With the official enactment of the 2025 Crypto Asset Service Providers Law, Turkey has entered a new era of digital asset regulation. Crypto exchanges operating in or targeting Turkish users are now required to obtain licenses, comply with data localization mandates, and fulfill capital adequacy requirements. This new legal framework aims to eliminate fraud, strengthen investor protection, and align Turkey with EU-level standards. However, the regulatory process is complex, especially for foreign exchanges or DeFi platforms seeking local presence. Our Turkish Law Firm guides clients through the application process, KYC/AML audits, and ongoing compliance. If you're seeking the support of a best lawyer firm in Turkey to establish or legalize your crypto operation, we are here to help.
Overview of the 2025 Crypto Exchange Licensing Framework
Under the new regulation, crypto exchanges in Turkey are required to register with the Capital Markets Board (CMB) and obtain operational clearance from MASAK. Licenses are tiered based on volume, asset types, and custodial structures. The process includes submission of corporate documents, source of funds declarations, software security audits, and shareholder background checks. Our English speaking lawyer in Turkey team works closely with founders, compliance officers, and technology vendors to prepare complete licensing packages. As a Company Lawyer Turkey partner, we also review Articles of Association to ensure crypto operations are within lawful scope under the Turkish Commercial Code.
Risk-Based Licensing Tiers: Small vs. Systemic Exchanges
The Turkish model separates crypto exchanges into two core categories: general providers and systemic providers. Systemic exchanges are defined by their user base, fiat gateways, and monthly trading volume. They are subject to enhanced scrutiny, higher capital minimums, and periodic penetration tests. Smaller exchanges or DEXs targeting only institutional clients may qualify for simplified licensing under certain conditions. Our Turkish Lawyers help exchanges correctly position themselves to reduce compliance burdens without sacrificing legality. Working with a Turkish Law Firm ensures your application aligns with your operational model and strategic roadmap.
Custody and Wallet Infrastructure Rules
Licensed crypto exchanges must partner with regulated custodians or build their own secure wallet infrastructure, audited annually under MASAK rules. Cold storage minimums, insurance provisions, and user segregation controls are mandatory for Tier 1 platforms. In 2025, Turkey became the first country to require third-party insurance for digital asset reserves exceeding 50 million TRY. Istanbul Law Firm, recognized as a best lawyer firm in Turkey, supports exchanges in drafting smart custody agreements, evaluating wallet providers, and navigating FinTech sandbox procedures. Our English speaking lawyer in Turkey team also liaises with Turkish banks to assist in opening operational and fiat gateway accounts.
Foreign Ownership and Market Entry for Crypto Platforms
Turkey allows 100% foreign ownership in licensed crypto exchanges, but foreign shareholders must pass additional regulatory scrutiny. Shareholder identity, funding source, and global crypto licensing history are all examined. A local legal representative is required for all foreign-owned crypto entities. Our Turkish Law Firm assists clients in structuring Turkish subsidiaries, preparing share transfer documents, and managing cross-border compliance. For U.S. or EU-based platforms, we coordinate Turkish licenses with existing obligations abroad. Having an English speaking lawyer in Turkey handle your licensing removes language barriers and accelerates your launch. We’re also recognized as a best lawyer firm in Turkey for crypto market entry strategy.
Blockchain Infrastructure and Audit Requirements
Beyond licensing, exchanges must demonstrate the reliability and auditability of their blockchain infrastructure. The 2025 law mandates annual smart contract audits, source code registration, and off-chain data redundancy. If a platform uses proprietary blockchain tools, these must be documented and reviewed by MASAK-licensed IT audit firms. Istanbul Law Firm works with leading Turkish developers and compliance auditors to ensure your backend is secure and auditable. Our Company Lawyer Turkey and tech counsel teams collaborate to produce full technical-legal compliance files. As a recognized Turkish Law Firm, we help platforms integrate legal design principles into their tech stack. This alignment is essential for both licensing and future investor rounds.
