New Draft Communiqué from MASAK: Gradual Declaration Period for Financial Transactions

The Turkish Financial Crimes Investigation Board (MASAK) published a new draft communiqué (Draft) on 1 August. The regulation aims to increase transparency and prevent unregistered transactions in EFT, wire transfers and cash transactions. The Draft has a broad scope, covering everything from daily money transfers to high-value commercial transactions. Within this framework, the objective is to prevent the laundering of criminal proceeds and the financing of terrorism, as well as to combat the informal economy.

Draft stipulates a risk-based system. Rather than requiring an additional application, it imposes a declaration obligation that varies based on the amount of the transaction. Based on the value of a single  transaction amount or the total amount of multiple related transactions, the system is structured as follows:

- Cash transactions between 0 and 200,000 Turkish liras: No obligation to declare.

- For cash transactions between 200,001 and 2,000,000 Turkish liras: The customer must specify the nature of the transaction. At this stage, financial institutions are expected to offer customers the most commonly used transaction types as options. The customer must select one of the specified categories for the nature of the transaction. If none is appropriate, the customer must enter an explanation of at least 20 characters.

- For cash transactions between 2,000,001 and 20,000,000 Turkish liras: For transactions within this amount range, financial institutions are required to ensure that the “Cash Transaction Declaration Form” included in the annex to the communiqué is filled out for the declaration of the nature of the transaction. If the Cash Transaction Declaration Form contains general options such as “other” or “individual payment” that do not provide concrete information about the nature of the transaction, and if these options are selected by the customer, a description of at least 20 characters must be provided regarding the nature of the transaction.

- For cash transactions exceeding 20,000,000 Turkish liras: In addition to completing the Cash Transaction Declaration Form, the customer is required to submit additional supporting documents (e.g., invoice, contract) for the transaction.

Who Will Be Affected by The New Regulation?

Financial institutions will be required to integrate this gradual declaration system into their infrastructure. For customer's, there will be no change if, for instance, an EFT transaction of less than 200,000 Turkish liras is made.

Exceptions are as follows:

- Transactions are carried out between the customers’ accounts within the same financial institution.

- Transactions where the customer is a state institution or organisation.

- Transactions are carried out between banks where the customer is a bank.

- Electronic transfer and remittance transactions made through ATMs, where the transaction amount or the total amount of multiple related transactions does not exceed 15,000 TRY (within the amount specified in Article 5/1-c of the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism).

- Cash transactions conducted via ATMs where the transaction amount or the total amount of multiple interconnected transactions does not exceed 200,000 Turkish liras.

The fundamental drivers behind this system can be summarised under two headings:

1. Enhancing Turkey's compliance with its international obligations. In particular, FATF (Financial Action Task Force) standards are targeted.

2. The aim is to reduce unregistered cash flows within the country and make the financial system more monitorable.

In conclusion it should be noted that this regulation is still in draft status. MASAK will continue to collect opinions and suggestions from public institutions and private sector representatives until 18/08/2025. The Draft also states that the relevant communiqué will come into force on 01/01/2026.