This article explores the latest regulatory developments in Turkey, where the Capital Markets Board has just issued new rules regarding the licensing and operational oversight of crypto asset service providers (CASPs).
On 13th March 2025, the Turkish Capital Markets Board (CMB) published the Communiqué on Operating Procedures and Principles and Capital Adequacy (Communiqué No. III-35/B.2) in the Official Gazette. Following the introduction of the 2024 bill that began the process of regulation for crypto assets, the latest update now imposes stricter oversight on platforms, custody services, and foreign providers. This move brings greater regulatory alignment between Turkey and other digital asset regulatory frameworks, such as the EU’s Markets in Crypto Assets (MiCA) regulation.
Newly regulated services for CASPs
Under the new rules, only CMB-authorized CASPs may offer key crypto services, including:
- Execution, clearing, and settlement of crypto asset transactions
- Custody and management of crypto assets and private keys
- Intermediation in the initial offering or distribution of crypto assets
- Investment advisory services specific to crypto assets
Additionally, authorized CASPs can engage in NFT-related transactions and financial analysis of crypto assets without requiring additional authorization, provided they notify the CMB.
Restrictions on foreign CASPs
The Communiqué establishes clear limitations on non-resident CASPs serving Turkish users. They may only offer services upon direct client request, adhering to the principle of “reverse solicitation.” The ruling means they cannot actively market, promote, or advertise their services within Turkey nor establish a Turkish-language website or local offices.
Platform operations and listing rules
Platforms facilitating crypto asset transactions must comply with new listing standards and operational guidelines:
- Crypto assets must meet predefined listing criteria, ensuring compliance with smart contract integrity and legal safeguards.
- A listing committee, comprising at least three experienced professionals, must oversee all listing and delisting decisions.
- Platforms must review their listing policies annually and disclose an up-to-date list of listed assets on their websites.
Additionally, platforms are prohibited from offering leveraged trading, derivative contracts, short selling, or lending transactions involving crypto assets.
Custody services and central securities depository integration
Custody services are restricted to banks and institutions authorized by the CMB. Client assets must be stored separately from the custody provider’s own accounts. Platforms unable to secure external custody for a listed asset may hold it temporarily for up to six months, subject to capital adequacy requirements.
Moreover, platforms must integrate with the Turkish Central Securities Depository (Merkezi Kayıt Kuruluşu A.Ş.) to maintain transparency in crypto asset balances and reporting obligations.
Capital adequacy and financial reporting
The CMB has introduced stringent capital adequacy requirements to ensure financial stability among CASPs:
- Platforms must have a minimum share capital of TRY 150 million, while custody institutions must maintain at least TRY 500 million.
- Shareholder equity must remain above these thresholds, with at least 25% consisting of paid-in or issued capital.
- Each quarter, CASPs must monitor capital adequacy, with total short- and long-term debt capped at three times their capital base.
- Platforms must maintain liquid reserves proportional to client assets held.
Additionally, CASPs are subject to independent financial audits and must comply with the CMB’s financial reporting standards.
Transition period and compliance deadlines
The CMB has established a transition period to help market participants comply with the new regulations. Platforms already listed as operational by the CMB or those that have applied for authorization before 13th March 2025 must meet custody infrastructure requirements by 30th June 2025. Capital and equity compliance must be achieved by the same deadline.
Digital asset market opportunity for Turkish CASPs
Even as the regulatory landscape is still emerging, interest and adoption of cryptocurrencies are remarkably high among Turkish consumers. A 2023 survey from KuCoin revealed that over half of adults have invested in digital assets. Another poll carried out in 2024 by local exchange Paribu found that cryptocurrencies are among the top three investment products for Turkish users, behind only gold and foreign currencies.
Consequently, many providers have chosen not to delay the launch of their crypto-asset service offerings, even as the regulatory situation is still evolving. In January, Turkey’s fifth-largest bank, Garanti BBVA, announced it would roll out crypto services to 27 million of its clients, while Istanbul-based BankPozitif recently confirmed a partnership with digital asset custodian Taurus for the rollout of crypto custody services to its clients.
The CMB’s latest regulatory overhaul marks another shift in Turkey’s approach to crypto asset regulation, further aligning the market with global regulatory trends, including the EU’s far-reaching MiCA regulation. While the recent measures in Turkey introduce new compliance burdens for CASPs and foreign providers, they also aim to foster a more stable and transparent crypto ecosystem with enhanced investor protections.
Launching a regulatory-compliant digital asset offering with Wyden
Wyden enables banks and brokers to build and maintain retail and institutional client offerings as well as supporting internal proprietary trading needs via a single platform, making Wyden the ideal choice for Turkish CASPs when building and scaling their regulatory-compliant digital asset businesses.
Wyden’s institutional digital asset platform covers the entire end-to-end trading lifecycle of digital assets across all pre-trade, trading, and post-trade requirements. A key compliance advantage is that it offers true best execution through market-wide connectivity to over 55 trading venues and a smart order routing system that carries out price comparisons and order splitting to achieve the optimal execution terms. Pre-trade risk and treasury management coupled with post-trade settlement, reconciliation and double-entry accounting allows Wyden’s European clients to build and offer retail and institutional products and comply with the requirements of both MiCA and DORA.
Seamless integration with custody partners, such as Ripple, also means that Wyden maintains an auditable record of all transaction flows between custody and trading with automated liquidity management and settlement solutions that ensure an uninterrupted trading experience. Core banking integrations ensure smooth reconciliation and support the assimilation of new digital asset offerings into established systems, infrastructure and workflows.
Banque Delubac & Cie, a pioneer among French institutions in adopting digital assets, implemented Wyden’s cloud-native platform to facilitate crypto trading for its private clients and corporates. In addition, one of Europe’s leading online brokers flatexDEGIRO entrusted Wyden’s trading infrastructure for the launch of its digital asset trading offering to its multinational customer base. Further clients range from German investment bank, Baader Bank, numerous Swiss banks and also one of the largest global French banks serving millions of retail and institutional customers.
Given its track record, Wyden is the premier digital asset trading infrastructure provider for Turkish banks and brokers seeking a robust solution that can demonstrate best market practices while also future-proofing their business against potential future regulatory updates that may introduce even more stringent demands.
Contact us today for an initial discussion about implementing a compliant digital asset offering in your organization.
Please note that the above article does not constitute legal advice.