TURKEY Trends and Developments Contributed by: Caghan Tansel, TANSEL
Licensing, Capital and Custody The Turkish regime is now licensing-led. A project that provides exchange, brokerage, custody, wallet or similar crypto-asset services to Turkish residents must assess whether it falls within the CASP perimeter and whether it must obtain CMB permission before launching or continuing Turkish-facing operations. The capital requirement is also no longer a techni- cal detail. The 2025 framework introduced substan- tial minimum capital expectations, and 2026 market guidance indicates that applicants should budget for materially higher indexed amounts than the original 2025 figures. Current guidance refers to TRY250 mil- lion for platforms (centralised exchanges-CEX) and TRY630 million for custodians, although applicants should verify the latest CMB bulletin and application package immediately before filing. Custody is another decisive issue. The CMB’s 2026 announcements show that custody arrangements remain a central implementation point: deadlines for platforms to submit custody agreements and for CASPs on the CMB list to obtain certain required certificates were extended, with new deadlines to be determined after CMB-authorised custody institutions begin offering services more broadly. For foreign entrants, this means custody planning should begin before market entry. A Türkiye strategy should identify whether assets can be supported by a local authorised custodian, whether any interim struc- ture is legally available, how client assets will be seg- regated, and how custody, reconciliation, audit and proof-of-reserves processes will operate in practice. AML, MASAK and the Travel Rule Türkiye’s crypto framework is not only a capital-mar- kets regime; it is also an AML regime. MASAK, Tür- kiye’s Financial Crimes Investigation Board, has inten- sified expectations for CASPs through amendments, guidance and Communiqué No 29, which regulates enhanced measures for crypto-asset service provid- ers under Law No 5549. MASAK’s current guidance addresses customer iden- tification, remote identification, Travel Rule implemen- tation, transfer limits and timing, politically exposed
This demand profile explains why Türkiye remains strategically important for exchanges, custodians, banks, fintechs and tokenisation projects. However, the key commercial question has changed. In earlier years, speed to market often mattered more than regulatory structure. In 2026, the decisive question is whether a project can operate within a licensed, auditable and custody-compliant framework. The New Legal Architecture Türkiye’s crypto-asset framework is now anchored in the Capital Markets Law. Law No 7518, published in July 2024, amended that law and introduced a statu- tory basis for the regulation and supervision of CASPs by the CMB. The amendments gave the CMB author- ity over the establishment, operation, supervision and enforcement framework for crypto-asset platforms and related service providers. The next major step came on 13 March 2025, when two principal CMB communiqués entered into force: • Communiqué III-35/B.1, concerning the establish- ment and operating principles of CASPs; and • Communiqué III-35/B.2, concerning the working procedures and principles, capital adequacy and related operational matters of CASPs. Together, these communiqués form the backbone of Türkiye’s 2026 CASP regime. They address incor- poration, operating permission, founders and share transfers, managers and personnel, internal audit, internal control, risk management, information sys- tems, records, independent audit, proof-of-reserves, services, trading venues, custody, transfer processes, listing principles and capital adequacy. A critical practical point is that the CMB’s transitional “active providers” list should not be treated as a full licence list. The CMB describes it as a public-informa- tion list of entities that declared they would continue operating under the temporary provisions introduced by Law No 7518. New market entrants and existing platforms must therefore distinguish between being on a transitional list and holding the final operating permissions required under the secondary legislation.
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