Crypto and Turkish banks: why exchange transfers trigger restrictions and how to answer

Money moving between a Turkish bank account and a crypto exchange is one of the transaction types banks watch most closely. A restriction after such a transfer is a compliance step, not a verdict. This guide sets out the legal framework, the documents that normally settle the question, how to write the reply and what to avoid. It is general information, not legal, tax or investment advice.

Why exchange transfers draw attention

Turkish banks are obliged persons under Law No. 5549 on the Prevention of Laundering Proceeds of Crime. They must know their customer, understand the purpose of each relationship and report suspicious transactions to MASAK, the Financial Crimes Investigation Board. Crypto flows are treated as higher risk because the origin of the asset, the counterparty and the real owner of a wallet are harder to see from the bank side. Typical triggers are a large first deposit from an exchange, repeated in-and-out movements, transfers to a platform the bank cannot identify, or a pattern that does not match the declared occupation. When one appears, the bank usually limits the account or holds the transfer while it requests documents. The bank is not allowed to tell you whether a report was filed, so the letter will only ask for information.

The legal framework in short

Three layers matter. First, Law No. 7518, published in the Official Gazette on 2 July 2024, amended the Capital Markets Law No. 6362: crypto asset service providers now need permission from the Capital Markets Board (SPK) before they are established and operate, and SPK publishes lists of providers. Offshore platforms that target Türkiye without permission are treated as unlicensed activity. Two SPK communiqués on establishment, operating rules and capital adequacy followed on 13 March 2025. Second, MASAK obligations apply to these providers as well as to banks, including customer identification. Third, the Central Bank Regulation on Not Using Crypto Assets in Payments, in force since 30 April 2021, bars crypto assets from direct or indirect use in payments and stops payment and e-money institutions from intermediating transfers to or from crypto platforms. It does not itself make a bank transfer to a licensed exchange unlawful.

Documents that usually help

The bank wants a traceable story, so bring records that connect each amount to a source. From the exchange: an account statement or transaction history showing deposits, purchases, sales and withdrawals for the period, the account holder name and, where available, the identification level completed. From your own side: bank statements showing the original funds that went to the exchange, salary slips, sale contracts, dividend resolutions or inheritance papers that explain those funds, and tax returns or tax assessments where the gain or income was declared. If the money came from a third party, add the contract, invoice or written explanation and that person’s identity details. Documents in another language need a Turkish translation. Present them as one indexed set, each amount marked against its document, rather than as a loose pile of screenshots.

How to answer the bank

Reply once, in writing, through the channel named in the letter, and keep proof of delivery. Start with a short statement of who you are and which account and transfer are concerned. Then follow the money in date order: where the funds originated, how they reached the exchange, what happened on the platform, how they came back to the account. Quote platform name and transaction dates exactly as they appear on the statements. Answer the questions asked and no others, and avoid commentary on the value of any asset. If you hold the funds for someone else, say so openly. If a document does not exist, say that and offer the closest alternative instead of leaving the line blank. Ask the bank to confirm in writing that the file is complete and what the next step will be.

What not to do

Do not move the same funds to another bank to avoid questions: the new bank will ask the same things and a transfer between your own accounts can look like evasion. Do not split a transfer into smaller amounts below a limit you think exists. Do not send edited, partial or recreated statements; download the official export from the platform. Do not guess figures from memory when a record is available. Do not reply by telephone only, because a call leaves no record. Do not use an exchange that is not on the SPK lists of operating providers for amounts you may later need to explain, since the bank may treat it as higher risk. If the account is already restricted, keep the letter and any case number, and compare it with our guide to blocked accounts, because a court or tax enforcement block follows different rules.

Sources

• mevzuat.gov.tr — Law No. 5549 (anti-laundering) and Capital Markets Law No. 6362 as amended by Law No. 7518
• spk.gov.tr — Capital Markets Board: crypto asset service providers, licensing announcements and lists
• tcmb.gov.tr — Central Bank: Regulation on Not Using Crypto Assets in Payments
• masak.hmb.gov.tr — MASAK: obligations of banks and crypto asset service providers

Questions