Recent AML/CFT Regulations Affect Foreign Investors
What you need to know about Turkey’s strengthened anti–money laundering and counter–financing of terrorism rules, and how to stay compliant as a foreign investor.
In 2025, Turkey significantly overhauled its Anti–Money Laundering (AML) and Counter–Financing of Terrorism (CFT) framework—bringing its laws closer in line with EU and FATF (Financial Action Task Force) standards. These updates affect every corner of Turkey’s economy, but they carry special importance for foreign investors, who often move large sums across borders, set up new enterprises, and purchase high-value assets like real estate.
Why this matters now
Global scrutiny of transparency means Turkey must tighten its rules or risk FATF grey-listing.
Foreign capital is vital for Turkey’s post-pandemic recovery, making investor compliance a top priority.
New digital tools (e-Devlet, e-signature) lower barriers—but also harden reporting expectations.
Who this guide is for
Real-estate buyers investing ≥ €150K
Entrepreneurs opening Turkish companies or branches
Wealth managers moving funds through Turkish banks
Crypto traders dealing with Turkish-licensed exchanges
Art and luxury goods investors (precious metals, jewelry)
Advisors (lawyers, accountants, agents) serving those clients
Wle’ll dive deep into:
Turkey’s AML/CFT legal architecture (Laws, regulators, international context)
2025 updates and what’s changed for you
Who must comply and why your transactions trigger checks
Due-diligence & reporting: step-by-step, from KYC to SARs
Case studies & scenarios illustrating real-world application
Penalties & enforcement trends in 2025
Practical compliance roadmap with templates, checklists, and tips
Future outlook: what to expect in 2026–27
FAQs addressing lingering questions
Tools & resources: e-Devlet links, sample forms, MASAK portals
By the end, you’ll know exactly which documents to carry, which questions to ask your bank or advisor, and how to seamlessly integrate Turkey’s new AML/CFT requirements into your investment strategy—protecting your capital, reputation, and legal standing.
Turkey’s AML/CFT Legal Framework
1. Core Legislation
Law No. 5549 on the Prevention of Laundering Proceeds of Crime (2006, amended 2025)
Scope: Financial institutions, real-estate agents, notaries, lawyers, accountants, precious-metals dealers, casinos, and now crypto-asset service providers.
Obligations:
Customer Due Diligence (CDD): verify identity, beneficial ownership, source of funds.
Ongoing Monitoring: periodic reviews, transaction monitoring.
Record-keeping: retain all CDD and transaction records for five years post-relationship.
Law No. 6415 on the Amendment of Criminal Law (2020, with 2025 enhancements)
Strengthened money laundering definitions, increasing penalties for concealment of illicit proceeds.
2. Regulatory Bodies
MASAK (Financial Crimes Investigation Board)
Central Financial Intelligence Unit (FIU) in Turkey.
Issues binding circulars on thresholds, reporting formats, and electronic submission via MASAK’s e-portal.
Coordinates international information exchange under Egmont Group.
BRSA (Banking Regulation & Supervision Agency)
Issues guidelines for banks’ AML/CFT units.
Conducts on-site inspections for compliance.
SPK (Capital Markets Board) and BDDK (Financial Institutions)
Oversee non-bank financial institutions, securities firms, and payment service providers.
3. International Standards & Turkey’s Commitments
FATF: Turkey’s 2025 mutual evaluation prompted the latest amendments, lowering CDD thresholds and tightening beneficial-ownership rules.
EU 5th & 6th AML Directives: While not an EU member, Turkey aligns many regulations to facilitate cross-border investment and payment relations.
UN Conventions: Implements Vienna and Palermo Conventions on transnational crime.
2. 2025 Regulatory Updates & What’s Changed for Investors
A. Lowered CDD Thresholds
Previous: TRY 40,000 (~€1,200)
Now: TRY 30,000 (~€900) triggers “simplified” due diligence (ID + address).
Full CDD still applies for any high-risk client regardless of amount.
B. Beneficial Ownership (BO) Disclosure
All Turkish companies (including LLCs with foreign shareholders) must register BO data in the Central BO Registry.
Individual owners of ≥ 25% shares or voting rights must be declared.
Update within 10 days of any change; penalties for late updates up to TRY 500,000 per instance.
C. Real-Estate Sector Focus
Reporting requirement: Real-estate agents and title-deed offices must report transactions ≥ €150,000 within 3 business days.
