Turkey Crypto Regulation 2026: CMB VASP Licensing & Compliance

The CMB VASP licence requires applicants to meet substantial financial and operational requirements. Under CMB Communiqué III-35/B.2, minimum founding capital is TRY 150 million for a crypto asset trading platform and TRY 500 million for a custodian, paid in full in cash, and the CMB can raise both amounts each year in line with the official revaluation rate. Lira depreciation makes the hard-currency cost of this capital a planning item in its own right.

Turkey's Financial Crimes Investigation Board (MASAK — Mali Suçları Araştırma Kurulu) supervises AML/CFT compliance for all financial institutions including CMB-licensed VASPs. MASAK has been substantially strengthened as part of Turkey's FATF action plan, with expanded powers to investigate, supervise, and sanction non-compliant entities.

The Travel Rule in Turkey requires VASPs to collect and transmit originator and beneficiary information for crypto transfers above TRY 15,000 (subject to regulatory adjustment). The information transmission must include: full legal name, account number or wallet address, national identification number (T.C. Kimlik No for Turkish nationals), and transaction reference. VASPs must maintain systems capable of real-time Travel Rule compliance across both outgoing and incoming transfers.

MASAK-specific obligations for Turkish VASPs include: filing Suspicious Transaction Reports (STRs) within prescribed timeframes; maintaining transaction records for minimum eight years; screening all customers and transactions against UN Security Council lists, EU restrictive measures lists, and Turkey's own proscribed persons list (maintained by MASAK); reporting any transactions linked to Turkey's designated terrorist organisations or persons.

Turkey offers one of the most favourable individual crypto tax environments in Europe and MENA: as of 2026, individual investors pay 0% capital gains tax on profits from crypto asset disposals. This policy has contributed to Turkey's exceptionally high retail crypto adoption and makes Turkey particularly attractive as a market for retail-focused crypto platforms.

The Turkish government has periodically discussed introducing a withholding tax on crypto transactions — proposals have included rates from 0.03% to 0.1% on transaction values — but as of 2026 no withholding tax had been enacted.

For corporate entities (Turkish A.Ş. companies), crypto trading profits are treated as ordinary business income and subject to the standard corporate income tax rate of 25%. For VASP-licensed exchanges, fee income from crypto trading is also subject to 25% CIT. VAT treatment of crypto services remains an area where official guidance is evolving, with exchange services generally treated as VAT-exempt financial transactions under the Turkish Value Added Tax Law.

Banking access for CMB-licensed VASPs in Turkey is significantly better than in most emerging markets, with several major Turkish banks having established relationships with regulated crypto exchanges. The CMB licensing framework provides the regulatory basis for banks to extend accounts and payment services to crypto businesses, reducing the informal banking uncertainty that plagued the sector prior to 2024.

Major Turkish banks including Garanti BBVA, İş Bankası, and Yapı Kredi have been reported to provide banking services to compliant, CMB-licensed VASPs. The Turkish Interbank Card Center (BKM) and Turkey's instant payment system (FAST) provide efficient TRY settlement infrastructure. For TRY/crypto on-ramp and off-ramp services, partnerships with Turkish banks are essential and achievable with full CMB authorisation.

For international settlements and hard-currency treasury management, CMB-licensed VASPs typically maintain accounts at European or UAE banks. Turkey's foreign exchange regulations (enforced by the Central Bank of Turkey — TCMB) require attention: large outbound transfers may trigger reporting obligations, and companies must comply with export proceeds repatriation rules where applicable.