What is the current legal landscape for your practice area in your jurisdiction ?

Since 2024, Turkey has become one of the countries with the most comprehensive regulatory framework for crypto assets in the region. After years of operating in a “grey area,” the crypto market was formally integrated into the Capital Markets Law through Law No. 7518, which introduced the legal definition of a “crypto asset” into the Turkish legal system for the first time.

The law defines as “crypto asset service providers (CASPs)” all entities engaged in the issuance, trading, custody, or transfer of crypto assets, and makes licensing by the Capital Markets Board of Turkey (CMB) mandatory for these activities.

While previously hundreds of crypto platforms operated in Turkey, following the entry into force of the new legislation, only 58 companies have applied for licenses and are continuing operations under the transition regime. As of 2025, the CMB is conducting comprehensive audits and fit-and-proper assessments on these applicants, focusing on information-system security, segregation of client assets, capital adequacy, and compliance with anti-money-laundering (AML) obligations. Licenses will be granted only to entities that fully meet these standards. As a result of this regulatory transformation, the Turkish crypto market has evolved into a more institutionalized, licensed, and supervised ecosystem. The CMB’s stated objective is that, by 2026, only fully licensed entities will be permitted to operate, thereby ensuring full compliance of the Turkish crypto sector with international standards.

Our law firm, Köksal & Partners, primarily specializes in financial technologies law, information technology law, personal data protection law, and provides both litigation and legal consultancy services in matters related to crypto assets. We also have significant expertise in the regulatory framework governing Crypto Asset Service Providers (CASPs) and the broader fintech sector.

Our firm offers comprehensive legal advisory services to CASPs, including:

• Legal support in the establishment and licensing process before the SPK,
• Ensuring full operational and systemic compliance with obligations set forth by both the SPK and the Financial Crimes Investigation Board (MASAK). This includes developing and revising policies and procedures related to AML, CFT, and KYC regulations, providing robust corporate compliance support, and offering guidance to internal audit, internal control, and compliance teams on legally permissible operations.

Our firm is positioned at the intersection of these two regulatory pillars. We not only provide the “front-end” support for licensing and establishment but also manage the “back-end” of regulatory risk. This includes providing robust legal representation in disputes, whether they involve the regulatory authorities themselves or arise from the relationship between CASPs and their clients. Our in-depth understanding of this complex environment allows us to guide our clients through the complexities of compliance and regulatory risk management.

What three essential pieces of advice would you give to clients involved in your practice area matters?

For clients operating in the complex and rapidly evolving fields of financial technologies, payment services, and particularly crypto-asset services, our advice centers on building a resilient and sustainable operational framework. Based on our practical experience and insight into the regulatory mindset, we offer three essential recommendations:

First, In Turkey’s new regime under Law No. 7518, licensing is no longer a formality—it defines your ability to exist in the market. All crypto-asset service providers (CASPs) must obtain authorization from the Capital Markets Board (SPK), and those operating without one face criminal sanctions. Before the new law, hundreds of platforms operated in Turkey. Following the regulatory overhaul, only 58 companies have remained in the licensing process, while all others either ceased operations or entered mergers and acquisitions. This clearly demonstrates the regulator’s position: only fully compliant and financially strong entities will survive. Compliance is no longer an administrative requirement but rather the foundation of a company’s legitimacy and credibility. Firms should view AML/KYC implementation, client asset segregation, information system security, and data protection not as periodic tasks, but as integrated, daily business practices. We advise clients to build proactive compliance frameworks that prevent, rather than merely respond to, risks. We strongly encourage clients to embed a proactive, preventive compliance culture deep within their organization—moving beyond reactive checks. This means implementing robust internal controls, training teams effectively, and seeking legal guidance before new products are launched. Viewing compliance as a strategic asset, rather than an administrative burden, is critical for building long-term credibility with regulators, financial partners, and the market.

Second, now that the market is formally regulated, foreign platforms that accept Turkish users-either directly or through partnerships-must assess the legal implications of their operations in light of Turkish legislation. A clear strategic decision must be made on whether their service flows will include or exclude Turkey, and this determination must shape their corporate and compliance structures accordingly. Turkey remains one of the most active retail crypto markets in the world, with strong investor demand and high trading volumes. Despite increased capital and licensing requirements, the market now rests on a clear and reliable legal foundation. Before regulation, approximately 200 platforms were active; today, only about 58 remain, making the market smaller but more credible and attractive for serious, well-capitalized players. Therefore, companies considering entry into the Turkish market should carefully assess whether to establish a local entity, partner with a licensed provider, or explicitly exclude Turkish users. Those who structure their entry strategically—within the scope of Turkish law—can gain a significant early-mover advantage in a consolidated and institutionally supervised environment.

Finally, the Turkish crypto market is in transition from unregulated growth to supervised maturity. Regulators such as the SPK and MASAK (Financial Crimes Investigation Board) are adopting a zero-tolerance approach in line with Turkey’s national financial policy and its exit from the FATF “grey list.” Enforcement activity is increasing, and foreign entities targeting Turkish users are now explicitly required to comply with Turkish regulations or cease operations. The legal landscape for digital assets and fintech is not static; it is constantly evolving, both locally (under bodies like the SPK and MASAK) and globally. We emphasize the importance of tracking international frameworks—such as those from the FATF or the EU’s MiCA regulation. Therefore, for any entity operating in this market, uncompromising and exception-less compliance is not just a goal, but an absolute necessity for survival.

