Regulation regarding acting on behalf of another person and the identification of the customer and the beneficial owner may not be applicable. In this context, obliged parties may be exempt from the requirements relating to the issuance of relevant notices, the collection of written declarations, and the measures aimed at identifying the beneficial owner.

In addition to the foregoing exemptions, with respect to bank accounts to be opened upon the written request of public authorities and institutions for the purpose of making mandatory payments to beneficiaries, the frequency of ongoing monitoring of the customer within the scope of a continuous business relationship and the updating of customer-related information, documents and records pursuant to Article 19 of the Regulation may be reduced.

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.