Vircon Legal advises crypto-asset issuers, layer-1 and layer-2 networks, DAOs and digital-asset infrastructure operators on token economy design, regulatory perimeter analysis and the structuring of international issuance vehicles. We work as on-chain native counsel for clients operating between Türkiye, the U.S., the UAE and other crypto-friendly jurisdictions.
Our work regularly covers SAFT, SAFE-T, token-warrant and rights-conversion structures alongside traditional equity instruments. We design tokenomics with regulatory durability in mind: reducing the surface area for retroactive enforcement risk while preserving distribution flexibility.
Our Managing Partner, Mümtaz Hacıpaşaoğlu, advises founders, funds and exchanges on Türkiye’s crypto-asset regime, AML/KYC frameworks and Capital Markets Board (CMB/SPK) licensing pathways, and represents portfolio companies of international funds investing in the Turkish blockchain ecosystem.
What our crypto-asset practice covers
- Token issuance structuring (utility, security, governance, hybrid)
- SAFT, SAFE-T and Token Purchase Agreement drafting and negotiation
- Tokenomics design and on-chain treasury structuring
- Cross-border SPV setup (BVI, Cayman, ADGM, Wyoming, Delaware)
- Crypto-asset service provider (CASP) compliance, including CMB licensing
- AML, KYC and travel-rule programme design for exchanges and on-ramps
- DAO formation and governance design
- NFT and digital-collectible launch advisory
- Token-warrant agreements alongside equity rounds
- Regulatory perimeter analysis for new token launches (ICO and public coin offerings included)
Crypto licensing in Türkiye
Since Law No. 7518 (Official Gazette of 2 July 2024) added Articles 35/B and 35/C to the Capital Markets Law No. 6362, running a crypto-asset platform or custody service in Türkiye requires permission from the Capital Markets Board, and a foreign platform that targets Turkish residents is treated as operating without it. The requirements, 2026 minimum capital, the application sequence and the CMB’s provisional lists are covered on our Turkey crypto license (CASP) page. This page covers the token, Web3 and transaction side of our crypto work.
Representative work
- Gameness: advised on its public coin offering, from token design and jurisdictional structuring to investor disclosures and post-offering compliance.
- Covalent: managed the SAFE financing round and parallel token warrant process, closed on 4 October 2022.
- Angelic: advised on its future token sale round backed by Animoca Brands, Solana Ventures and 37 additional investors.
- Janus Interactive: advised on its token sale round led by Evox Capital.
- Best In Slot: advised the Bitcoin-native digital-asset infrastructure company on its investment round joined by Hyperithm, Sora Ventures and UTXO Management, closed on 23 September 2023.
- Goart Metaverse: advised the Web3 art and creator platform on its pre-seed round led by Islamic Coin.
Related services and reading
For the licence itself, see our CASP / Crypto Compliance service page and the free CASP License Obligation Checklist. Payments, e-money, open banking and crypto work come together in our fintech law hub.
- The CASP Licence in Türkiye: An Application Guide in Build Order
- Türkiye’s Crypto Advertising and Sweepstakes Rules
- Türkiye’s First Official RWA Move: The Digital Precious Metals Communiqué
- The SEC’s Regulation Crypto Assets Proposal
This page is general information and not legal advice; a specific situation should be assessed with counsel.
Other Practice Areas
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Need a crypto licence in Türkiye? Exchanges, custodians and other crypto-asset service providers need Capital Markets Board authorisation under Law No. 7518. Requirements, 2026 capital amounts and the two-stage permission process: Crypto licence in Turkey (CASP).
Frequently Asked Questions
Is crypto trading legal in Türkiye?
Trading and holding crypto-assets is legal. Using crypto as a payment instrument has been prohibited since the 2021 payments regulation, and Law No. 7518 (2024) brought crypto-asset service providers under Capital Markets Board licensing and supervision.
Do token issuers need a licence?
It depends on what the token does. Tokens with security-like features fall toward the capital-markets regime; platform operators need CASP licensing; and offshore issuance does not exempt marketing into Türkiye. The characterisation analysis should precede the whitepaper, not follow it.
What does it take to operate a crypto exchange in Türkiye?
A CASP licence under Law 7518: minimum capital, fit-and-proper management, custody and segregation arrangements, listing standards, and full MASAK anti-money-laundering compliance including the travel rule. Entities operating during the transition period appear on the CMB’s published lists.