The growth team opens the standard playbook: welcome bonus, refer-a-friend, a giveaway on X, and a “top-performing coin this month” post. Ordinary moves in any other industry; for a licensed crypto platform in Türkiye, all four are now either prohibited or seriously risky. The rules arrived in two waves: the CMB’s Board decision of 19 September 2024, then the III-35/B.1 and III-35/B.2 Communiqués published in the Official Gazette on 13 March 2025 (No. 32840). Here is what is banned, what survives, and the checklist to hand your marketing team.
The regime’s logic: crypto advertising reads like investment-firm advertising
The CMB’s premise is simple: a platform holding the CASP licence is a capital-markets institution, and its marketing is held to that discipline. The baseline duty: publications, announcements and adverts must be objective, non-misleading and complete. Specific bans stack on top: absolute return promises, loss-protection guarantees, steering customers toward specific crypto assets, and exploiting particular professions or vulnerabilities. “This coin is about to fly” is no longer marketing copy; it is an enforcement exhibit.
Campaigns and sweepstakes: where the break really happens
What truly disrupts growth teams is the promotion side. Prohibited: campaigns containing a return promise; campaigns steering investment into one or more crypto assets; and, the sector’s favourite mechanic, any structure providing benefits to whoever brings in a customer, or to the customer they brought. Referral bonuses, invite-code token rewards and “bring a friend, earn ₺100” models are categorically closed. High-value prize draws live in the same basket: raffling cars, phones or chunky USDT for sign-ups or trades is indefensible under this frame. The original decision required winding down existing campaigns within 15 days without harming investors. That transition is long over; running such campaigns today is a knowing breach.
What still works
| Marketing move | Status | Note |
|---|---|---|
| Brand advertising (platform name, licence, security) | Permitted | Objective and non-misleading, always |
| Education content, market analysis | Permitted (carefully) | Analysis must not become steering; single-coin tips cross the line |
| Fee discounts / commission campaigns | Relatively safe ground | So long as no return promise or asset steering rides along |
| Welcome token/coin gifts | Risky-to-banned | Slides into asset steering plus benefit mechanics |
| Referral / invite programmes | Banned | Benefits for customer acquisition are expressly covered |
| High-value sweepstakes | Banned | The centre-case of the promotion prohibition |
| Influencer “look how much I made” content | Banned | Return perception + misleading content; liability stays with the platform |
Foreign platforms and Turkish-language marketing
The regime has a cross-border arm: targeting Turkish residents (a Turkish interface, Turkish campaigns, Türkiye-directed advertising) is read as an indicator of unlicensed activity for platforms without authorisation. A global exchange announcing a campaign from its Turkish-language X account is not making a marketing choice; it is taking a perimeter risk. Conversely, groups with a licensed local entity must route Turkish marketing through that entity alone.
What is the sanction for breaking the campaign rules?
The CMB’s usual ladder: correction demands, administrative fines and, in serious scenarios, measures touching the operating licence, with criminal exposure on the unlicensed-activity side. The real cost is usually indirect: a screenshot of an old campaign sitting on the table during licensing or an audit.
Are airdrops and quest campaigns banned too?
It depends on the mechanics: if they grant benefits for customer acquisition or trading volume, they fall inside the ban; protocol-level distributions independent of the platform are assessed separately. The line is thin; run the campaign copy past counsel before it ships.
Where to start
Hold your marketing calendar against the table above and push every live campaign through three questions: any return promise? any asset steering? any benefit to the referrer or the referred? A campaign that cannot answer “no” three times is one you should close before an auditor does.
Source: CMB announcement: Communiqués III-35/B.1 and III-35/B.2 · Related: travel rule · MASAK.
More on this area: our Fintech & Payments Law page.
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