By 2025, CMB license has become mandatory for crypto exchanges and wallets in Türkiye.
Scope
- Crypto exchanges
- Wallet providers
- Intermediary organizations
- Token issuance services
Conditions
- Minimum capital
- Legal entity established in Türkiye
- Authorized managers
- Internal control systems
- Segregation of customer assets
- MASAK compliance
Customer Protection
- Customer asset is separate from the asset of the stock exchange
- Insurance obligation
- Customer is protected in case of bankruptcy
- KYC/AML mandatory
Penalties and Sanctions
- Unlicensed activity: administrative fine + criminal liability
- Customer damage: compensation
- Personal liability to managers in case of bankruptcy
Overseas Exchanges
- Cannot provide services to Türkiye (as a rule)
- Turkish customer must refuse
- With VPN access is legally problematic
Tax
- KVHS transactions are taxable
- Withholding tax
- Declaration obligation
CMB Approach
CMK predicts that the crypto market should be regulated with "investor protection" priority, and that the sector will become transparent by including domestic platforms within the scope of KVHS.
Practical. Recommendations (Investor)
- Prefer licensed platforms
- Check the license list on the CMB website
- Large assets in cold wallet
- Declare (tax liability)
Crypto and capital market law lawyer recommended.