TURKEY Law and Practice Contributed by: Caghan Tansel, TANSEL
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain 1.1.1 Evolution of Uses of Blockchain In Türkiye, blockchain use continues to be most visible in the crypto-asset market, especially in trading, cus- tody, wallet infrastructure and crypto-asset transfers. Although blockchain is discussed in a broader range of contexts – including tokenisation, digital identity, programmable money and non-fungible tokens (NFTs) – the most mature commercial activity remains con- centrated around crypto-asset service providers and their interaction with banks, custodians, payment institutions and regulators. The last 12 months have been defined less by experi- mental blockchain deployment and more by institu- tionalisation. Türkiye’s crypto market remains highly active: Chainalysis ranked Türkiye 14th globally in its 2025 Global Crypto Adoption Index, with strong activity on centralised services and institutional cen- tralised-service value received. Local survey data also indicates that cryptocurrency awareness has reached 99% for three consecutive years, while the share of people conducting crypto transactions rose from 27% in 2024 to 31% in 2025. However, the same survey shows that “blockchain” as a concept is less widely understood than crypto itself, with blockchain awareness measured at 27% in 2025 and tokenisation awareness at only 8%. The most important market development has been the transition from a largely unlicensed environment to a regulated capital-markets perimeter. The Capital Markets Board of Türkiye (CMB) published two key communiqués on 13 March 2025: Communiqué III- 35/B.1 on the establishment and operation of crypto- asset service providers, and Communiqué III-35/B.2 on operating procedures, principles and capital adequacy. These regulations brought issues such as governance, internal systems, audit, custody, listing procedures, proof-of-reserves and capital adequacy into the ordinary business planning of crypto-asset platforms. The practical effect has been a shift in market behav- iour. Operators that previously focused mainly on user
acquisition and liquidity are now prioritising licence readiness, custody arrangements, internal controls, information systems and anti-money laundering (AML) architecture. The CMB’s “active providers” list remains transitional and is expressly described as a public- information list for entities that declared their intention to continue operations; it should not be read as a final authorisation list. In March 2026, the CMB extended certain deadlines concerning custody agreements and authorisation certificates, showing that custody infrastructure and licensing readiness will remain cen- tral implementation issues. AML and countering the financing of terrorism (CFT) controls have also become much more important. MASAK updated its crypto-asset service provider guidance in 2025 and emphasised risk-based imple- mentation of customer due diligence, transaction monitoring and related controls. Communiqué No 29, published in June 2025, introduced enhanced meas- ures for crypto-asset service providers under Law No 5549, further aligning the Turkish framework with FATF expectations. At the same time, traditional financial institutions are moving closer to the sector. For example, leading banks via their CASP subsidiaries offer crypto-asset wallet, transfer and trading services, including Turkish lira and US dollar trading pairs and custody supported by measures such as multi-signature wallets and cold- wallet infrastructure. This is a significant change in market perception: blockchain and digital assets are increasingly being treated not as a parallel retail phe- nomenon but as a regulated financial-infrastructure vertical. What Current Use Cases Are Commonly Being Looked At? The most common use case remains crypto-asset investment, trading and custody. Retail users con- tinue to use crypto-assets as investment products, while platforms and financial institutions are focusing on compliant brokerage, wallet, transfer and custody models. The increasing role of bank-affiliated or insti- tutionally backed platforms suggests that custody, operational resilience and regulatory credibility are becoming as important as pricing and product range.
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