This page summarises the rules that apply in Türkiye when crypto assets are connected with the laundering of proceeds of crime or the financing of terrorism. It is based on Prof. Dr. Murat Volkan Dülger's publications listed at the end. The legislation cited was checked against official sources on 31 October 2026.

Holding crypto assets is not an offence

Issuing, holding, buying and selling crypto assets is not an offence in Türkiye. The legislation regulates the intermediaries, not the crypto asset itself. Two limits apply. Crypto assets may not be used in payments, directly or indirectly, under the Central Bank's Regulation on the Non-Use of Crypto Assets in Payments (Official Gazette 16 April 2021, No. 31456). Crypto-asset services may be provided only with authorisation under the Capital Markets Law.

There is no separate “crypto offence”. Using crypto assets to launder proceeds of crime is a new way of committing an existing offence. In practice the difficulty lies in evidence and investigative capacity rather than in missing legal norms.

The money laundering offence (Art. 282 TCK)

Under Art. 282(1) of the Turkish Criminal Code (TCK), anyone who takes abroad assets deriving from an offence punishable by a minimum of six months' imprisonment or more, or subjects them to transactions in order to conceal their illegitimate source or to create the impression that they were lawfully acquired, is punished with three to seven years' imprisonment and a judicial fine of up to 20,000 days. Under Art. 282(2), a person who, without having participated in that offence, knowingly acquires, accepts, possesses or uses such assets is punished with two to five years' imprisonment.

The prison sentence is increased by half where the offence is committed by a public official, or by a member of a profession in the course of that profession; the penalty is doubled where it is committed within the activities of an organisation set up to commit offences. Under Art. 282(6), no penalty is imposed on a person who, before the trial stage (kovuşturma) begins, enables the assets to be seized or facilitates their seizure by informing the authorities of their location.

Two regimes must be kept apart. The criminal regime rests on Art. 282 TCK. The preventive regime rests on Law No. 5549 on the Prevention of Laundering Proceeds of Crime; there the threshold is suspicion and the sanctions are mainly administrative fines, although Arts. 14 and 15 of the Law also provide for criminal penalties. A suspicious transaction report is neither an accusation nor, on its own, evidence.

Crypto-asset service providers (Law No. 7518)

Law No. 7518 (Official Gazette 2 July 2024, No. 32590) added definitions of crypto asset, wallet, crypto-asset service provider, custody service and platform to Art. 3 of the Capital Markets Law No. 6362. Under Art. 35/B, a provider needs authorisation from the Capital Markets Board (SPK) to be established and to operate. Under Art. 35/C, it must identify its customers under Law No. 5549, and transfers must follow the rules made by the SPK and the Financial Crimes Investigation Board (MASAK), including information on the originator and the beneficiary.

Providing crypto-asset services without authorisation is an offence under Art. 109/A, punishable with three to five years' imprisonment and a judicial fine of 5,000 to 10,000 days. Art. 110/A creates a separate offence of embezzlement in crypto-asset service providers.

The SPK's Communiqués III-35/B.1 and III-35/B.2 on the establishment and operation of crypto-asset service providers were published on 13 March 2025 (Official Gazette No. 32840). The SPK also publishes a list of entities operating during the transition period and states that inclusion in that list does not mean authorisation.

Anti-money laundering obligations and the travel rule

Crypto-asset service providers have been obliged parties under the Regulation on Measures for the Prevention of Laundering Proceeds of Crime and Financing of Terrorism since 1 May 2021 (Art. 4(1)(ü)). They must identify their customers, monitor transactions and report suspicious transactions to MASAK.

Art. 24/A of the same Regulation, added by Presidential Decision No. 9305 (Official Gazette 25 December 2024, No. 32763), introduced the travel rule. For transfers of 30,000 TL or more intermediated by a provider, the transfer message must contain the originator's name, wallet address and at least one further identifying detail, and the accuracy of this information is verified; the beneficiary's name and wallet address must also be included. The threshold was raised from 15,000 TL to 30,000 TL by Presidential Decision No. 11845 (Official Gazette 7 October 2026, No. 33393).

MASAK General Communiqué No. 29 (Official Gazette 28 June 2025, No. 32940) introduced, among other measures, waiting periods for certain crypto-asset withdrawals and daily and monthly limits for stablecoin transfers.

