Edit Analysis - Turkey

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Executive Summary

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Landmark Laws

**Law on Amendments to the Capital Markets Law (Law No. 7518)** (Law No. 7518) - Enacted: 2024-07-02
  - Brought crypto assets under the scope of the Capital Markets Law No. 6362. Defined 'Crypto Asset Service Providers' (CASPs), mandated licensing by the CMB, and established penalties for unauthorized operations.
  - [Source](https://www.resmigazete.gov.tr/eskiler/2024/07/20240702-1.htm)

**Communiqué on the Principles Regarding the Establishment and Activities of Crypto Asset Service Providers** (Communiqué No. III-35/B.1) - Enacted: 2025-03-13
  - Detailed the requirements for establishment, shareholding structure, and operational principles for CASPs.
  - [Source](https://spk.gov.tr/)

**Communiqué on Operational Procedures and Capital Adequacy of Crypto Asset Service Providers** (Communiqué No. III-35/B.2) - Enacted: 2025-03-13
  - Set forth capital adequacy standards, information system requirements, and custody rules.
  - [Source](https://spk.gov.tr/)

**Regulation on the Disuse of Crypto Assets in Payments** (Official Gazette No. 31456) - Enacted: 2021-04-16
  - Prohibits the use of crypto assets for payments in the provision of goods and services; bans payment service providers from developing business models for such use.
  - [Source](https://www.resmigazete.gov.tr/eskiler/2021/04/20210416-4.htm)

Considerations

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Detailed Explanation

Retail cryptocurrency trading is legal and fully regulated in Turkey. The foundational regulatory shift occurred with the enactment of Law No. 7518 on July 2, 2024, which amended the Capital Markets Law to bring crypto assets under formal oversight. This law defined Crypto Asset Service Providers (CASPs) and mandated that they obtain a license from the primary regulator, the Capital Markets Board (CMB/SPK). The regulatory framework was further solidified in March 2025 with the issuance of two key communiqués: the Communiqué on the Principles Regarding the Establishment and Activities of Crypto Asset Service Providers (No. III-35/B.1) and the Communiqué on Operational Procedures and Capital Adequacy of Crypto Asset Service Providers (No. III-35/B.2). These detailed the licensing requirements, shareholding structures, capital adequacy standards, information system rules, and custody obligations, including the segregation of client assets and the holding of customer cash in authorized banks. The Financial Crimes Investigation Board (MASAK) enforces Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) rules, with a strict implementation of the FATF Travel Rule for transactions over 15,000 TRY effective February 2025. A notable technical oversight role is held by the Scientific and Technological Research Council of Turkey (TÜBİTAK), which audits the technological infrastructure of CASPs. A critical restriction within this otherwise permissive framework is the enduring ban on using crypto assets for payments, established by the Regulation on the Disuse of Crypto Assets in Payments enacted on April 16, 2021. This prohibits the direct use of crypto to pay for goods and services, effectively treating it solely as an investment asset. Foreign platforms are also required to establish a local entity and obtain authorization, with unauthorized platforms having been mandated to cease targeting Turkish residents by October 2024.

Bullet Points

**I. Regulatory Status**
*   Retail cryptocurrency trading is *Allowed-Regulated*.
*   The activity is fully legal under a comprehensive licensing regime established in 2024-2025.

**II. Key Regulatory Bodies**
*   **Capital Markets Board (CMB/SPK)**: Primary regulator responsible for licensing, supervision, and issuing secondary regulations for Crypto Asset Service Providers (CASPs).
*   **Financial Crimes Investigation Board (MASAK)**: AML/CFT authority enforcing KYC and transaction monitoring rules.
*   **Scientific and Technological Research Council of Turkey (TÜBİTAK)**: Conducts technical audits of CASP infrastructure.

