Centralized exchange in Turkey
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is conditionally permitted in Turkey with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- CASP must register with MASAK as an 'obliged entity' and implement KYC/AML/CFT protocols (tr.licensing.financial-crimes-investigation-board-masak)
- Travel Rule applies on withdrawals at threshold TRY 75,000 (~$2,100 USD); originator and beneficiary information must be transmitted (tr.travel-rule.status, tr.travel-rule.official-gazette-amendments-dec-25)
- Ongoing transaction monitoring and suspicious transaction reporting to MASAK under AML legislation amendments (December 2024) (tr.licensing.aml-legislation-amendments-december-2024)
- Customer identity verification at onboarding — CDD required under MASAK regulation (tr.licensing.masak-enforces-aml-for-casps)
Key Restrictions
- CASP license from SPK/CMB required — TRY 50M (~$1.5M USD) minimum paid-up capital (tr.licensing.vasp, tr.licensing.exchange)
- Operator must establish a Turkish entity with Turkish-resident board members (tr.licensing.vasp)
- Crypto payments for goods/services are banned (CBRT Regulation, April 2021) — exchange trading activity is permitted, but payment use cases are prohibited (tr.licensing.central-bank-regulation-on-prohibition-of-payments-with-crypto-assets)
- At least 95% of customer assets must be held in cold wallets managed by authorized custodians; max ~5% in hot wallets (tr.custody.at-least-95-in-cold)
- Custody must use TÜBİTAK-compliant secure hardware modules for private keys (tr.custody.use-tbitak-compliant-secure-hardware-modules)
- Integration with MKK (Turkish Central Securities Depository) required for reconciliation and reporting (tr.custody.integration-with-mkk-turkish-central)
- Only authorized banks or institutions may provide custody; foreign CASPs face restrictions (tr.custody.only-authorized-banks-or-institutions)
- Existing operators must comply by June 30, 2025 transitional deadline (tr.custody.platforms-must-register-in-the)
- CASP must register in CMB's institutional ledger (kurum kaydı) (tr.custody.platforms-must-register-in-the)
- Lending and related prohibited activities under CMB Resolution Sept 19, 2024 (tr.custody.cmb-resolution-dated-september-19)
Key Risks
- Criminal penalties for unlicensed operation — unlicensed CASPs face criminal liability under the Crypto Assets Law (2024) — high enforcement risk (tr.licensing.legislation-crypto-assets-law)
- Payment-usage ban creates line-drawing risk — exchange services are allowed but any feature resembling payment processing could trigger CBRT sanctions (tr.licensing.central-bank-regulation-on-prohibition-of-payments-with-crypto-assets)
- High minimum capital (TRY 50M) and Turkish entity/resident director requirements create entry barriers and governance exposure (tr.licensing.vasp)
- Regulatory framework is new (mid-2024) with secondary legislation still evolving — interpretive risk and potential for additional restrictions (tr.licensing.cmb-communiqus-and-resolutions-secondary)
- Thodex-type fraud precedent means political and enforcement scrutiny is high; authorities have demonstrated willingness to block platforms (e.g., PancakeSwap 2024) (tr.licensing.capital-markets-board-cmb-primary)
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
SPK/CMB — Crypto Asset Service Provider licensing, prudential oversight
Crypto Assets Law (2024) — CASP licensing, investor protection, criminal penalties for unlicensed operation. Came after Thodex fraud (2021, CEO fled with ~$2B).
VASP: Crypto Asset Service Provider License from SPK under Crypto Assets Law (2024). TRY 50M (~$1.5M USD) minimum paid-up capital. Must establish Turkish entity with Turkish-resident board members. 6-12 months. One of world's highest crypto adoption rates.
EXCHANGE: CASP license — TRY 50M minimum. Crypto PAYMENTS banned (CBRT regulation, April 2021) — ban remains despite licensing framework. Criminal penalties for unlicensed operation.
Law No. 7518: Official Gazette No. 32590, July 2, 2024 (establishes CASP status, CMB licensing, segregation).
CMB Resolutions/Communiqués: Govern licensing, capital (TRY 500M/~$13.7M for custodians), prohibitions (e.g., Sept 19, 2024).
Central Bank Regulation: Official Gazette No. 31456, April 16, 2021 (prohibits crypto as payment, no direct custody impact).
MASAK enforces AML for CASPs, including custody.
Capital Markets Board (CMB): Primary authority for licensing CASPs, enforcing operational rules, sanctions, and blocking unlicensed platforms (e.g., PancakeSwap in 2024).
Financial Crimes Investigation Board (MASAK): Enforces anti-money laundering (AML) regulations concerning cryptocurrencies and classifies CASPs as "obliged entities" subject to strict AML and Know-Your-Customer (KYC) protocols.
Central Bank of the Republic of Turkey (TCMB): Responsible for monetary policy and issued the 2021 regulation prohibiting cryptocurrency payments, focusing on maintaining financial stability.
Banking Regulation and Supervision Agency (BRSA): Oversees banking activities related to crypto, including approving banks offering crypto asset custody services.
Scientific and Technological Research Council of Türkiye (TÜBİTAK): Handles technical compliance and standards.
Evidence fact tr.licensing.central-bank-regulation-on-prohibition-of-payments-with-crypto-assets not found (may have been renamed).
Law on Amendments to the Capital Markets Law: Entered into force July 2, 2024; mandates CMB licensing for CASPs, defines operations, and sets transitional rules. https://www.resmigazete.gov.tr/eskiler/2024/07/20240702-1.htm
CMB Communiqués and Resolutions (Secondary Legislation, post-July 2024): Cover establishment, capital adequacy, custody, risk management, and conduct; enforce 2024 licensing powers (e.g., DEX blocks).
AML Legislation Amendments: December 2024 updates enhance CASP requirements.
Minimum capital for custodians: TRY 500 million (~$13.7 million).
Platforms must register in the CMB's “kurum kaydı” (institutional ledger) system and comply by June 30, 2025, for existing operators.
Only authorized banks or institutions may provide custody; foreign CASPs face restrictions.
CMB Resolution dated September 19, 2024, further details prohibitions like lending.
At least 95% in cold wallets managed by authorized custodians (max ~5% in hot wallets for operations).
Use TÜBİTAK-compliant secure hardware modules for private keys.
Integration with MKK (Turkish Central Securities Depository) for reconciliation and reporting.
Travel Rule adopted — threshold: TRY 75,000
Official Gazette amendments (Dec 25, 2024): https://www.resmigazete.gov.tr/ (search MASAK communiqués)
MASAK Regulation on Measures: https://www.masak.gov.tr/en/mevzuat/regulation-on-measures-regarding-prevention-of-laundering-proceeds-of-crime-and-terrorism-financing
SPK/CMB and TÜBİTAK standards: Via respective sites (cmb.gov.tr, tubitak.gov.tr)
Regulator/Prosecutor: Turkish prosecutors
Regulator: Turkish authorities (likely law enforcement)
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — centralized exchanges are permitted in Turkey but must obtain a CASP license from SPK/CMB (TRY 50M minimum capital), establish a Turkish entity with resident directors, comply with strict custody segregation rules (95% cold storage, TÜBİTAK-compliant HSM, MKK integration), adhere to MASAK AML/CFT obligations including the Travel Rule at TRY 75,000 threshold, and operate under a blanket ban on crypto payments for goods/services.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?