The Financial Crimes Investigation Board (MASAK) is Turkey's primary regulatory authority in the fight against money laundering. The vast majority of financial service companies carry various obligations under MASAK. In this article, we explain what an AML compliance programme is, which companies are required to have one, and how to implement it.
AML stands for Anti-Money Laundering. MASAK supervises the compliance activities of obligated institutions under Law No. 5549 on the Prevention of Laundering Proceeds of Crime.
Note: Crypto asset platforms have been explicitly defined as MASAK obligees as of 2024. All companies operating in this space are required to establish a compliance programme.
Money laundering and terrorist financing risks are assessed based on the company's services, client profile and operating geographies. This assessment forms the foundation of the compliance programme.
Verification of the identities of customers and businesses, risk-based classification and ongoing monitoring. Screening for politically exposed persons (PEPs) and sanctions lists falls within this scope.
Where there is a suspicion of money laundering or terrorist financing, notification to MASAK is mandatory. This process must be supported by internal procedures.
Institutions above a certain threshold are required to appoint a suitably qualified compliance officer. The compliance officer is responsible for operating the programme and reporting.
All employees must receive regular training on AML obligations.
MASAK inspections may result in administrative fines, operational restrictions and licence revocation for identified non-compliance. Criminal liability may also arise in serious cases.
Contact Koru Legal for a company-specific risk assessment and AML compliance programme design. We also provide full support for MASAK notification and reporting processes.
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