Crypto-asset service providers (CASPs) — exchanges, custodians, wallet providers, and broker-dealers — operate under one of the most rapidly evolving regulatory environments globally. Vircon Legal advises crypto operators preparing for Turkish CASP licensing, EU MiCA registration, and US state-level compliance — from pre-license structuring through operational audit readiness.
Our CASP and crypto compliance practice covers:
- Turkish CASP licensing. Application strategy, qualification analysis, capital adequacy planning, governance structure, and submission management with the Turkish Capital Markets Board.
- Cross-border structuring. Multi-entity architectures spanning Türkiye, EU MiCA jurisdictions, US states, and offshore CASP-friendly jurisdictions — integrated with our fund structuring and M&A practices.
- AML / KYC and Travel Rule. Onboarding flows, transaction monitoring frameworks, suspicious activity reporting, and FATF Travel Rule compliance.
- Custody and asset segregation. Hot/cold wallet policy design, insurance arrangements, segregation of customer assets, and proof-of-reserves frameworks.
- Token launch and offering. SAFT structures, token classification analysis, sale documentation, and post-launch compliance — see also our Capital Markets practice.
- Smart contract and DAO governance. Legal wrappers for DAOs, smart contract audit coordination, and on-chain governance documentation.
- Stablecoin operations. Reserve attestation, redemption mechanics, and multi-jurisdictional issuance compliance.
- Regulator engagement and enforcement defense. Pre-application meetings, response to information requests, and enforcement proceeding defense.
For operators preparing their own initial license assessment, our CASP License Obligation Checklist walks through the key compliance pillars. We work with crypto-native startups, traditional financial institutions expanding into digital assets, and infrastructure providers building the backbone of the next-generation financial system.
Founder Academy resources
Free, practical checklists for this area: CASP License Checklist.
Frequently Asked Questions
Who needs a CASP licence in Türkiye?
Platforms providing crypto-asset trading, custody, or transfer services under Law No. 7518 — exchanges first and foremost. Entities already operating were required to declare themselves for the transition process, and the CMB publishes the list of those permitted to operate while applications proceed.
What are the core compliance obligations for CASPs?
Minimum capital and organisational requirements, segregation and custody of customer assets, listing and disclosure standards, IT and security infrastructure, and full MASAK AML compliance — customer due diligence, suspicious-transaction reporting, and the travel rule for transfers. Governance expectations track those of licensed capital-markets institutions.
Can foreign exchanges serve Turkish users without a licence?
Targeting Türkiye — Turkish-language interfaces, TL pairs or local payment rails, marketing to Turkish residents — brings the activity within the licensing regime. Passive availability of a global platform is a narrow and fact-sensitive defence; regulators have already moved against unlicensed targeting.