Enhanced monitoring of cash payments in property deals.
D. Cross-Border Wire-Transfer Pre-Notification
Outgoing transfers > $5,000 (or equivalent) require a pre-notification to MASAK within 1 business day of scheduling.
Must include: beneficiary, purpose, supporting KYC docs.
E. Digital ID & e-Signature Acceptance
Banks, notaries, and real-estate offices may accept e-Devlet e-signature (e-İmza) for verifying identity and BO declarations—streamlining remote transactions.
F. Penalty Enhancements
Fines: Up to TRY 1 million for failure to file STRs or inaccurate BO info.
Criminal: Up to 5 years’ imprisonment for laundering offenses, with asset seizure provisions.
3. Who Must Comply?
Even if you aren’t a regulated entity, your counterparties (banks, agents, notaries) will apply AML/CFT measures to you. Be prepared:
| Sector | Your Role | Key Trigger |
|---|---|---|
| Real-Estate Agents/Notaries | Buyer/Seller | Property deals ≥ €150K |
| Banks & Fintechs | Mortgage, Capital transfer | Deposits/withdrawals ≥ TRY 30K; cross-border payments > $5K |
| Lawyers & Accountants | Company formation, document drafts | Beneficial-owner cases; large cash flows |
| Crypto-Asset Service Providers | Exchange, custody | Any transactions > TRY 30K |
| Precious-Metals Dealers | Gold/jewelry purchases | Cash transactions ≥ TRY 30K |
4. Due-Diligence & Reporting Obligations
1. Customer Due-Diligence (CDD)
Steps for Investors
Initial Identification: Provide passport + residence permit (or passport + valid business registration).
Proof of Address: Turkish utility bill, rental contract, or bank statement not older than 3 months.
Source of Funds Documentation: Bank statements, sale deeds, employment letters—anything showing how you financed the transaction.
Beneficial-Owner Declaration: If investing via a company, submit company’s BO registry extract from MERSIS portal.
Enhanced Due-Diligence applies if:
You’re a PEP (politically exposed person).
Funds originate from high-risk jurisdictions (non-FATF, sanctioned countries).
Transactions are complex or unusually large.
2. Beneficial-Ownership (BO) Registry
Register via the MERSIS company registration portal.
Fees: nominal (TRY 100–200).
Annual confirmation required if no changes.
3. Suspicious Activity Reporting (SARs)
Your bank/notary must file within 2 business days if they detect:
Structuring to avoid reporting (multiple payments below threshold).
Discrepancies between declared and actual transaction purpose.
Unusual cross-border fund flows.
4. Cross-Border Notification
Upload required form on MASAK’s e-portal: beneficiary details, purpose, transaction proof.
Keep your bank SWIFT messages for audit purposes.
5. Case Studies & Real-World Scenarios
Case 1: Real-Estate Purchase via LLC
Scenario: Jane, a UK national, uses a Turkish LLC to buy a €300K villa in Bodrum.
Compliance Steps:
Company BO registered in MERSIS (Jane’s UK passport uploaded).
CDD at bank: Jane submits salary slips and inheritance documents.
Title-deed office reports sale within 3 days.
Jane’s bank notifies MASAK of cross-border loan repayment.
Pitfall Avoided: No nominee structure—no penalties, smooth title transfer.
Case 2: Crypto Remittance
Scenario: Carlos, a Brazilian trader, sells crypto for TRY 100K on a Turkish-licensed exchange.
Compliance Steps:
Exchange verifies Carlos’s identity via e-Devlet e-signature.
Exchange files CDD record, including wallet address.
When Carlos wires TRY 80K to Spain, bank pre-notifies MASAK under $5K rule (converted).
Pitfall Avoided: Avoided SAR for unexplained transfer.
Case 3: Luxury-Goods Purchase
Scenario: Anna, a Russian national, buys €50K of gold jewelry in Istanbul cash.
Compliance Steps:
Dealer asks for passport; structures sale as two separate €25K purchases labels modern design collection.
Dealer flags suspicious structuring, files SAR.
Lesson: Structuring below thresholds still triggers reporting if repetitive or suspicious.
Case 4: Real-Estate Financing
Scenario: A Saudi investor takes a TRY 500K mortgage.
Compliance Steps:
Bank performs enhanced CDD (Saudi PEP risk).
Investor provides proof of business ownership in Riyadh.
Mortgage is approved with conditional compliance waiver.
