Self-custodial wallet / non-custodial software in Turkey
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is not permitted in Turkey.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
Key Restrictions
- Publishing self-custodial wallet software does not require a CASP license under Turkish law because the publisher never holds, controls, or accesses user private keys or funds — the definition of a CASP under the Crypto Assets Law (2024) and CMB regulations centers on custody, exchange, transfer, or other intermediary services involving crypto assets.
- Crypto payments are banned outright (CBRT Regulation, April 2021). While this does not directly target non-custodial software, it restricts any payment-adjacent functionality the wallet might enable.
- Turkish licensing regime (CMB) focuses on CASPs that hold or control customer assets. Non-custodial software publishers fall outside the scope of SPK/CMB licensing requirements.
Key Risks
- Regulatory ambiguity: Turkish law defines CASPs around custody and intermediation; a purely non-custodial software publisher is not clearly captured, but there is no explicit exemption either — authorities could take a broad enforcement view.
- Enforcement precedent: CMB has blocked unlicensed platforms (e.g., PancakeSwap 2024). If a wallet's built-in swap features are deemed intermediation, the publisher could face retroactive enforcement.
- Tax/PR risk: High crypto adoption in Turkey means regulators and the public are sensitive to crypto-related activities; a non-custodial wallet publisher could attract scrutiny even if technically not a CASP.
- Criminal penalties for unlicensed CASP operation under the Crypto Assets Law create serious downside risk if authorities reinterpret the scope.
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.
CUSTODY: Included under CASP license; customer asset segregation required
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).
Capital Markets Board (CMB): The primary regulatory authority responsible for establishing regulatory measures, making decisions, and implementing sanctions related to crypto assets. The CMB grants operating licenses to crypto asset service providers (CASPs).
Capital Markets Board (CMB): Primary authority for licensing CASPs, enforcing operational rules, sanctions, and blocking unlicensed platforms (e.g., PancakeSwap in 2024).
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).
Central Bank Regulation on Prohibition of Payments with Crypto Assets: Published in Official Gazette No. 31456 on April 16, 2021; bans crypto use for goods/services. https://www.resmigazete.gov.tr/eskiler/2021/04/20210416-3.htm
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:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Not permitted as a CASP — non-custodial wallet software publishing does not trigger CASP licensing under Turkish law because the publisher never holds, controls, or accesses user private keys or funds; however, there is no explicit exemption, and if the wallet includes features like built-in swaps/dex integration, it could be reclassified as intermediation, exposing the publisher to criminal penalties for unlicensed operation.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?