Strict Oversight on Customer Due Diligence and Withdrawal Transactions: MASAK Communiqué Now in Force

With the new regulation published by the Financial Crimes Investigation Board (MASAK), stricter measures will be applied on the crypto asset service providers. The General Communiqué No. 29 was published in the Official Gazette on June 28, 2025, and has entered into force.

Key highlights are summarized below:

• Crypto asset service providers are now subject to more detailed identification and data collection obligations when establishing a business relationship with a customer. Especially for high-risk transactions, documents regarding the source of funds and purpose of the transaction must be regularly obtained.
• The transfer of the crypto assets of the customer to another platform may only be effectuated after at least 48 hours from the date of the transaction. This period is extended to 72 hours for the first withdrawal transactions.
• Daily and monthly limits have been introduced for transactions involving stable-value crypto assets:

Transfers of crypto assets, which are typically pegged to a currency and conducted via platforms, are now subject to restrictions.

Accordingly, the transfer of such assets to other platforms is limited to:

     i.     A maximum of 3,000 USD per day,

     ii.    A maximum of 50,000 USD per month.

If the transactions are carried out within the scope of specific risk measures, these limits may be doubled.

• It is mandatory to obtain a transaction description of at least 20 characters from the user for each crypto transfer.
• Liquidity providers, market makers, and arbitrage investors may be exempt from these restrictions under certain conditions. However, such exemption is only possible with a separate board of directors’ approval with respect to each individual customer and is subject to the condition of ongoing monitoring.
• Entities responsible for the custody of crypto assets are also subject to the same restrictions.
• The restrictions shall not apply to the transfers between platforms and custody institutions, operating under the capital markets legislation.
• In case of non-compliance with the Communiqué, legal sanctions stipulated under the Law may be imposed.