Türkiye AML/CFT Guide

Türkiye has a large, bank-dominated financial sector and sits on trade and transit routes between Europe, the Middle East, the Caucasus and Central Asia. The FATF’s 2026 report describes it as a regional trade, transit and financial hub. At the end of 2024, financial-sector assets were about TRY 43.2 trillion, and 63 banks held 75.65% of them. The same report counts 773 exchange offices, 89 payment and e-money institutions and 58 crypto-asset service providers. Türkiye is also one of the region’s largest crypto markets: Chainalysis estimated that it received close to USD 200 billion on-chain in a year, the most in the Middle East and North Africa.

The regime is built on the Law on the Prevention of Laundering Proceeds of Crime (Law No. 5549), the Turkish Penal Code, which defines the laundering offence in Article 282, the Law on the Prevention of the Financing of Terrorism (Law No. 6415) and the Law on the Prevention of the Financing of Proliferation of Weapons of Mass Destruction (Law No. 7262). Detailed rules sit in the Regulation on Measures, the Regulation on the Compliance Programme and MASAK’s numbered General Communiqués.

How the regime fits together

• Policy and coordination. The Coordination Board for Combating Financial Crimes, chaired by a Deputy Minister of Treasury and Finance, brings together MASAK, supervisors, police, intelligence, customs and the justice and foreign ministries. A 2026–2030 national AML/CFT strategy was announced in July 2026.
• Financial intelligence and supervision. MASAK, part of the Ministry of Treasury and Finance, is both the financial intelligence unit and the AML/CFT supervisor for every obliged sector. Sector regulators license and prudentially supervise firms, and their examiners also carry out AML/CFT inspections.
• Reporting. Obliged parties send suspicious transaction reports to MASAK, which analyses them and passes cases to prosecutors.
• Enforcement. Prosecutors lead investigations with the police and gendarmerie, the courts convict and confiscate, and MASAK imposes administrative fines for breaches of preventive duties.

Key milestones

1. October 2006

   Law No. 5549 is adopted and becomes the core AML law, building on MASAK’s work since 1997.

2. February 2013

   Law No. 6415 on terrorist financing is adopted, after the FATF warned it could suspend Türkiye’s membership.

3. October 2014

   The FATF ends its first period of monitoring of Türkiye, which began in 2010.

4. December 2019

   The FATF publishes Türkiye’s fourth-round mutual evaluation.

5. December 2020

   Law No. 7262 creates a proliferation-financing framework and tightens penalties under Law No. 5549.

6. October 2021

   The FATF places Türkiye under increased monitoring (the grey list).

7. June 2024

   Türkiye is removed from the grey list. In July, Law No. 7518 brings crypto-asset service providers under Capital Markets Board licensing.

8. September 2026

   The FATF publishes Türkiye’s fifth-round evaluation and places it in enhanced follow-up.

What has changed recently

• Higher thresholds. From 7 October 2026, the identification threshold for occasional transactions doubled to TRY 370,000, and the wire and crypto-asset transfer threshold doubled to TRY 30,000.
• Crypto-asset controls. A Travel Rule for crypto-asset transfers has applied since February 2025. Since June 2025, MASAK has required withdrawal holds and stablecoin transfer limits at crypto-asset service providers.
• Compliance officers. Since 2025, compliance officers must pass a MASAK exam, hold a licence and appear on MASAK’s register.
• Remote onboarding. MASAK rules issued in 2026 add a verification transfer before some remote customers are accepted and allow remote onboarding of foreign nationals using a chip passport and video call.
• Account suspensions. Since December 2025, banks, payment institutions and crypto-asset service providers can suspend an account for up to 48 hours on reasonable suspicion of certain fraud and cyber-theft offences, pending a seizure order.

The framework combines a core preventive law, criminal offences in the Penal Code and separate laws on terrorist and proliferation financing. Presidential decisions set the regulations, and MASAK issues numbered General Communiqués that carry most of the practical detail. Laws and regulations are published in the Official Gazette (Resmî Gazete), and consolidated texts are on the official legislation portal, mevzuat.gov.tr.

