New Developments (In brief)
The Regulation Amending the Regulation on Measures Regarding the Prevention of Laundering of Proceeds of Crime and Financing of Terrorism (“Amendment Regulation”), published in the Official Gazette dated 13 February 2026 and numbered 33167, expanded the scope of obliged parties under the Regulation on Measures Regarding the Prevention of Laundering of Proceeds of Crime and Financing of Terrorism (“Measures Regulation”).
You can access Amendment Regulation here, and Measures Regulation here.
What changes do the amendments bring?
Pursuant to the Amendment Regulation, the scope of obliged parties set forth under paragraph (1) of Article 4 of the Measures Regulation has been expanded by adding a new subparagraph to follow subparagraph (y).
Within this scope, from the date of publication of the Amendment Regulation, persons and entities providing cash or valuable goods transportation services within the scope of Law No. 5188 on Private Security Services dated 10 June 2004 are obliged parties under the Measures Regulation.
Within this scope, pursuant to Law No. 5188 on Private Security Services dated 10 June 2004, entities providing cash or valuables transportation services have now become subject to the obligations set forth under Law 5549 on the Prevention of Laundering of Proceeds of Crime (“Law No. 5549“) and Measures Regulation. In this context, such service providers are expected to fulfil various obligations, including but not limited to know your customer, suspicious transaction reporting, identification of the beneficial owner, and providing documents and information to MASAK.
Failure to comply with these obligations may result in the imposition of the sanctions set out below.
| Obligation | Consequences of non-compliance |
| Know your customer | Administrative fine of TRY 30,000 for each violation (subject to revaluation) For 2026: TRY 284,449 |
| Suspicious Transaction Reporting | Administrative fine of TRY 50,000 for each violation (subject to revaluation) For 2026: TRY 474,079 |
| Confidentiality of suspicious transaction reports | Imprisonment for a term of one to three years and a judicial fine of up to 5,000 days (equivalent to between TRY 500,000 and TRY 2,500,000). Security measures applicable to legal entities are imposed on the obliged party. Such security measures include (i) revocation of license/permit and (ii) confiscation of assets or material benefits. |
| Continuous reporting of certain transactions | Administrative fine of TRY 30,000 for each violation (subject to revaluation) For 2026: TRY 284,449 |
| Provision of information and documents upon request by MASAK | Imprisonment for a term of one to three years and a judicial fine of up to 5,000 days (equivalent to between TRY 500,000 and TRY 2,500,000). Security measures applicable to legal entities are imposed on the obliged party. Such security measures include (i) revocation of license/permit and (ii) confiscation of assets or material benefits. |
| Retention of documents and other information relating to transactions | Imprisonment for a term of one to three years and a judicial fine of up to 5,000 days (equivalent to between TRY 500,000 and TRY 2,500,000). Security measures applicable to legal entities are imposed on the obliged party. Such security measures include (i) revocation of license/permit and (ii) confiscation of assets or material benefits. |
Conclusion
The Amendment Regulation entered into force on its date of publication. Within this scope, persons and entities providing cash or valuable goods transportation services under the Law No. 5188 on Private Security Services dated 10 June 2004 must comply with the obligations regulated under Law No. 5549 and the Measures Regulation, including, but not limited to, know your customer, suspicious transaction reporting and identification of ultimate beneficial owners. Failure to comply with the relevant obligations may result in the imposition of administrative fines and imprisonment.
To prevent future violations, the newly designated obligated parties are advised to closely review their responsibilities and to take necessary measures to effectively fulfill their obligations.
