TLDR:
Anti-Money Laundering (AML) compliance encompasses the programs, processes, and obligations financial institutions and other regulated businesses use to detect, prevent, and report money laundering and related financial crimes. AML compliance has expanded dramatically in scope and enforcement since 9/11 and continues to evolve as new technologies (cryptocurrencies, digital assets) and global threats (sanctions evasion) emerge.
Core AML Program Elements
A compliant AML program typically requires: customer identification and KYC procedures, customer due diligence (CDD) including UBO identification for legal entities, ongoing monitoring of customer transactions for suspicious activity, suspicious activity report (SAR) filings with relevant authorities (FinCEN in US, MASAK in Türkiye, NCA in UK), sanctions screening against OFAC, EU, UN, and other sanctions lists, recordkeeping for required periods (typically 5+ years), AML officer designation, employee training, independent audit, and risk-based approach calibrating procedures to actual risk.
Sectors Subject to AML
AML obligations apply to: banks and credit institutions (historically primary regulated population), money service businesses (currency exchange, money transfer), payment institutions and e-money institutions, securities firms and investment advisers, insurance (life and certain other), real estate (in many jurisdictions, particularly for high-value transactions), legal and accounting professionals (for specific services), and increasingly crypto-asset service providers (under MiCA in EU, MASAK regulation in Türkiye, expanding under FinCEN guidance in US). Different sectors have specific obligations adapted to their risk profile.
Turkish AML Framework
Türkiye’s AML framework centers on Law No. 5549 (Prevention of Laundering Proceeds of Crime) and Law No. 6415 (Prevention of Financing of Terrorism), administered by MASAK (Mali Suçları Araştırma Kurulu, Financial Crimes Investigation Board). Obligations apply to broad set of “yükümlüler” including financial institutions, payment services, currency exchange, real estate firms, jewelers, attorneys for specific services, and crypto-asset service providers (since 2025 regulation). MASAK reporting includes Suspicious Transaction Reports (Şüpheli İşlem Bildirimi, ŞİB) within 10 business days of detection. FATF reviewed Türkiye in 2019-2021, leading to comprehensive AML reforms and removal from FATF’s “grey list” in 2024.