Primary laws

Regulations and MASAK rules

Key guidance

• MASAK sector guides on suspicious transaction reporting, including the guide for banks and the postal service (version 2.0, May 2024)
• MASAK’s compliance guide for crypto-asset service providers, covering identification, the Travel Rule and reporting
• The English translation of the Regulation on Measures on MASAK’s website
• Summaries of the national risk assessment published by the Ministry of Treasury and Finance

Türkiye uses a single AML/CFT supervisor model. MASAK supervises every obliged sector for AML/CFT. Sector regulators license firms and supervise them prudentially, and examiners from several bodies carry out AML/CFT inspections that MASAK can use to impose fines.

Supervisors

The financial intelligence unit: MASAK

• Status. MASAK operates within the Ministry of Treasury and Finance and has worked as Türkiye’s financial intelligence unit since 1997.
• Reports. It receives suspicious transaction reports and other reports from obliged parties through MASAK.Online. Access is given to each obliged party’s compliance officer and deputy.
• Analysis. The FATF found that MASAK has direct access to more than 300 databases and rated Türkiye’s use of financial intelligence as substantially effective.
• Powers. MASAK can request information from obliged parties and public bodies. The minister can suspend a suspicious transaction for up to seven working days.
• Supervision and fines. MASAK sets AML/CFT rules and fines obliged parties for breaches. Examiners include tax inspectors, MASAK experts, sworn bank auditors and staff of the sector supervisors.

Who investigates and prosecutes

Public prosecutors lead criminal investigations into laundering and terrorist financing and apply for seizure and confiscation. They work with:

• the National Police and the Gendarmerie, which investigate financial crime
• the Ministry of Justice, which handles mutual legal assistance with other countries
• the Ministry of the Interior, which oversees associations and other non-profit organisations
• the Ministry of Trade’s customs enforcement, which handles cash and goods at the border
• the courts, which convict, confiscate and review asset freezes
• MASAK, which sends case files to prosecutors and can file criminal complaints

Targeted financial sanctions

• Freeze without delay. Check new Official Gazette freezing decisions and UN Security Council list changes every day, and freeze matched assets at once.
• Known gap. The FATF found that UN listings took about 2.5 days on average to take effect in Türkiye because they must first be transposed into a Presidential decision. A draft to allow temporary freezes in the meantime was announced in March 2026.
• Other lists. Firms with US dollar or euro business, or US or EU counterparties, should also consider US and EU sanctions lists, which can affect them through those relationships.

AML/CFT obligations apply to obliged parties (yükümlüler) listed in Article 4 of the Regulation on Measures. The list is wider than the FATF standard: it includes, for example, car dealers, cargo companies, sports clubs and lottery and betting operators. It covers Turkish branches of foreign firms and, where local law allows, foreign branches of Turkish firms.

Financial institutions

• Banks, including participation (Islamic) banks and development and investment banks
• Payment institutions, electronic money institutions and non-bank card issuers
• Exchange offices, precious-metals intermediaries and the precious-metals activities of Borsa İstanbul
• Financing, factoring, financial leasing, savings finance and asset management companies
• Brokerage houses, portfolio management companies, investment trusts and clearing and custody institutions
• Insurers, reinsurers, pension companies and insurance brokers, and the postal service (PTT) and cargo companies

Banks, brokerage houses, insurers, payment and e-money institutions, exchange offices and crypto-asset service providers, among others, must run a full compliance programme with a licensed compliance officer. Some others, such as cargo companies and online betting dealers, must appoint a compliance officer without a full programme.

Designated non-financial businesses and professions

Casinos are prohibited in Türkiye. There is no separate category for trust and company service providers. The FATF found that supervision of lawyers and notaries is limited.

Crypto-asset service providers

• AML duties. Crypto-asset service providers have been obliged parties since May 2021 and are treated as financial institutions since December 2024. They must run a full compliance programme.
• Licensing. Under Law No. 7518, they need a licence from the Capital Markets Board (SPK). The FATF counted 58 in scope at the time of its 2025 visit.
• Extra controls. They must apply the Travel Rule, withdrawal holds and stablecoin transfer limits, and must not allow remote onboarding for privacy-coin services.

