Update: The amendment discussed in this column was enacted as Law No. 7518 (Official Gazette 2 July 2024, No. 32590). For the current regime, see our CASP / Crypto Compliance page.
In May 2024, in his column on CoinDesk Türkiye, our Managing Partner Erdem Mümtaz Hacıpaşaoğlu examined the Capital Markets Law amendment bill: also known as the Crypto-Asset Law. He assessed what the long-anticipated regulation, whose various drafts had already leaked into public discussion, would mean for investors, service providers and ecosystem stakeholders.
The central thesis of the column was clear: the amendment to the Capital Markets Law brings crypto-asset service providers (CASPs) under a licensing regime and redefines the ecosystem along the axes of transparency and investor protection; but until secondary legislation lands, many practical questions (capital adequacy, custody architecture, transition timing) remain open.
Headline items in the regulation
The column unpacked the CASP definition and licensing obligation, segregation of client assets, heightened director liability, audit requirements, and criminal/administrative sanctions in detail.
Investor perspective
The investor-protection mechanisms introduced by the law (standardization of KYC/AML, segregated client custody, and complaint/dispute resolution channels) were a key part of the piece.
Service-provider perspective
For CASPs, the licensing application timeline, capital adequacy thresholds and operational compliance burden were highlighted as items that will remain open until secondary regulation is published.
Highlights from this column
- Scope: CASP definition, licensing, client-asset segregation
- Liability: Directors, audit, sanctions
- Investor: KYC/AML, protection, resolution mechanisms
- Open questions: Secondary regulation, transition window, capital adequacy
You can read Mümtaz’s LinkedIn post at this link, and the original column on CoinDesk Türkiye at this link.
The secondary regulation the column was waiting for arrived on 13 March 2025 (communiqués III-35/B.1 and III-35/B.2). For the regime as it stands today, including the 2026 capital amounts, see crypto licence in Turkey (CASP).
