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DLT and cryptocurrencies
FinTechs belonging to this category offer financial services using crypto currencies. This category also includes FinTechs utilising blockchain and distributed ledger technologies (DLT) upon which Bitcoin and Ethereum are based, among others. FinTechs develop and do research in this field in order to create new services – e.g. crypto currency exchange markets, wallet providers, NFTs-related services, new payment services, "smart contracts" or new clearing and settling services.


Attitude of the country towards financial services using crypto currencies

On 16 April 2021, the CBRT published the country’s first crypto-asset regulation, Regulation on the Use of Crypto-Assets in Payments, effective 30 April 2021, in Official Gazette numbered 314561. According to the regulation:

  • Crypto-assets cannot be used, directly or indirectly, to purchase goods and services in Turkey.
  • Crypto-assets cannot be used in the provision of payment services or issuance of e-money.
  • Intermediary financial services to crypto-asset platforms and service providers, including funds transfers, and custodial, settlement, and issuance services are prohibited.
  • Development of financial services business models involving crypto-assets is prohibited.

Other than that, blockchain, NFTs and crypto assets are not regulated under Turkish law. 

Legal affairs

Obligations and requirements to provide financial services using crypto currencies described above

Crypto assets are not regulated under Turkish law. It is understood, however, that a regulatory scheme is in process. Recently, the Ministry of Treasury and Finance announced crypto-money, indicating that there would be co-operation between the Banking Regulation and Supervision Agency (“BRSA”), the CMB and other related organisations to regulate this area. The Information and Communication Technologies Authority (“ICTA”) also announced in its strategy plan that the ICTA and TÜBITAK had initiated their work regarding the technology infrastructure for crypto currencies. Moreover, the Ministry of Treasury and Finance requested all users' information from the crypto-markets, which is considered by the market players as a concrete step towards regulating these markets.

Just as the crypto currencies, the NFTs are not specifically regulated under Turkish law. However, there are certain restrictions on the use of crypto assets in various regulated sectors. For instance, payment and electronic money institutions are forbidden to provide services directly or indirectly for the use of crypto assets as a means of payment, to develop business models, or provide services regarding those business models where crypto assets are used in the provision of payments services and issuance of electronic money. Similarly, capital markets intermediary institutions are not allowed to conduct any derivative or spot transaction based on crypto assets. In this regard, the use of the NFT in capital markets and payment services is not possible in Turkey. Furthermore, blockchain is currently not regulated under any specific law or regulation too. It is understood, however, from publicly available data that work on draft legislation is in progress. The use of crypto currencies in capital markets is prohibited.

Additional comments regarding the legal situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area

According to The Regulation on Amendment of Regulation on the Measures for Prevention of Laundering Proceeds of Crime and Terrorist Financing, crypto asset service providers, payment and electronic money institutions, debit and credit card issuance institutions are considered as obligated parties to com
ply with anti-money laundering rules. Cryptocurrency platforms that are in this scope must comply with rules regarding anti-money laundering including identification obligation and suspicious transaction reporting.

Economic conditions

Market size for financial services using crypto currencies and biggest companies in this business area

It is estimated that over 2.4 million people, 2.94% of Turkey’s total population, currently own crypto currency.

At the beginning of 2021, Turkish crypto exchanges BtcTurk and Paribu were trading in excess of USD 1 billion daily. Any discussion about crypto currencies in Turkey would not be complete without mentioning its expansion into the world of football. Turkey’s largest crypto exchange BtcTurk, which has over 1 million users trading on the platform, is now a major sponsor of both the Turkish men’s and women’s national teams in lieu of next year’s UEFA European Championship.

Additional comments regarding the economic situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area

The legal uncertainty at the moment creates a legal risk. However, crypto currencies are vastly popular among consumers.



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