Quick check: are you an obliged party?

1. Does your firm hold a licence from BDDK, TCMB, SPK or SEDDK, or from the Ministry of Treasury and Finance as an exchange office or precious-metals intermediary?
2. Do you trade or broker real estate, precious metals, jewellery, vehicles or art, or work as a notary, freelance lawyer, accountant or auditor in a covered activity?
3. Do you provide crypto-asset exchange, custody or transfer services to customers in Türkiye?

If any answer is yes, check Article 4 of the Regulation on Measures and the Regulation on the Compliance Programme to confirm your duties and whether you need a compliance officer.

These are the main duties for obliged parties. Sector supervisors and MASAK communiqués add detail for particular sectors, so always check the rules that apply to your firm.

Key numbers

Read these with the rules below. Thresholds are set by Presidential decision and can change at short notice.

What you must do

Penalties

• Administrative fines. Under Article 13 of Law No. 5549, the base fines are TRY 30,000 per identification breach and TRY 50,000 per reporting breach. They double for financial institutions, with a minimum of 5% of the transaction amount, and are revalued every January.
• Compliance failures. A firm that fails to run its compliance programme receives a written warning and at least 30 days to fix it, then a fine. Persistent failure can lead to restrictions or loss of licence.
• Criminal offences. Tipping off, failing to provide information and breaching record-keeping duties carry one to three years’ imprisonment and a judicial fine.
• Example. In December 2021, MASAK fined Binance TR TRY 8 million, the first fine on a crypto-asset platform.

Türkiye is a member of the FATF in its own right, not through a regional body, and is assessed by the FATF directly. It has been under increased monitoring twice: from 2010 to 2014, and from 2021 to 2024.

Current status

The 2026 mutual evaluation

• Process. The FATF’s fifth-round on-site visit took place in November 2025. The report was adopted at the June 2026 plenary and published on 23 September 2026.
• Technical compliance. R.7 (proliferation-financing sanctions) and R.8 (non-profit organisations) are partially compliant. All other Recommendations are compliant or largely compliant, with none non-compliant.
• Effectiveness. Substantial for risk and coordination (IO.1), international cooperation (IO.2) and financial intelligence (IO.6). Moderate for the other eight outcomes, including supervision, preventive measures, beneficial ownership, prosecution, confiscation and sanctions.
• Strengths. Good understanding of risk overall, a central and well-resourced financial intelligence unit, and a large number of laundering prosecutions.
• Weaknesses. A backlog of laundering cases, few complex cases involving professionals, modest confiscation and limited recovery of assets abroad, weak verification of beneficial ownership, limited supervision of lawyers and notaries, and sanctions that do not always apply without delay.

How the ratings changed

1. December 2019: fourth-round report

   11 compliant, 17 largely compliant, 10 partially compliant and 2 non-compliant (R.7 and R.12 on PEPs). Effectiveness was substantial for IO.1 and IO.2, low for IO.10 and IO.11, and moderate for the rest.

2. November 2021: first follow-up

   R.6, R.7, R.18 and R.35 were upgraded to largely compliant. R.15 on new technologies fell to non-compliant after the FATF strengthened its virtual asset standard.

3. 2022: second follow-up

   R.23 was upgraded to compliant, and R.24 and R.25 to largely compliant.

4. July 2023: third follow-up

   R.12 and R.26 were upgraded to compliant, and R.8, R.22 and R.28 to largely compliant. R.15 rose to partially compliant.

5. September 2026: fifth-round report

   15 compliant, 23 largely compliant and 2 partially compliant. R.7 and R.8 fell back to partially compliant, while R.15 rose to largely compliant.