Investor Protection and Legal Recourse Mechanisms
One of the core objectives of Turkey’s crypto licensing regime is investor protection. Licensed exchanges must offer investor risk disclosures, establish complaint portals, and integrate arbitration clauses into user agreements. Unlicensed platforms face administrative bans and criminal exposure under the Banking Law. Our Turkish Lawyers draft legally enforceable user terms that meet both MASAK and Capital Markets Board expectations. We also represent exchanges in disputes and regulatory audits. A best lawyer firm in Turkey not only ensures license issuance, but also long-term operational stability. An English speaking lawyer in Turkey from our team can review, localize, and notarize all compliance documents. See our full breakdown of user protection under tech startup compliance law in Turkey.
Ongoing Compliance and Reporting Obligations
After licensing, exchanges must fulfill ongoing obligations including transaction reporting, suspicious activity declarations, and user data backups. Reports must be submitted to MASAK monthly, and real-time flagging mechanisms are required for high-risk transactions. At our Turkish Law Firm, we integrate crypto compliance into your corporate governance plan. We work closely with CTOs and CFOs to automate reporting and build legal risk dashboards. A dedicated Company Lawyer Turkey ensures the exchange's board understands its legal liabilities. We also assist in staff AML training and internal investigations. If you're working with foreign advisors, our English speaking lawyer in Turkey bridges jurisdictional gaps, ensuring a fully localized compliance framework.
Common Pitfalls in Turkish Crypto Licensing Applications
Exchanges often underestimate the regulatory complexity in Turkey. Common mistakes include: failing to localize terms of use, submitting unaudited code, or applying without a physical address. Some startups also reuse global templates without adapting to Turkish Law. This leads to application rejections or delayed inspections. Our Turkish Lawyers conduct mock audits and pre-application reviews to eliminate these risks. Istanbul Law Firm is a best lawyer firm in Turkey for blockchain licensing. We’ve rescued numerous applications initially filed by generalist law firms or freelance consultants. Want to understand how we reverse-engineer crypto licensing success? Read our case study: AI and Automation Legal Liability in Turkey.
Frequently Asked Questions (FAQs)
- Do I need a license to run a crypto exchange in Turkey? Yes. As of 2025, operating without a license is punishable under the Banking Law and MASAK regulations.
- Can foreign exchanges get licensed? Yes, with local representation. Our English speaking lawyer in Turkey can serve as legal liaison and regulatory counsel.
- How long does licensing take? On average, 3–6 months. Pre-review by a Turkish Law Firm can shorten the timeline.
- What are the capital requirements? 5 million TRY for general, 30 million TRY for systemic exchanges.
- Is DeFi allowed in Turkey? Not prohibited, but must pass security audits and meet KYC protocols.
- What if I already operate without a license? Immediate compliance steps are essential. Our Turkish Lawyers can guide your transition.
- Do I need to host user data locally? Yes. KVKK compliance requires all user data be stored on servers within Turkey.
- Can I get a license with a foreign-registered company? You’ll need to set up a Turkish entity. Our Company Lawyer Turkey team handles this fully.
- Do I need to insure user funds? Yes, for platforms holding assets over 50 million TRY. We draft compliant policies with local insurers.
- How do I integrate legal into tech? Our Turkish Law Firm offers integrated counsel across dev, compliance, and tax units.
- Do you support token-based platforms? Yes. We handle STOs, whitepapers, and cross-border token offerings. See also: Convertible Instruments in Turkey.
- Who is the best lawyer firm in Turkey for crypto law? Istanbul Law Firm is the market leader in blockchain regulation and licensing.
Contact Our Turkish Law Firm
Whether you're launching a crypto exchange, securing a Turkish license, or auditing your DeFi infrastructure, our Turkish Law Firm offers strategic counsel backed by proven results. Our Turkish Lawyers understand not only the law, but also the underlying technology that powers digital assets. As a best lawyer firm in Turkey, we guide platforms from day one to scale. Our English speaking lawyer in Turkey team is available to support you with compliance, licensing, and dispute resolution across Turkish and international jurisdictions.