Recent Development
MASAK published new suspicious transaction reporting guidelines on its official website on 13 June 2025, while updating some of the preexisting guidelines applicable to certain obliged parties. Additionally, the MASAK Online 2.0 system was announced on MASAK’s official website on 13 June 2025 as the designated platform for submitting suspicious transaction reports electronically.
The obliged parties covered by the newly issued guidelines are as follows:
- Electronic commerce intermediary service providers
- Investment partnerships
- Insurance and reinsurance brokers
- Those who deal with the purchase and sale of any kind of sea, air and land transportation vehicles, including construction machines, and those who act as intermediaries for these transactions
- Dealers and auctioneers of historical artifacts, antiques and works of art
- Sports clubs
- Public notaries
- Lawyers[1]
- Certified general accountants, certified public accountants and sworn-in certified public accountants operating without being attached to an employer
- Independent audit institutions authorized to conduct audits in financial markets
The obliged parties covered by the updated guidelines are as follows:
- Those who deal with the purchase and sale of precious metals, stones and jewelry, and those who act as intermediaries for these transactions
- Those who buy and sell immovables for trading purposes and intermediaries of these transactions
Key changes in the newly published and updated guidelines
The key changes introduced in the newly published and updated guidelines, which came into effect on 16 June 2025, are outlined below.
- Tailored examples of suspicious transactions for the relevant obliged parties
The newly published guidelines introduce examples of suspicious transactions that are specifically tailored to the respective obliged parties. As for the updated guidelines, the suspicious transaction examples for the relevant obliged parties have been expanded. In this regard, obliged parties that fall within the relevant groups are advised to review the suspicious transaction examples provided in the newly published or updated guidelines.
- Electronic submission of suspicious transaction reports
Effective 16 June 2025, all suspicious transaction reports submitted by obliged parties must adhere to the procedures and principles outlined in the newly published or updated guidelines. Except where handwritten submission is required, all reports must be filed electronically via the MASAK Online 2.0 system. For registration with MASAK Online, obliged parties are advised to review the MASAK Online application guidelines. Where electronic submission is not possible due to unavoidable circumstances, reports may be prepared in paper format and submitted directly to MASAK.
With respect to the updated guidelines, particular attention should be paid to the applicable version based on the reporting date. Reports that must be submitted before 16 June 2025 should comply with the procedures and principles outlined in the previous version of the relevant guidelines, whereas reports submitted on or after that date must adhere to the procedures and principles specified in the updated version.
Conclusion
In line with the newly published and updated guidelines that entered into force on 16 June 2025, obliged parties are required to submit suspicious transaction reports to MASAK in accordance with the specified procedures and principles. It is particularly important for the obliged parties listed above to consider the suspicious transaction examples specifically outlined in the guidelines relevant to their category. That said, the suspicious transaction examples provided in the guidelines are illustrative in nature, and obliged parties are expected to assess each case individually to determine whether it constitutes a suspicious transaction.
Failure to comply with the obligation to report suspicious transactions will result in administrative fines for the relevant obliged parties. For 2025, the administrative fine for noncompliance is set at TRY 377,783 for certain nonfinancial business and professional groups, and TRY 755,566 for financial institutions. For the sake of completeness, non-compliance with the rules set out in these guidelines, in cases resulting in a breach or suspected breach of another regulatory framework, may entail the imposition of different sanctions for violation of the relevant regulation, in addition to the fines provided for herein.
[1] Under subparagraph (ş) of the first paragraph of Article 4 of the Regulation on Measures regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism, lawyers deemed as obliged parties refer to private practice lawyers whose activities are limited to the execution of certain legal transactions, provided that (i) the information obtained during professional activities conducted within the scope of alternative dispute resolution methods is excluded, (ii) the provisions of other laws regarding the right to defense and the right to a fair hearing are not violated and (iii) the provisions of Article 36 of Law No. 1136, which pertain exclusively to matters that can only be handled by attorneys, remain reserved. The transactions for which the lawyers are designated as obliged parties include purchasing and selling immovables; establishing and removing limited real rights; forming, merging, managing, transferring and liquidating companies, foundations and associations; and managing banks, securities and all types of accounts, as well as the assets contained in them.