Grey list history

The FATF first identified strategic deficiencies in Türkiye in 2010, mainly in criminalising terrorist financing and freezing terrorist assets. In October 2012 it warned that Türkiye’s membership would be suspended unless it acted, and in February 2013 it decided not to suspend after Law No. 6415 was adopted. Monitoring ended in October 2014. The FATF placed Türkiye under increased monitoring again in October 2021, with an action plan covering risk-based supervision, financial investigations, terrorist-financing designations and non-profit oversight, and removed it in June 2024.

What comes next

• Türkiye will report back to the FATF under enhanced follow-up, with a three-year roadmap of priority actions.
• The priority actions include complex laundering cases linked to drugs, smuggling and illegal betting, recovering assets abroad, implementing sanctions without delay and verifying beneficial ownership.
• The Ministry of Treasury and Finance has said there is no risk of a return to the grey list. Check the FATF’s statements after each plenary.

Türkiye’s national risk assessment is prepared under the Ministry of Treasury and Finance. The official summary published in 2023 rates threats and sectors on a five-level scale. A 2025 update was approved in June 2025, and the FATF’s 2026 report draws on it. The ratings below are from the 2023 summary.

Money laundering threats

According to a public summary by a former MASAK president, the 2025 assessment keeps fraud as the highest threat, followed by illegal betting, drug trafficking and theft. The FATF lists fraud, illegal betting, drug trafficking and smuggling as the main sources of criminal proceeds.

Most vulnerable sectors

The FATF also points to cash, unlicensed money transfer services and misuse of legal persons, sometimes with help from lawyers and accountants. Banks are the most used channel because they hold about three-quarters of financial-sector assets.

Terrorist and proliferation financing

• Organisations. Türkiye’s assessments name FETÖ/PDY, PKK/KCK-PYD/YPG, ISIL and al-Qaida as the main terrorist-financing threats, and the FATF also cites DHKP/C.
• Channels. Exchange offices, money transfer services and social media are named as channels, and the FATF found few terrorist-financing reports from higher-risk sectors.
• Proliferation. The FATF links Türkiye’s proliferation-financing exposure mainly to trade routes and its border and trade with Iran.

Common typologies

• Iran sanctions evasion. In September 2026, the US designated Türkiye-based Golden Global Bank, alleging it moved Iranian oil revenue that was converted into cash and gold. The bank denies the allegations. In October 2026, the US designated Turkish petrochemical traders for buying Iranian products. A 2019 US indictment of Halkbank alleged a scheme using gold and fake food and medicine sales; according to news reports, the case was dismissed in June 2026 without a conviction.
• Russia sanctions circumvention. The US has designated Türkiye-based firms for supplying Russia with microelectronics and other dual-use goods, for example in November 2023 and October 2024, and the EU has listed Türkiye-based companies in its Russia sanctions packages.
• Rented accounts. Criminals pay people to hand over bank, payment or crypto accounts to move fraud and illegal betting proceeds. New criminal rules in 2025 and 2026 target account renting and allow short account suspensions.
• Gold and precious metals. Gold is easy to move and store and is a common way to integrate criminal proceeds. Türkiye is one of the world’s largest jewellery producers.
• Real estate. Property purchases are a main laundering method. Citizenship can be acquired through a property investment of at least USD 400,000.
• Crypto-assets. High crypto use, the 2021 collapse of the Thodex exchange and rapid transfers between platforms and stablecoins led to MASAK’s withdrawal holds and transfer limits.

Red flags to watch for

These are common warning signs drawn from the risks above. One red flag is not proof of crime; consider it with everything else you know about the customer.

Eight scenario questions on the main points in this guide. Choose an answer, then open it to check. The answers use only the facts set out above.

1. Question 1. A customer of an Istanbul exchange office who has no continuous relationship with it exchanges currency worth TRY 250,000 in the morning and TRY 150,000 in the afternoon of the same day. What applies?

   1. Nothing, because each transaction is below the threshold
   2. The transactions are linked and together exceed TRY 370,000, so the customer must be identified, and the split should be reviewed as a possible red flag
   3. Only a report to the Central Bank is needed
   4. The exchange office must refuse the second transaction
   Show answer

   Answer: B. The identification threshold for occasional transactions applies to single or linked transactions, and since 7 October 2026 it is TRY 370,000. Splitting a transaction to stay below a threshold is a red flag to consider for a suspicious transaction report.

