Amendment to the Regulation on Compliance Programs: New Obligations and Transitional Provisions

The Regulation Amending the Regulation on Compliance Programs Regarding Obligations for the Prevention of Laundering Proceeds of Crime and Financing of Terrorism, published by the Ministry of Treasury and Finance (the “Ministry”), entered into force upon its publication in the Official Gazette dated 22 August 2025 and numbered 32994. The amendments introduce innovations in various areas ranging from the appointment requirements of compliance officers, the scope of obliged parties and notification requirements about transitional periods. While most of the provisions entered into force on the date of publication, some provisions are set to enter into force at a later date (25 December 2025).

1. Scope of Obliged Parties

Under the previous regulation, “development and investment banks” were included among the obliged parties subject to the compliance program. With the new regulation, this phrase has been removed and replaced with “İstanbul Settlement and Custody Bank” Furthermore, for the first time, dealers conducting games of luck and betting activities exclusively through electronic means without any physical workplace or face-to-face contact with customers, have also been included within the scope of the compliance program.

2. Appointment Requirements of Compliance Officers

Under the existing regulation, there was no restriction concerning the past activities of persons to be appointed as compliance officers or assistants. With the new regulation, it has been stipulated that persons who have conducted examinations or compliance audits of an obliged party within the two years preceding the appointment date cannot be appointed as a compliance officer or assistant for that same obliged entity.

3. Dismissal of Compliance Officers and Notification Obligation

Previously, the notification obligation to the Financial Crimes Investigation Board Presidency (“Presidency”) arose only if it was later understood that the compliance officer did not meet the necessary qualifications. With the new regulation, this scope has been expanded. From now on, in cases where the compliance officer is dismissed, notification must also be made to the Presidency together with the reasons for dismissal.

4. Qualifications of Compliance Officers and Transitional Provision

Under the existing regulation, compliance officers were already required to hold a university degree (Article 17/1-ç).

With the newly added Provisional Article 5, a transitional ease has been introduced for those who have been working as compliance officers for at least six months but do not meet this educational requirement. Such individuals, provided that their employment is certified with Social Security Institution records, may take the authorization exam within a period of two years. Those who succeed in this exam will be granted a Compliance Officer License, and with this license, they will be able to continue to serve as compliance officers or assistants without being subject to the university degree requirement. Moreover, during this two-year period, these individuals may continue to work as compliance officers even without fulfilling the university degree requirement.

5. Transitional Periods

With the new regulation, the deadline for development and investment banks to appoint a compliance officer and assistant has been set as 31 October 2025, and the deadline to establish their compliance programs has been set as 30 November 2025.

Dealers conducting games of luck and betting activities exclusively through electronic means are also required to appoint a compliance officer no later than 31 October 2025.

Most of the provisions of the regulation entered into force on the date of publication. However, provisions regarding restrictions on the appointment of compliance officers, the new qualification requirement, and the transitional licensing arrangements will enter into force on 25 December 2025.