Nowadays, crypto assets allow investors to carry out transactions quickly and with minimal costs, without being subject to the fees charged by banks or intermediaries, using nothing more than a smartphone with an internet connection. Over the past decade, their decentralized nature, which grants individuals greater financial autonomy over their assets, has been a key factor in positioning them as a viable alternative to the traditional banking system.
However, this freedom has also created an unregulated environment, which has allowed crypto assets to be used as a tool for financing illegal activities and has occasionally led to abuses causing significant losses to investors. The rapid increase in such transactions has made the establishment of a general framework for transaction and oversight of crypto assets one of the priorities of public authorities.
One of the most recent regulatory developments in this area is the Financial Crimes Investigation Board (“MASAK”) General Communiqué No:29 (“Communiqué”), titled “Tightened Measures in the Relationship of Crypto Asset Service Providers (“CASP”) with their Customers”, which was published in the Official Gazette dated 28 June 2025 and numbered 32940. In the continuation of our article, we will summarize the Communiqué’s provisions, which aim to enhance transaction security by imposing information-gathering obligations on crypto asset transfers, supported by time and limit restrictions, and are presented under three subheadings.
- MEASURES RELATING TO TRANSACTION TIMING: Time Requirement for Inter-Platform Crypto Transfers
Platforms are required to observe the following for transfers they facilitate:
a. Transfers sent to or received from a wallet address that is not registered with any crypto asset service provider, or
b. Transfers sent to or received from a crypto asset service provider or a financial institution authorized to conduct crypto asset transfers that is located abroad and not subject to an obligation under its domestic legislation to share information about the sender and recipient,
must be executed at least 48 hours after the acquisition, exchange, or deposit of the crypto asset to be transferred, including transfers to other platforms. For first-time crypto asset withdrawals, this period is extended to at least 72 hours.
- MEASURES RELATING TO TRANSACTION LIMITS: Daily and Monthly Transaction Limits for Stablecoin Transfers
- Transfers of stablecoins, which are reserve assets designed to maintain value stability and pegged to a specific currency, commodities such as gold, or other financial instruments, including transfers to other platforms, are strictly limited to a daily equivalent of USD 3,000 and a monthly equivalent of USD 50,000.
- For crypto asset transfers facilitated by CASP with a value of ₺15,000 or more, these limits can be increased to a daily equivalent of USD 6,000 and a monthly equivalent of USD 100,000.
The Communiqué also introduces an exception specifying that the measures relating to transaction limits and timing described above may not apply under certain conditions and circumstances.
Platforms may be exempt from applying transaction limit and timing measures for crypto asset transfers, provided that all measures to identify the customer are taken, including periodic collection of documents related to the source of assets and account details with banks or other platforms, and that steps are taken to prevent the customer from circumventing the transaction limit and timing measures. This exception applies only if the transfer is confirmed to be for the purposes of liquidity provision, market making, or inter-market arbitrage, and requires individual board approval for each customer.
Platforms are obliged to continuously monitor and supervise customers for whom the measures are not applied. If it is determined that the transactions are not related to liquidity provision, market making, or inter-market arbitrage, the transaction limit and timing measures must be immediately applied.
- MEASURES RELATING TO TRANSACTION PARTIES: Requirement for Transaction Description and Customer Information for All Crypto Transfers
Finally, under the Communiqué, it is mandatory to obtain from the customer a transaction description of at least 20 characters for all crypto asset transfers, without exception.
In addition to this general regulation, it is mandatory to obtain a declaration regarding at least one piece of information that can identify the sender or recipient who is a natural person not registered with any CASP, such as their full name, or in the case of legal entities, their trade name and address, or their place and date of birth, or customer number, national identification number, passport number, tax identification number, or other identifying information. Transfers carried out by depository institutions on behalf of or in the name of platform customers are subject to the restrictions set forth in this article.
In conclusion, these recent legal regulations targeting the crypto asset market in Turkey aim to enhance transaction security and ensure system traceability for investors. The new rules, ranging from transfer timing and transaction limits to requirements for transaction descriptions and customer identification, require every investor to conduct their transactions more carefully and consciously. Therefore, it is of paramount importance for both individual and corporate crypto asset investors to closely monitor these new obligations and assess the legal compliance of the platforms they use, in order to mitigate legal risks and safeguard the security of their assets.
Kaan Kabataş