With the amendment of July 7, 2024, Türkiye introduced KVHS license obligation to crypto exchanges; CMB + CBRT + MASAK multiple compliance.
License terms (summary)
- Minimum capital is 150M TL (500M TL for crypto custody license).
- Status of joint stock company.
- Finance + technology experience in managers.
- Internal control + risk management + compliance (MASAK) unit.
- Customer asset segregation.
- System security (ISO 27001 + cold wallet).
- Liquidity & customer protection fund.
Application process
MASAK compliance
- KYC (Know Your Customer): ID + address.
- Suspicious transaction reporting (STR).
- Regular activity reporting (annual).
- Wallet address analysis (Chainalysis etc.).
- Sanctions list monitoring (UN, OFAC, EU).
Frequently asked questions
Is a license required if a foreign exchange provides services in Türkiye?
If it is actively marketing to Turkish customers, yes, it falls under Turkish jurisdiction with the "effective connection" doctrine. CMB warning + risk of access blockage only if there is a global service (Turkish site, Turkish lira double, BTC bonus).
Can we continue operating without obtaining a license?
No, platforms that apply during the transition period remain under CMB control; Even if the operation continues, accepting new customers may be restricted. If the license is rejected, sequential closure is mandatory.
What is the period to obtain a license?
Transition period 2024-2025; Existing platforms must apply. New application: 6-12 months.
Can foreign investors become partners in KVHS?
Yes, but 50%+ foreign share additional CMB + CBRT approval process. KEK (Entity Added Control) notification is mandatory.
Is the DeFi protocol subject to these licenses?
Fully decentralized protocol — currently unclear; The EU MiCA example is being followed. If there is a "managing team", the license liability as the "controlling party" is being discussed.
Relevant legislation
- Law No. 6493 — Payment and securities; KVHS compliance framework.
- 5549 SK — MASAK crypto reporting and compliance.
- BRSA 2021/30 — Ban on using crypto in payments.
- CMB Crypto Communiqué — Crypto issuances (in draft process).
- KVK + GVK — Crypto earnings taxation framework.