7
Supervisory bodies
2
Authorities at once
9
Sectors covered
1
AML supervisor / MASAK
02The regulatory landscape
02
Two authorities at once
Turkey does not run its financial-crime regime through a single door: authorisation sits with the sector supervisor, and AML/CFT supervision sits, across almost every sector, with MASAK, the Financial Crimes Investigation Board (Mali Suçları Araştırma Kurulu), reporting under the Ministry of Treasury and Finance. What an examiner tests: that you satisfy both the body that granted the licence and the body that inspects the programme behind it. The gap between them is where an operator gets caught.
- Licensed sectors: a bank, a payment institution, a portfolio management company and a crypto-asset service provider hold a positive grant from a named supervisor before they may operate.
- AML-only sectors: corporate and trust service providers, real-estate operators and other DNFBPs, and art and high-value dealers answer to MASAK directly, with no dedicated financial regulator.
- Prohibited: private commercial gambling. Getting this map wrong is the first failure a Turkish inspection exposes.
Capital markets
CMB / SPK The Capital Markets Board of Türkiye (Sermaye Piyasası Kurulu) authorises crypto-asset service providers and supervises portfolio management and funds. A licensing regime, not a notification one: the grant comes first, and the AML programme is inspected against it. CASP register → PMC register →
Banking
BRSA / BDDK The Banking Regulation and Supervision Agency (Bankacılık Düzenleme ve Denetleme Kurumu) licenses and supervises banks and financial institutions. Prudential and conduct supervision sits here; the financial-crime programme is inspected by MASAK in parallel. Register →
Payments
CBRT / TCMB The Central Bank of the Republic of Türkiye (Türkiye Cumhuriyet Merkez Bankası) authorises and oversees payment and electronic-money institutions. A payments operator holds a CBRT authorisation and a standing MASAK obligation at once. Register →
Treasury & exchange offices
HMB The Ministry of Treasury and Finance authorises exchange offices (yetkili müessese) on the money-services side, and through Milli Piyango and Spor Toto holds the state monopoly over lottery and sports betting. MASAK reports under this ministry, so on money-services and gaming the licensing authority and the AML supervisor share a parent.
Precious metals
BIST PMDM Borsa İstanbul operates the Precious Metals and Diamond Market (Kıymetli Madenler ve Kıymetli Taşlar Piyasası) and its membership regime for the gold and precious-metals trade. Membership is the access control; the dealer-side AML programme sits underneath it and is inspected by MASAK. Members →
Gaming
MPI / Spor Toto Private commercial gambling is prohibited in Turkey. Casinos and betting outside the state monopoly are banned; only state monopoly entities operate lottery and sports betting under the Ministry of Treasury and Finance, via Milli Piyango and Spor Toto.
Defence & dual-use
MSBMinistry of TradeSSB The Ministry of National Defence (strategic-trade and defence-export controls) and the Ministry of Trade (Ticaret Bakanlığı, export licensing of dual-use and controlled goods) govern the defence and dual-use sector, with the Presidency of Defence Industries (Savunma Sanayii Başkanlığı) alongside. An export-control and licensing regime layered over sanctions exposure, not conventional AML supervision.
AML supervision
MASAK The Financial Crimes Investigation Board (Mali Suçları Araştırma Kurulu) is the AML/CFT supervisor across the whole market and the recipient of suspicious-transaction reporting. For corporate and trust service providers, real estate and DNFBPs, and art and high-value dealers there is no separate financial regulator: the obligation runs to MASAK directly.
Every body above is drawn from the verified Turkey regulator matrix. The current framework is what we build against: any specific rule change, effective date, transition window, threshold or penalty is verified with the named regulator before it is stated as fact, and none is asserted here.
03Who operates here, and what they must build
Authorised or seeking authorisation in Turkey, you carry a standing AML/CFT and sanctions obligation to MASAK, whichever sector supervisor granted your licence, or none did. That obligation is not a policy document on a shelf: it is a working programme with named owners, live controls and an audit trail that survives inspection. What a Turkish operator must build and then actually run:
01A formally appointed compliance officer function with the standing and independence the framework requires, notified to MASAK where the rules demand, plus the deputy, reporting lines and authority to escalate without being overruled by the business.
02Customer and enhanced due diligence keyed to your risk, sectors and cross-border exposure, with beneficial-ownership identification that holds up on complex, layered ownership structures.