Outcome: Smooth financing; bank avoids enforcement action.
6. Penalties & Enforcement Trends (2025)
A. Administrative Fines
| Violation | Fine Range | Risk Level |
|---|---|---|
| Late BO update | TRY 100,000 – 500,000 | 🟠 Medium–High |
| Failure to file SAR | TRY 200,000 – 1,000,000 | 🔴 Very High |
| Inaccurate CDD records | TRY 50,000 – 300,000 | 🟡 Medium |
B. Criminal Sanctions
Money laundering conviction: up to 5 years imprisonment + asset confiscation.
Terrorist-financing: up to 7 years imprisonment.
C. Freezes & Seizures
MASAK can freeze funds or property mid-investigation—locking accounts in days.
Cross-agency cooperation: tax, gendarmerie, customs share data in real time via GOVTR.
7. Practical Compliance Roadmap
Step 1: Pre-Investment Checklist
Obtain and verify apostilled passport copies.
Register or update your e-Devlet e-signature.
File or confirm BO data in MERSIS if using a company.
Prepare source-of-funds binder: bank statements, sale deeds, salary slips.
Step 2: During Transaction
Present originals and notarized copies to banks/notaries.
Insist on electronic CDD via e-signature where available.
Request written confirmation of any SAR threshold logic.
Step 3: Post-Transaction Follow-Up
Verify title-deed office filed MASAK report for property deals.
Check your bank’s internal system shows “CDD completed”.
Retain all emails, PDFs, and receipts for 5-year retention.
Templates & Tools
CDD Document Checklist (downloadable PDF link)
BO Registry Submission Guide (step-by-step screenshots)
SAR Form Template (for advisers drafting on your behalf)
MASAK e-portal link: https://masak.gov.tr/ebildirim
8. Future Outlook: What’s Next?
2026: Introduction of blockchain for BO registry—instant public verification.
2027: EU-style whistleblower protection for internal SAR reporters.
Digital ID interoperability with EU E-IDAS system—enabling cross-border banking.
Foreign investors who adopt a “compliance first” mindset will enjoy faster transactions, preferential financing, and enhanced reputation—key assets in a world where transparency is currency.
9. FAQs
Q1: I bought a small Airbnb for €30K—do I need to worry?
Yes. Even though your purchase is below the CDD threshold, if your cumulative dealings with that bank exceed TRY 30,000, they’ll still ask for ID, address, and source-of-funds.
Q2: My company is 51% foreign-owned—what BO steps apply?
You must declare each shareholder owning ≥ 25%. If you’re the sole majority, list your name, nationality, and share percentage in MERSIS within 10 days of formation.
Q3: Can I use a virtual office address for CDD?
No. Banks require proof of physical address, such as a signed rental contract or utility bill. Virtual offices are not accepted.
Q4: How do I contest a SAR if I believe it’s unfounded?
Work with your bank’s compliance officer to provide supporting documents. If unresolved, file a written appeal to MASAK with evidence.
Q5: Do crypto-to-fiat conversions trigger AML checks?
Yes. Turkish-licensed exchanges must apply CDD and file SARs for large or suspicious trades. Expect to provide wallet-linking proof and exchange statements.
10. Tools & Resources
MASAK e-Bildirim Portal: https://masak.gov.tr/ebildirim
MERSIS BO Registry: https://mersis.gtb.gov.tr
e-Devlet e-signature Activation: https://www.turkiye.gov.tr/edevlet-sifresi
FATF Turkish Mutual Evaluation Report (2024): [Download PDF]
EU AML Directives Overview: [Link]
Final Thoughts
Turkey’s 2025 AML/CFT enhancements reflect a global shift towards transparency and accountability. As a foreign investor, embracing these measures not only keeps you compliant—it positions you as a trusted partner in Turkey’s economy. By following the roadmap, leveraging digital IDs, and partnering with experienced advisors, you can navigate AML/CFT obligations smoothly and focus on what you do best: growing your investments.
📌 Need AML/CFT Compliance Support?
At Ensari Yiğitcan Çakmak Law Office, we provide:
AML/CFT risk assessments for your investments
Due-diligence document preparation & review
Beneficial-ownership registry filing
Suspicious-activity reporting assistance
Training and workshops for foreign investor teams
📞 Stay compliant—contact us today:
🌐 www.ensariyigitcancakmak.av.tr
📧 info@ensariyigitcancakmak.av.tr
📱 +90 533 194 52 14
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