Crypto Exchange Licensing in Turkey: Requirements, Costs & Compliance Guide

• By JayKay Sun
• 9 Jan, 2025
• 25 Comments

In July2025, Turkish regulators pulled the plug on 46 unlicensed crypto platforms, leaving thousands of traders scrambling for a legal alternative. That decisive move signaled the country’s commitment to a formal licensing regime for crypto‑asset service providers (CASPs). If you’re eyeing the Turkish market-whether as a local startup or a foreign exchange looking to set up a foothold-understanding the new framework is non‑negotiable.

Quick Takeaways

• Licensing is handled by the Capital Markets Board (Capital Markets Board (CMB) Turkey’s securities regulator responsible for granting crypto‑exchange licenses).
• Minimum paid‑in capital: 150millionTRY for exchanges, 500millionTRY for custodial services.
• Annual fee: 1% of gross revenue to the CMB plus 1% to TUBITAK.
• AML/KYC trigger: transactions over 15,000TRY must be fully verified.
• Foreign operators can’t actively market or maintain a physical office in Turkey.

Legal Foundations: Communiqué I & II

The regime rests on two official communiqués published in the Official Gazette Turkey’s legal publication where new regulations are announced on 13March2025. CommuniquéI (III‑35/B.1) lays out the definition of a CASP, ownership rules, and the overarching principles. CommuniquéII (III‑35/B.2) dives into operational details: capital adequacy, risk‑management obligations, and reporting procedures. Together they provide a “full‑stack” licensing model that mirrors the EU’s MiCA but with tougher capital thresholds.

Who Issues the License?

The Capital Markets Board (CMB) Turkey’s primary financial regulator for securities and crypto‑asset services evaluates applications, runs fit‑and‑proper tests, and ultimately issues the license. The process involves:

1. Submission of a corporate restructuring plan that converts the applicant into a joint‑stock company (pay‑in shares must be cash‑based and registered by name).
2. Proof of the minimum paid‑in capital (150millionTRY for exchanges, 500millionTRY for custodians).
3. Documentation of internal controls, cybersecurity safeguards, and audit frameworks.
4. Background checks on founders, board members, and senior managers-both financial integrity and criminal‑record screenings.
5. Approval by the CMB’s Licensing Committee, followed by a registration in the “Financial Services Registry”.

Capital & Financial Requirements

Capital is the most visible hurdle. As of 2025, the required paid‑in capital equals roughly $4.1millionUSD for an exchange and $13.7millionUSD for a custodial service. Compared with Singapore’s S$1million threshold or the UK’s £1million requirement, Turkey sits in the mid‑range-high enough to deter fly‑by‑night operators but not prohibitive for serious players.

Beyond the upfront capital, the law imposes an annual fee of 1% of total income (excluding interest) payable to the CMB and an additional 1% to the Scientific and Technological Research Council of Turkey (TUBITAK) government agency that funds research and innovation projects. The combined 2% revenue charge is effectively a “regulatory tax” that scales with business size.

Ownership, Management & Fit‑and‑Proper Tests

Applicants must demonstrate:

• Clean legal records for all shareholders holding >5% of equity.
• At least one Turkish resident director with a minimum of three years’ experience in finance or technology.
• Independent audit committees and a designated compliance officer who reports directly to the board.

MASAK, Turkey’s Financial Crimes Investigation Board (MASAK Turkey’s AML and counter‑terrorism financing authority), conducts its own fit‑and‑proper assessment, focusing on the applicant’s AML/KYC track record.

AML/KYC Obligations: What You Need to Know

Every transaction over 15,000TRY (~$425USD) triggers mandatory identity verification. The required data includes full name, national ID, address, and source‑of‑funds declaration. In addition:

• Real‑time monitoring systems must flag suspicious patterns and report them within 24hours to MASAK.
• All transaction logs-including canceled or unexecuted orders-must be stored for at least five years.
• MASAK can freeze both crypto wallets and linked bank accounts without a prior court order if it suspects money‑laundering activity.

Failure to comply can lead to fines up to 5% of annual revenue, license suspension, or outright revocation.

Operational Costs Beyond Capital

While the capital floor is clear, the day‑to‑day expense profile is more nuanced:

• Compliance infrastructure: Dedicated AML/KYC teams (usually 3‑5 analysts for a midsize exchange) and a technology stack costing $200‑$300k per year.
• Risk‑management: Price‑monitoring tools that detect wash‑trading or spoofing, typically licensed from third‑party vendors.
• Banking integration: Because the Central Bank of Turkey (TCMB) still bans crypto for payments, exchanges must partner with banks that allow fiat‑on‑ramp services, often incurring higher transaction fees.
• Audit & reporting: Annual external audits required by the CMB, averaging $100k for a compliant entity.

Foreign Participation: Restrictions You Can’t Ignore

Non‑resident CASPs may register a Turkish subsidiary but are barred from active marketing within Turkey. The law also requires a local physical presence for any customer‑facing operation. In practice, this means a foreign exchange must set up a Turkish joint‑stock company, hire resident directors, and maintain an office-often a co‑working space-to satisfy the “local presence” clause.

Compared with Malta’s open‑door policy that encourages offshore entities, Turkey’s stance is more protectionist, aiming to keep capital and data inside its borders.

How Turkey Stacks Up: A Quick Comparison

Application Timeline & Practical Tips

Preparing a solid license application typically takes 6‑12months. Here’s a roadmap most applicants follow:

1. Corporate restructuring: Convert to a joint‑stock company, allocate the required paid‑in capital, and open a Turkish corporate bank account.
2. Compliance platform selection: Choose a KYC/AML vendor with native Turkish language support and the ability to generate MASAK‑compatible reports.
3. Documentation pack: Draft internal policies (cybersecurity, audit, risk‑management), board minutes, and shareholder declarations.
4. Legal review: Engage a Istanbul‑based fintech law firm that can produce bilingual submission forms and liaise with the CMB.
5. Submission & review: File the application via the CMB’s e‑portal, respond to any clarification requests within the stipulated 30‑day window.
6. Post‑approval setup: Implement the mandated transaction‑recording system, train staff on MASAK reporting, and establish a local office.

Skipping any of these steps-especially the bilingual legal review-almost guarantees a rejection or a prolonged back‑and‑forth with regulators.

Risks, Enforcement & Market Realities

Since the July2025 crackdown, the CMB has issued warnings to licensed operators that miss even a single AML filing deadline. Penalties range from 50,000TRY fines to full license revocation. Moreover, MASAK’s authority to freeze assets without a court order adds a layer of operational risk not seen in many European jurisdictions.

On the upside, being licensed dramatically boosts user trust. Exchanges that secured a CMB license report a 20‑30% increase in daily active users within the first six months, largely because Turkish traders now prefer platforms that guarantee asset protection under national law.

Future Outlook

The regulatory landscape is still evolving. Analysts expect possible adjustments to foreign‑operator restrictions if international pressure mounts, and a potential reduction in capital thresholds for non‑custodial exchanges. Keeping tabs on CMB circulars and MASAK bulletins will be essential for staying compliant.