Updates in Suspicious Transaction Notifications for Payment and Electronic Money Institutions

The Financial Crimes Investigation Board (MASAK) announced on 5 June 2024 that the Suspicious Transaction Notification Guide (Guideline) and the Suspicious Transaction Notification Guide Form (Form), which regulate the procedures and principles regarding suspicious transaction notifications specific to the payment and electronic money institutions sector, have been updated.

Pursuant to Law No. 5549 on the Prevention of Laundering Proceeds of Crime, obligated parties are required to submit suspicious transaction reports to MASAK. In General Communiqué No. 13, MASAK is authorized to publish general and sector-specific suspicious transaction notification guidelines for obligated parties. In this context, as with the banking sector, the relevant details for payment and electronic money institutions have also been established.

MASAK updated the Guideline and the Form within the framework of opinions and suggestions received from representatives and industry associations, as well as the National Risk Assessment Report on Combating Money Laundering and Financing of Terrorism.

The Guideline regulates the principles and procedures for how suspicious transaction notifications will be made by payment and electronic money institutions operating under Law No. 6493 on Payment and Securities Settlement Systems, Payment Services, and Electronic Money Institutions.

We have compiled the main changes in the Guideline below:

• — The form has been simplified to cover current financial technologies.
• — Sector-specific transaction (e.g. POS transactions, card transactions) and account types (e.g. credit account, time deposit account, digital wallet) have been added.
• — New types of suspicious transactions were included by taking into account the evolving and changing crime typologies, demonstrating that efforts are meticulously carried out to ensure that such guidelines are aligned with current developments.
• — Terrorist organization information and financing the proliferation of weapons of mass destruction were added to the notification categories.
• — Checkpoints were created to improve the quality of notifications in the description field for suspicious transactions.
• — Reference value tables were updated, and coding was renewed.
• — Sections on identification type and financial institution information intermediating the transaction have been added.
• — New categories of suspicion were added (e.g. smuggling of cigarettes, alcohol and tobacco products, pyramid schemes (Ponzi schemes), abuse of non-governmental organizations, illegal aid and fundraising activities) and the selection of the suspicion category was made mandatory.

Suspicious transaction reports submitted electronically until 7 June 2024 were made under the previous version of the Guideline before it was updated. However, after 7 June 2024, suspicious transaction notifications must be sent only in accordance with the principles and procedures set forth in the Guideline.

With the update of the Guideline and the Form, the "MASAK ONLINE 1.0" system, which enables electronic notification, has also been redesigned using the latest technology. Accordingly, within the scope of the "MASAK ONLINE 2.0" project, access security was enhanced, and sector-specific, flexible structures were enabled. An XML guide was prepared and shared with sector representatives to enable obliged parties to make their notifications faster and easier.

You can reach the full version of the updated Guide here (only available in Turkish) and the full version of the Form here (only available in Turkish).