03Transaction monitoring and suspicious-transaction reporting into MASAK that fires on real typologies, not a switched-off rule set, on MASAK's timelines rather than a best-effort backlog.
04A sanctions and screening capability calibrated to Turkey's cross-border position, including the FATF Travel Rule for crypto-asset transfers where you carry client value across the chain.
05A written, tested and inspectable AML programme: enterprise-wide risk assessment, policies, procedures, staff training, record-keeping and independent audit, refreshed as the regime moves.
Turkey pairs a sector licence, where one exists, with a live MASAK obligation that always exists. Passing the first inspection is not the same as running a programme that survives the second. That gap is the work.
04Nine sectors, even weight
How we serve every sector here
Coverage here is even. Every sector below is fully served, under the supervisor that actually governs it. No flagship, no filler.
VASP & cryptoA crypto-asset service provider is licensed by the CMB and AML-supervised by MASAK. We build the licensing-stage programme and Travel Rule controls, then run the MLRO and monitoring function MASAK inspects.
Payments & MSBCBRT payment and e-money authorisations, plus HMB-authorised exchange offices (yetkili müessese). We build and staff the AML/CFT programme behind the authorisation, then run it operator-side.
Banks & FIsBRSA-licensed banks and financial institutions, AML-supervised by MASAK. We remediate, audit and run the financial-crime programme, and provide bridge cover when the second line has a gap.
Funds & CSPCMB-supervised portfolio management companies; corporate and trust service providers answer to MASAK with no dedicated financial regulator. We build the programme for both.
Gold & DPMSMembership of the Borsa İstanbul Precious Metals and Diamond Market is the access control; the AML programme sits underneath. We build the dealer-side programme and due-diligence controls.
GamingPrivate commercial gambling is prohibited; only state monopoly entities operate under the Treasury via Milli Piyango and Spor Toto. Our work here is integrity, sanctions and AML advisory scoped to what the law permits.
Real estate & DNFBPMASAK supervises directly, with no dedicated financial regulator. We build the AML programme, CDD and reporting obligations real-estate operators and other DNFBPs carry to MASAK.
Defence & dual-useMinistry of National Defence strategic-trade controls, Ministry of Trade export licensing and the SSB. We build the export-control, sanctions and integrity due-diligence programme for controlled and dual-use trade.
Art & high-valueMASAK supervises with no dedicated regulator. We build the AML and provenance due-diligence programme for art and high-value dealers subject to MASAK supervision.
05The five service lines, in this market
01
Licensing and new-regime programme build. The AML/CFT and sanctions programme that sits behind a CMB, BRSA, CBRT or HMB authorisation, or behind BIST market membership, built to the standard MASAK inspects to, ready before the first review.
02
Remediation. Post-finding or post-enforcement rebuild of a Turkish programme, on a fixed scope, with the evidence trail MASAK and the sector supervisor will ask for and a defensible closure record.
03
Outsourced and bridge compliance officer, plus a managed reporting function. A senior officer and a working suspicious-transaction reporting line into MASAK while you recruit, scale, or stabilise after a departure.
04
Independent AML audit. The independent review the framework expects, run by a practitioner who did not build the thing being reviewed.
05
Sanctions, export-control and integrity due diligence. Counterparty, corridor, beneficial-owner and Travel Rule work, calibrated to Turkey's cross-border position, including controls for dual-use and strategic-goods exposure under the defence-export regime.
Fixed scope. Fixed fee. No hourly billing. A costed plan within 48 hours.
06The operator-side value
Independent and conflict-free
We sell no software and take no commissions. We do not refer you to a product we are paid to place. We are the reviewer, not the seller.
Operator-side only
Lawyers file the application. We build the programme that has to work after it is granted, and we run it when you need us to.
Senior-only
The people who scope your Turkey engagement are the people who do it. No pass-down to a junior bench.
Fixed scope, fixed fee
You get a costed plan within 48 hours and no hourly billing. You know the shape of the work before it starts.
Briefing seriesCurrent and datedA live financial-crime and regulatory briefing feed on how frontier and Gulf regimes actually move, the CMB and MASAK perimeter among them.Insights →
Local partnersLocal legal standingLicensed local law-firm and compliance partners in our markets.Partners →
CredentialsCAMS / ICAThe people who run the programme hold CAMS and ICA qualifications. No client names, no invented cases.The firm →
Build the programme MASAK will actually inspect.
Send us your Turkish licence, or the one you are applying for, and we will return a fixed scope for the programme behind it.