Mandatory Examination and Licensing Requirements Imposed on Employees Serving as Compliance Officers

The Financial Crimes Investigation Board’s Communiqué No. 30 (“Communiqué”) regulates the procedures and principles concerning the examination, professional training, licensing processes and registry requirements applicable to individuals who will be authorized to serve as compliance officers or assistant compliance officers at the subject entities.

The authorization examination shall be conducted either directly by the Financial Crimes Investigation Board (“Presidency”) or by institutions and organizations designated by the Presidency. In order to be eligible to sit for the examination, candidates must be citizens of the Republic of Turkey, not be deprived of public rights, not have been convicted of the offenses enumerated in the Communiqué, and have graduated from a higher education institution that provides at least a four-year program in Turkey, or from a foreign institution of higher education whose equivalency is recognized by the Council of Higher Education.

Candidates who successfully complete the authorization examination shall, following the announcement of the examination results, submit their applications for the Compliance Officer License through the application system available on the official website of the Presidency. The Compliance Officer License shall be granted to candidates who meet the aforementioned requirements. Individuals to whom such license is issued shall be authorized to serve as compliance officers or assistant compliance officers.

The Compliance Officer License shall be recorded in the registry, and its validity period shall commence as of the date of the examination. Holders of the Compliance Officer License are obliged to participate in the license renewal training program every three years as determined by the Presidency and to submit, in electronic form to the Presidency, the documentation evidencing their continued fulfillment of the conditions required for the issuance of the Compliance Officer License. Failure to complete the renewal training within the prescribed period, or failure to provide the Presidency with the documentation evidencing compliance with the licensing requirements, shall result in the suspension of the license, which suspension shall also be duly recorded in the registry.

Compliance Officers in Office as of the Date of the Communiqué

As of the date of publication of the Communiqué, which was 9 September 2025, those serving as compliance officers who do not meet the requirement of “having graduated from a higher education institution abroad providing at least a four-year program, provided that its equivalency is recognized by the Council of Higher Education in Turkey” may participate, until 25 December 2025, in the authorization examinations, provided that their employment is duly substantiated by Social Security Institution records. Candidates who take and successfully pass the examination under this provision shall be granted the Compliance Officer License, provided that they also meet other licensing requirements.

As of 25 December 2025, those who have been serving as compliance officers for at least six months and who do not meet the aforementioned graduation requirement may participate in the authorization examinations until 25 December 2027, provided that their employment is duly substantiated by Social Security Institution records. Candidates who take and successfully pass the examination under this provision shall be granted the Compliance Officer License, provided that they also meet other licensing requirements.