Article
MASAK’s Draft Communiqué No.30: Raising the Bar for Transaction Transparency
The comprehensive rules are designed to promote transparency, ensure the traceability of funds, and reinforce the integrity of Türkiye’s financial system.
Objectives and scope
The primary aim of the Communiqué is to strengthen the framework for customer due diligence and transaction monitoring within financial institutions. By introducing more comprehensive requirements for the oversight and reporting of cash transactions, electronic transfers, and other financial operations, the Communiqué seeks to prevent illicit financial flows and ensure greater transparency in the financial system.
In line with the recommendations of the FATF, the Communiqué is designed to address prevention of money laundering and financing of terrorism, as well as to combat the informal economy. It introduces a risk-based approach, requiring institutions to pay special attention to transactions that deviate from the customer profile or lack a clear and legitimate legal or economic purpose. By doing so, the Communiqué not only aims to protect the integrity of the financial sector but also to reinforce public trust and support Türkiye’s broader efforts to align with international standards in financial crime prevention.
The scope of the Communiqué extends to banks, financial institutions as defined under the Regulation on Measures Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism (“Measures Regulation”) and electronic money institutions. The measures apply to both individual and corporate customers, and encompass a wide range of financial activities, including cash deposits and withdrawals and electronic transfers.
Key measures and institutional structure
The Communiqué introduces a series of enhanced measures and establishes a stricter framework to ensure effective compliance with international standards on anti-money laundering and counter-terrorism financing.
Enhanced Monitoring and Reporting Obligations
As an extension of the Measures Regulation, the Communiqué sets out stricter measures that financial institutions are required to apply during cash transactions. Accordingly, financial institutions are obliged to closely monitor their customers’ cash activities and pay special attention to those that are unusually large or frequent, lack a clear legal or economic purpose, or do not match the customer profile. Necessary steps must also be taken to obtain enough information about the nature of any requested transaction.
Mandatory Declaration of Transaction Purpose
According to the Communiqué, customers must declare the purpose of the transaction for electronic transfers and cash transactions. Financial institutions must provide customers with a list of the most common transaction types, including but not limited to real estate payments, vehicle purchases, loans, gifts, taxes, insurance, legal fees, health payments, crypto/digital assets, gambling, and entertainment. If a customer selects a generic option such as “other” or “individual payment,” a detailed explanation of at least 20 characters will be required.
Thresholds and Documentation Requirements
The Communiqué sets forth various documentation requirements depending on the transaction value as below. If the customer fails to fulfil the below obligations, the financial institution cannot proceed with the transaction.
| Transaction value (in cash) | Measure |
|---|---|
Below TRY 200,000 | General monitoring of unusual transactions |
TRY 2,000,001 – 20,000,000 | Cash transaction declaration form |
More than TRY 20,000,000 | Cash transaction declaration form with a detailed explanation regarding the source of the transaction and supporting documentation |
Exemptions
Certain transactions are specifically excluded from the scope of the obligations. Accordingly, the following transactions are not subject to the obligations set forth under the Communiqué:
- Transactions between a customer’s own accounts within the same financial institution;
- Transactions where the customer is a public institution or organisation;
- Interbank transactions and those carried out under correspondent banking arrangements;
- Electronic transactions and remittances performed via ATMs, provided the total amount (or the sum of related transactions) does not exceed TRY 15,000; and
- Cash transactions performed via ATMs provided the total amount (or the sum of related transactions) does not exceed TRY 200,000.
Next steps
The Draft Communiqué was submitted for public consultation until August 18, 2025. Following the evaluation of feedback and suggestions received from stakeholders and relevant parties during this period, the Draft Communiqué is expected to enter into force as of January 1, 2026.