By the Regulation Regarding the Amendment to the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism published at the Official Gazette dated 1 May 2021 with no. 31471 (the “Regulation”), crypto asset service providers and saving finance companies are now deemed to be one of the obligors within the scope of the legislation on the prevention of laundering crime proceeds and financing of terrorism.

Crypto asset service providers and saving finance companies are now included in the definition of obligors under the Regulation. In this context, the aforementioned companies, as of 1 May 2021, are liable for the fulfilment of the obligations stipulated under the Law on Anti-Money Laundering No 5549 and other relevant legislation, including the obligations of conducting KYC procedures, notifying suspicious transactions, periodically reporting, retaining and submitting information, for the prevention of laundering crime proceeds and financing of terrorism.

Nevertheless, the Regulation is silent on the definition of ‘crypto asset service providers’.