2. Question 2. A compliance officer at a Turkish bank forms a suspicion about a customer’s transfers on a Monday. Nothing suggests that a delay would cause harm. What is the latest the bank can file a suspicious transaction report?

   1. Within 24 hours
   2. At the end of the month
   3. Within 30 days of the transaction
   4. Within 10 working days of forming the suspicion
   Show answer

   Answer: D. Suspicious transaction reports must be filed with MASAK within 10 working days of the suspicion arising, or immediately where delay would cause harm.

3. Question 3. Which body is Türkiye’s financial intelligence unit and its AML/CFT supervisor for every obliged sector?

   1. MASAK, the Financial Crimes Investigation Board
   2. BDDK, the banking supervisor
   3. The Central Bank (TCMB)
   4. The Capital Markets Board (SPK)
   Show answer

   Answer: A. MASAK, part of the Ministry of Treasury and Finance, is the financial intelligence unit and the AML/CFT supervisor for all obliged parties. The other bodies license and supervise particular sectors.

4. Question 4. A Turkish crypto-asset service provider receives a customer’s transfer of crypto-assets worth TRY 45,000 from another provider, but the originator’s information is missing. What should it do?

   1. Accept it, because the Travel Rule does not apply to crypto-assets
   2. Accept it and file a report at the end of the year
   3. Ask for the missing information and return the transfer if it is not provided
   4. Freeze the customer’s whole account permanently
   Show answer

   Answer: C. Under Article 24/A of the Regulation on Measures, transfers at or above TRY 30,000 must carry full originator information. The receiving provider must ask for missing data and return the transfer if it is not supplied.

5. Question 5. A private bank in Ankara wants to open an account for a serving minister of a foreign country. What must it do?

   1. Get senior management approval, establish the source of funds and wealth, and monitor the relationship more closely
   2. Nothing extra, because PEP rules only apply to Turkish officials
   3. Refuse the account in all cases
   4. Only check the minister’s passport
   Show answer

   Answer: A. Under MASAK General Communiqué No. 21, enhanced measures always apply to foreign PEPs. For domestic PEPs, the same measures apply where the relationship is high risk.

6. Question 6. A company has three shareholders: Ali with 40%, Ayşe with 35% and Mehmet with 25%. Who must the bank identify as beneficial owners on the ownership test?

   1. All three shareholders
   2. Only the company director
   3. Ali and Ayşe, who each hold more than 25%
   4. Nobody, because no one holds a majority
   Show answer

   Answer: C. Natural persons holding more than 25% are beneficial owners. Mehmet holds exactly 25%, so he does not meet the test unless he controls the company in another way.

7. Question 7. A new UN Security Council listing of a terrorist financier is published. A Turkish bank finds the person holds an account with it. What should the bank do?

   1. Wait for the person’s next transaction before acting
   2. Close the account and transfer the balance back to the customer
   3. Ask the customer to explain the listing
   4. Freeze the assets as soon as the freezing decision applies, and tell MASAK
   Show answer

   Answer: D. UN listings are implemented by Presidential decision under Laws No. 6415 and No. 7262. Obliged parties must freeze matched assets immediately and tell MASAK, and must check new decisions every day.

8. Question 8. What did the FATF decide about Türkiye in its fifth-round evaluation, published on 23 September 2026?

   1. It placed Türkiye back on the grey list
   2. It placed Türkiye in enhanced follow-up, with 38 of 40 Recommendations rated compliant or largely compliant
   3. It suspended Türkiye’s FATF membership
   4. It rated all eleven outcomes as highly effective
   Show answer

   Answer: B. Türkiye is not on the grey list. The 2026 report rated 38 of 40 Recommendations compliant or largely compliant, three outcomes substantial and eight moderate, and placed Türkiye in enhanced follow-up.