Enhanced Measures Imposed by MASAK on Crypto Asset Service Providers

Legal regulations concerning crypto asset service providers (CASPs) have significantly expanded in recent years. In this context, secondary legislation regarding crypto assets continues to be introduced. CASPs operate under the supervision of two main authorities in Türkiye: the Capital Markets Board (CMB) and the Financial Crimes Investigation Board (MASAK). Accordingly, CASPs are considered obliged parties under the MASAK legislation.

As is known, a significant regulatory amendment concerning the sector entered into force on 25 December 2024. Following this development, the crypto asset sector has become subject to even stricter compliance obligations with the publication of MASAK General Communiqué No. 29 (Communiqué) in the Official Gazette dated 28 June 2025, which entered into force on the same day. The main amendments introduced under the Communiqué are as follows:

• * In cases where CASPs establish business relationships with customers or conducting transactions that require customer identification, CASPs must:
• - Obtain information regarding the source of the funds and assets involved in the transaction, as well as the purpose of the transaction;
• - Increase the frequency and number of monitoring controls, identify transaction types subject to enhanced due diligence, and maintain close oversight of the business relationship.

This requirement is significant not only within the scope of “know-your-customer” (KYC) obligations, but also in terms of the internal control duties that form the basis for suspicious transaction reporting. The Communiqué indirectly frames this obligation within a risk-based approach.

• * Platforms may carry out withdrawal transactions involving (i) wallets not registered with the CASP, and (ii) institutions established abroad that are not subject to information-sharing obligations, only after a minimum of 48 hours following the relevant purchase, exchange, or deposit transaction. For initial crypto asset withdrawal transactions, this period shall be no less than 72 hours. These timing restrictions are intended to mitigate the risk of money laundering and prevent potential market manipulation.
• * For stablecoin withdrawals, a daily limit of USD 3,000 and a monthly limit of USD 50,000 will apply. For crypto asset transfer transactions of TRY 15,000 or more intermediated by CASPs, these thresholds may be applied at twice the standard amount.
• * Platforms are now required to collect a transaction note of at least 20 characters from the customer explaining the nature of each crypto asset transfer.
• * The Communiqué provides a limited exemption mechanism for platforms. In this regard, platforms may be exempt from applying the prescribed measures in connection with crypto asset transfers conducted for the purposes of liquidity provision, market making, or inter-market arbitrage, provided that all of the following conditions are met:
• - Supporting documentation regarding the source of the assets must be submitted on a regular basis;
• - A separate board of directors’ approval must be obtained for each customer;
• - All know-your-customer (KYC) and due diligence measures must be fully implemented.

However, platforms are still required to continuously monitor and supervise customers benefiting from this exemption.

Transfers executed by custodians on behalf of or in the name of platform customers are also subject to the restrictions under the Communiqué. However, these measures shall not apply to transfers carried out between platforms and custodians where such transfers arise from obligations under capital markets legislation, as these transactions are already subject to CMB supervision.

Developments in the crypto asset sector continue at a rapid pace. This Communiqué may be considered one of the more significant recent regulatory milestones.

You can reach the full version of the Communiqué here (only available in Turkish).