What are the greatest threats and opportunities in your practice area law in the next 12 months?

A major turning point in the coming year will be the issuance of operating licenses for the first time under the new crypto-asset framework. This development represents both a threat and an opportunity for market participants. On one hand, only firms that meet stringent capital, governance, and compliance requirements will qualify—potentially narrowing the market to a limited number of large players. On the other hand, the Capital Markets Board’s (SPK) approach to licensing will determine the future competitive structure of the industry: whether it fosters a broader, innovation-driven market with multiple licensed participants, or instead concentrates activity among a few dominant domestic and global actors. The outcome of this process will define how inclusive and dynamic Turkey’s regulated crypto ecosystem will become in practice.

Over the next 12 months, the primary threat for market participants will stem from the rapidly changing legal landscape—particularly as the Capital Markets Board (SPK) finalizes secondary legislation on the custody, transfer, and potential seizure of crypto assets, and the Financial Crimes Investigation Board (MASAK) intensifies its oversight through updated Anti Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulations tailored to distributed ledger technologies. Driven by national financial policy, MASAK (Financial Crimes Investigation Board) has already implemented rigid compliance burdens, such as the 72-hour reporting rule, demanding flawless operational systems.Companies that fail to adapt swiftly risk facing not only administrative sanctions and financial penalties but also the suspension or revocation of operational licenses.

At the same time, several regulatory developments could further reshape the landscape. There is active market speculation that the Central Bank of Turkey may reconsider its current ban on crypto-based payments, a move that could significantly expand the sector’s practical use cases and unlock new business potential. Meanwhile, the future direction of TÜBİTAK’s upcoming technical standards—which will likely govern blockchain infrastructure, security, and interoperability—remains uncertain. However, early assessments suggest that these standards are expected to align closely with international best practices, supporting Turkey’s ambition to integrate its crypto and fintech ecosystem into the global regulatory and technological framework.

The industry is also eagerly anticipating further SPK regulation on Initial Coin Offerings (ICOs), which could revolutionize funding for technology startups, and the tokenization of real estate, which promises to revitalize the property sector while driving new transaction volumes.

In this context, the next year will not merely test compliance capabilities but will demand strategic foresight. This period of regulatory structuring presents significant opportunities. The fundamental driver remains Turkey’s vibrant, young, and crypto-literate population, which ensures high market potential.

How do you ensure high client satisfaction levels are maintained by your practice?

At Köksal & Partners, client satisfaction is one of our core priorities, and we achieve it by combining deep legal expertise with a young, dynamic, and technology-driven team. Our lawyers are not only specialists in their respective fields but are also highly fluent in the technological aspects of our clients’ industries—especially fintech, blockchain, and digital assets. This allows us to deliver advice that is not only legally sound but also commercially and technically practical.

Crucially, we do not position ourselves merely as an external law firm that is consulted when issues arise. Instead, we operate as a true partner and stakeholder in our clients’ success—functioning almost as an in-house business unit that works side by side with their teams. This close integration allows us to deeply understand their business models, anticipate challenges, and offer preventive legal guidance before problems materialize. It also creates a continuous, trust-based relationship that goes well beyond transactional advice.

Internally, every client matter benefits from collaborative review and multidisciplinary input, ensuring that our advice is always well-considered and thoroughly verified. Every case is reviewed by more than one professional, ensuring that clients receive well-considered and thoroughly verified advice. This team-based approach helps us provide accurate, practical, and reliable solutions that meet each client’s specific needs.

Finally, we maintain transparent and consistent communication at every stage of our work. Clients are kept informed and involved throughout each process, which reinforces confidence, builds long-term relationships, and sustains a consistently high level of satisfaction.

What technological advancements are reshaping your practice area law and how can clients benefit from them?

New technologies—especially artificial intelligence (AI)—are reshaping many legal and business processes in our field. We see this impact in how we deliver our legal services.

In our clients’ areas, particularly crypto asset and fintech law, digital transformation is driving major changes. We advise our clients to integrate these technologies carefully, ensuring they align with legal requirements and are fully auditable.

Furthermore, technology is transforming how we, as a firm, deliver legal advice. We are actively investing in AI and legal tech to enhance our own efficiency and minimize the time spent on routine processes.

By leveraging technology to automate and solve high-volume, everyday tasks, we create a significant opportunity for our team to focus on what truly matters: deep legal analysis and complex strategic interpretation. This is especially critical in novel fields like fintech and blockchain, where regulation is new and requires nuanced legal commentary.

This approach allows us to provide top-level consultancy services very quickly and effectively. Our clients benefit directly because our experts can dedicate their full attention to high-stakes regulatory challenges and strategic planning, rather than being bogged down by simple processes. This model enables us to deliver faster, more focused, and highly strategic legal support tailored to the complex challenges of these new sectors.