**III. Important Legislation**
*   **Law on Amendments to the Capital Markets Law (Law No. 7518)**: Enacted July 2, 2024. Brought crypto assets under capital markets law, defined CASPs, and mandated CMB licensing.
*   **Communiqué on the Principles Regarding the Establishment and Activities of Crypto Asset Service Providers (No. III-35/B.1)**: Enacted March 13, 2025. Details establishment, shareholding, and operational principles for CASPs.
*   **Communiqué on Operational Procedures and Capital Adequacy of Crypto Asset Service Providers (No. III-35/B.2)**: Enacted March 13, 2025. Sets capital adequacy, IT system requirements, and custody rules.
*   **Regulation on the Disuse of Crypto Assets in Payments**: Enacted April 16, 2021. Prohibits the use of crypto assets for payments for goods and services.

**IV. Compliance Requirements**
*   **Licensing**: Mandatory CMB authorization for all CASPs.
*   **Foreign Platforms**: Must establish a local legal entity in Turkey to operate.
*   **Capital & Governance**: Must meet strict capital adequacy and corporate governance standards.
*   **Custody & Segregation**: Client crypto assets must be segregated; customer cash must be held in authorized banks.
*   **AML/CFT**: Strict KYC enforcement and implementation of the FATF Travel Rule (for transactions over 15,000 TRY) under MASAK oversight.
*   **Technical Audit**: Infrastructure must pass audits conducted by TÜBİTAK.

**V. Notable Restrictions or Limitations**
*   **Payment Ban**: The use of crypto assets for payments in exchange for goods and services is *explicitly prohibited*.
*   **Unauthorized Operations**: Providing services without a CMB license is illegal.

**VI. Recent Developments or Notes**
*   The comprehensive regulatory framework based on Law No. 7518 and the 2025 communiqués is a recent development.
*   Unauthorized foreign platforms were required to cease targeting Turkish residents by October 2024.
*   Turkey has one of the highest crypto adoption rates globally; regulation focuses on controlling intermediaries while protecting the traditional payments system.

Full Analysis Report

Complete markdown report for this analysis

As of December 2025, Turkey has transitioned from a 'Gray-Zone' to a fully 'Allowed-Regulated' jurisdiction for retail cryptocurrency trading. The regulatory landscape was fundamentally transformed by the enactment of Law No. 7518 on July 2, 2024, which amended the Capital Markets Law to explicitly include crypto assets. This primary legislation empowered the Capital Markets Board (CMB/SPK) to oversee the sector, requiring all Crypto Asset Service Providers (CASPs) to obtain a license to operate. The law provided a transition period where existing exchanges had to apply for liquidation or authorization by August 2024, and foreign platforms were barred from soliciting Turkish residents without a local presence after October 2024.

The regulatory framework was completed with the publication of secondary legislation in March 2025. The 'Twin Communiqués' (III-35/B.1 and III-35/B.2) established rigorous standards for CASPs, including minimum capital requirements (paid-in capital), governance structures (joint-stock company requirement), and technological audits by TÜBİTAK. These regulations ensured that only financially stable and technically secure entities could obtain permanent licenses. A 'List of Active Providers' is maintained by the CMB, serving as the official register of authorized entities during the transition to full licensure.

Despite the robust support for trading and investment, the Central Bank's 2021 ban on using crypto assets for *payments* remains strictly in force. This means retail users cannot legally pay for goods or services (like coffee or cars) using Bitcoin or stablecoins. However, the banking sector is fully integrated for fiat on/off-ramps, and banks are the mandated custodians for the cash portion of client assets held by CASPs. This separation of trading (allowed) and payments (banned) is a defining feature of the Turkish model.

Enforcement has been active, with the CMB blocking access to unauthorized foreign platforms and DeFi sites that failed to comply with the local presence requirement. Anti-Money Laundering (AML) compliance is enforced by MASAK, with new rules implemented in February 2025 requiring identity verification for transactions exceeding 15,000 TRY. Taxation follows general income tax principles, treating crypto gains as taxable income, though discussions regarding a dedicated low-rate transaction tax continue to surface in legislative debates.

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Edit: Turkey

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