Crypto Travel Rule Legislation in Turkey: Understanding the New Requirements for Crypto Asset Transfers

Crypto Travel Rule Legislation in Turkey: Understanding the New Requirements for Crypto Asset Transfers

In line with global efforts to enhance transparency and combat money laundering, Turkey has implemented new regulatory measures for crypto asset transfers. These regulations, outlined in Article 24/A, introduce several requirements for crypto service providers, aimed at ensuring secure and compliant transactions for crypto users. This blog post explores the key provisions, addressing the essentials that both crypto service providers and users need to understand regarding the travel rule.

1. What Information Must Be Provided in Crypto Asset Transfer Messages?

For crypto transactions of 15,000 Turkish Lira (TRY) or more, service providers must ensure that the following information is included in the transfer message for the sender:

• Personal Identification: The full name of the individual or the registered name of a legal entity, including non-corporate entities.

• Wallet Information: The sender’s wallet address or, if unavailable, the reference number of the transaction.

• Identification Information: At least one of the following identifiers: address, date and place of birth, customer number, citizenship number, passport number, or tax ID number.

In addition to the sender’s details, the receiver’s information (as per points (a) and (b)) must also be included. However, unlike the sender’s information, the verification of the receiver's details is not mandatory.

2. What About Transfers Below 15,000 TRY?

For crypto transfers under 15,000 TRY, both the sender and receiver’s details (as per the information in points (a) and (b)) must be included. While the inclusion of this information is mandatory, there is no obligation for verifying these details.

3. What Happens If Required Information is Missing?

If a crypto service provider receives a transfer message that does not include the required details as outlined above, they must request the missing information from the sending provider. Should the required information remain incomplete, the transfer will be returned.

Continual missing information from a sender could result in actions such as:

• Rejection of transfers from the sender’s crypto service provider.

• Limitation of transactions with the sender’s service provider.

• Termination of business relations with the sender’s service provider.

4. Ensuring Data Integrity Across the Transfer Chain

From the sender’s initial transfer request to the final recipient's service provider, all intermediaries must ensure that the required sender information is passed along correctly. Each crypto service provider in the chain must ensure that these details are conveyed securely at every step of the transfer process.

5. What Technologies Can Be Used to Securely Transmit Data?

To ensure the secure transmission of data, service providers may use technologies like distributed ledger technology (DLT), independent messaging platforms, or application interfaces that facilitate communication and meet regulatory standards for secure data sharing.

6. What If the Wallet Address is Not Registered with a Service Provider?

In cases where a crypto transfer is made to or from an unregistered wallet address, service providers must obtain a declaration from the customer about the identity of the unregistered wallet owner. This declaration must include at least one of the following identifiers: full name (for individuals), registered name (for entities), or any other data that helps to identify the person, such as address, birth date, customer number, passport number, tax ID, or citizenship number.

7. How Are International Transfers Handled?

When crypto assets are transferred to or from a service provider outside Turkey, and the foreign service provider is not obligated to share sender/receiver details under their local regulations, the Turkish provider must still request a declaration from the customer. This declaration will include the sender's or receiver's name, address, birth date, customer number, citizenship number, passport number, or tax ID.

If the foreign service provider uses a messaging system that complies with the fifth paragraph outlined in the regulation, the details may be transferred via the system.

8. What Is the Role of Risk-Based Approach in This Legislation?

The regulation introduces a risk-based approach, whereby service providers may request additional information and documentation from the customer if the transfer raises any concerns. If there is insufficient information regarding the parties involved, the transfer may not proceed. Furthermore, transactions with the involved financial institution may be limited, or the business relationship may be terminated.

Key Takeaways:

Conclusion

The new regulations regarding crypto asset transfers in Turkey significantly align with global efforts to ensure that the crypto market remains transparent, secure, and compliant with anti-money laundering standards. Crypto service providers, along with their customers, must remain diligent in meeting these new requirements to ensure smooth and compliant transactions in 2025 and beyond.

Stay Compliant and Secure Your Crypto Transactions

To ensure your crypto transfers are in full compliance with Turkey’s latest regulations, it's crucial to stay informed and prepared. Whether you're a crypto service provider or an individual engaging in crypto transactions, understanding the new Crypto Travel Rule is essential.

Need guidance on how to implement these changes in your business or personal crypto transactions? Contact us today to learn more about the best practices and how we can help you navigate the evolving crypto regulatory landscape.

info@ozmconsultancy.com

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