Financing of terrorism

The financing of terrorism is governed by Law No. 6415 on the Prevention of the Financing of Terrorism (Official Gazette 16 February 2013, No. 28561). The Law defines “funds” as money or any movable or immovable, tangible or intangible property, right or claim whose value can be represented by money, and any document representing them (Art. 2). Crypto assets are not mentioned by name; the definition is not limited to particular forms of assets.

Under Art. 4, anyone who provides or collects funds for a terrorist or terrorist organisations, with the intention that they be used, or knowing and wanting that they be used, in whole or in part for the acts defined as offences in Art. 3, is punished with five to ten years' imprisonment, even where the funds are not linked to a specific act and unless the conduct constitutes another offence carrying a heavier penalty. It is not required that the funds were actually used in committing an offence (Art. 4(3)).

The Law also provides for the freezing of assets. Freezing decisions under United Nations Security Council resolutions are given effect by a Presidential decision published in the Official Gazette and applied without delay (Art. 5). Requests from foreign states are assessed by the Evaluation Commission and decided by the President (Art. 6). Assets in Türkiye may be frozen, in connection with an organisation finally declared a terrorist organisation by the courts and where there are reasonable grounds, by a joint decision of the Minister of Treasury and Finance and the Minister of the Interior on the Commission's proposal; the decision takes effect immediately and is submitted within 48 hours for approval to the assize court in Ankara designated by the Council of Judges and Prosecutors, which decides within five days (Art. 7). Arts. 5 and 7 were amended by Law No. 7262 on the Prevention of the Financing of the Proliferation of Weapons of Mass Destruction (Official Gazette 31 December 2020, No. 31351).

For obliged parties, including crypto-asset service providers, a suspicious transaction includes any information or suspicion that the assets are used for terrorist acts or by terrorist organisations, terrorists or those who finance terrorism, or are connected with them; such transactions must be reported to MASAK regardless of their amount (Art. 27 of the Regulation on Measures).

FATF Recommendation 5 requires countries to criminalise terrorist financing even in the absence of a link to a specific terrorist act, and Recommendation 6 requires the assets of persons and entities designated by the UN Security Council, or by the country itself under UNSC Resolution 1373, to be frozen without delay. Under the Interpretive Note to Recommendation 15, these measures also apply to virtual assets and their service providers. In its July 2026 update, citing its March 2026 report on stablecoins, the FATF notes that terrorist organisations, including ISIL and Al-Qaeda, increasingly favour stablecoins over Bitcoin. In the European Union, Art. 11 of Directive (EU) 2017/541 defines the terrorist financing offence, and the Transfer of Funds Regulation and the Anti-Money Laundering Regulation apply to terrorist financing as well as to money laundering.

International standards

FATF Recommendation 15 was amended in October 2018, and an Interpretive Note to it was adopted in June 2019, to bring virtual assets and virtual asset service providers within anti-money laundering rules: risk assessment, licensing or registration, supervision and the travel rule. The FATF's updated guidance on a risk-based approach dates from October 2021. In its seventh targeted update of July 2026, the FATF reports that 83% of the jurisdictions surveyed have passed travel rule legislation and that most identified on-chain illicit activity now involves stablecoins. Türkiye was removed from the FATF's list of jurisdictions under increased monitoring (the “grey list”) on 28 June 2024.

In the European Union, the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114) has applied since 30 December 2024, and its rules on stablecoins (asset-referenced and e-money tokens) since 30 June 2024; transitional periods for existing providers ended on 1 July 2026 at the latest. The Transfer of Funds Regulation (EU) 2023/1113 has applied the travel rule to crypto-asset transfers since 30 December 2024, regardless of the amount. The Anti-Money Laundering Regulation (EU) 2024/1624, which will apply from 10 July 2027, lists all crypto-asset service providers as obliged entities and prohibits anonymous crypto-asset accounts. The EU Anti-Money Laundering Authority (AMLA) in Frankfurt am Main is to begin direct supervision of selected entities in 2028.

Assessment

In Prof. Dr. Murat Volkan Dülger's view, the FATF's risk-based approach is correct, but the potential for misuse does not justify banning crypto assets or obstructing blockchain technology; a ban may push the activity underground. Crypto assets leave a permanent transaction record that cash does not, and proceeds have been recovered through records held at intermediaries and through international cooperation. Treating the mere holding of crypto assets as a ground for suspicion is incompatible with the basic principles of criminal law.

Further reading

Status of the law: 31 October 2026. This page provides general information and does not replace advice on a specific case.