
In February 2025, on the OKX Türkiye live broadcast, our Managing Partner Erdem Mümtaz Hacıpaşaoğlu joined Ahmet Usta and Elif Hilal Umucu Kara to discuss the Travel Rule recently entering into force in Turkey, in comparison with other jurisdictions.
The central thesis of the broadcast was clear: the Travel Rule now in force in Turkey is rapidly repositioning crypto-asset service providers (CASPs/KVHS) — not only in terms of FATF-recommendation alignment, but also in threshold amount, scope, and integration with international counterparts (EU, U.S., Singapore, U.K.).
Turkey’s Travel Rule implementation
Under the new regime, how CASPs must share originator and beneficiary information, above which threshold, and — perhaps most consequentially — how this is handled in transactions involving self-hosted wallets formed the technical core of the conversation.
Comparison with other jurisdictions
The EU’s Transfer of Funds Regulation (TFR) under MiCA, FinCEN’s U.S. implementation, and the approaches of Singapore (MAS) and the U.K. (FCA) were placed alongside Turkey’s regime; threshold amounts, sunrise letters, and obligations when the counterparty is not a CASP emerged as the common points of divergence.
Highlights from this broadcast
- Turkey Travel Rule: Effective date, threshold, scope
- Self-hosted wallets: Special status, compliance burden
- Comparison: EU TFR, FinCEN, MAS, FCA
You can read Mümtaz’s LinkedIn post at this link.
Author
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View all postsMümtaz is the Managing Partner of Vircon Legal, which he founded in 2016. He advises founders, investors and operators on financing rounds, M&A, cross-border incorporations and regulated verticals — including crypto-asset infrastructure, fintech and games — bringing a former startup founder's perspective to every engagement.
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