1 The current legal landscape

What is the current state of blockchain and crypto asset law in Türkiye?

Türkiye has entered a new stage in which crypto asset businesses must demonstrate how their operations satisfy a dedicated regulatory framework. The 2024 amendments to the Capital Markets Law and the CMB’s 2025 communiqués established the central architecture for platforms and custody. AML, data protection and advertising obligations operate alongside that architecture, while significant questions remain around particular token structures and decentralized models.

Our perspective is shaped by working in crypto asset law since 2017. We organized a crypto law summit in 2017 and an ICO law summit in 2018, when much of the legal work involved applying general principles to unfamiliar business models. Today, the challenge is increasingly to translate detailed regulatory requirements into workable governance, technology and customer processes.

We see institutional custody and tokenization as important areas of development. The national 2030 strategy expressly recognizes real-world asset tokenization, and the Digital Turkish Lira project is testing related uses. These developments create opportunities, but each business still needs to establish the legal basis for its own product. A provisional CMB listing is not, by itself, a license.

Sources: Capital Markets Law Articles 35/B and 35/C; Operating framework; Service-specific rules; Strategy 32; Authorization disclaimer

2 Three priorities for clients

What are your three most important legal recommendations for clients operating in the sector?

First, choose legal advisers for their sector experience as well as their knowledge of the legislation. Entering Türkiye requires an understanding of how regulators, financial institutions, technical teams and customers interact in practice. We encourage clients to treat their legal adviser as a long-term business partner who can explain both the permissible structure and the practical consequences of a decision.

Second, build the local team carefully. Governance, compliance, AML and technical capability must support each other. Recruitment and allocation of responsibilities should reflect the applicable suitability requirements, the business’s risk profile and the need for effective escalation. Legal and compliance teams should work together on due diligence and the control environment from the outset.

Third, make compliance an operational commitment. Advice is only useful when it is translated into documented decisions, customer journeys, training and tested controls. Clients should raise proposed departures with counsel before implementation and ensure that commercial pressure does not lead to a product being launched outside its permitted scope. A sustainable Turkish operation depends on consistent execution after the initial application process.

3 Risks and opportunities over the next year

What are the main risks and opportunities for blockchain and crypto asset businesses over the next 12 months?

We expect the main risk to be the gap between formal compliance and day-to-day operations. A business may have detailed policies yet still struggle to implement customer identification, transfer controls, custody arrangements and incident handling consistently. Changes in regulatory interpretation, authorization timetables and tax proposals can also affect costs and product design.

Our recommendation is to approach Türkiye as a lasting market commitment. Businesses should invest in people, governance and systems that can adapt to further requirements. Structuring an operation around temporary assumptions or a narrow reading of one rule can create avoidable disruption.

We see opportunities in institutional services, carefully structured tokenization and technology that makes compliance more reliable. Artificial intelligence may improve monitoring, document review and customer support, but businesses should establish rules for data use, validation, human oversight and accountability before relying on it. These are our expectations for the coming year, not a prediction that a particular product will be approved or that a proposed legal change will occur.

4 Client service

How does GlobalB Law maintain a high level of client satisfaction?

We provide senior-level legal support and work closely with clients as business partners. Our aim is to understand the commercial objective, identify the issues that could prevent its delivery and give advice that the client can put into practice. This includes considering how a regulatory decision may affect contracts, operations and potential disputes.

We are selective about the engagements we accept so that we can remain closely involved in the matters we undertake. Once engaged, we take an active interest in the client’s broader legal challenges and maintain direct communication as those challenges develop. Our approach brings together transactional, regulatory and contentious experience, which is particularly important when the same product can raise commercial, compliance and criminal-law questions.

Our work in information technology and artificial intelligence law also informs our advice. Through educational activities with universities, we engage with developments affecting the sector and contribute to professional understanding. For us, client service depends on sustained senior attention, clear explanations and an informed understanding of how the business operates.

5 Technology and legal practice

Which technological developments are reshaping the sector, and how can clients benefit?

At present, we observe that many businesses are directing substantial resources toward authorization and regulatory implementation. That focus is understandable, but it should be accompanied by preparation for technologies that may change how services are delivered.

Artificial intelligence is particularly relevant. It can support review of large volumes of information, transaction monitoring and customer-service processes. Blockchain analytics can help identify transaction patterns and support investigations, while improvements in wallet security and custody technology can strengthen operational controls. Smart contracts and tokenization can automate parts of a transaction, but they also require clarity about authority, the rights represented and responsibility when code behaves unexpectedly.

Clients should begin with a defined use case and test the technology against their legal obligations. For AI, that means examining data sources, confidentiality, reliability, oversight and the ability to explain or challenge consequential outputs. For blockchain applications, it means checking asset control, transfer mechanics and how the written legal arrangements correspond to the code. The benefit comes from adopting technology within a workable legal and operational structure, rather than treating the technology itself as evidence of compliance.

Sources: Relevant data protection framework; Article 16 on initial sales and smart-contract checks

6 A representative matter

Describe a particularly interesting or complex matter on which the firm has advised.

One matter involved advising a client operating an NFT-based platform on whether its business model fell within Türkiye’s crypto asset service provider authorization framework. The central issue was the legal treatment of the activities and rights involved, rather than the use of the NFT label alone.

We assessed the model and engaged directly with the CMB to obtain regulatory clarification. The CMB confirmed that the specific business model presented did not require authorization under the applicable crypto asset service provider framework. This conclusion was confined to that model and the scope of the assessment. It was not a general exemption for NFT platforms or an approval of every activity involving NFTs.

The clarification gave the client a clearer basis for assessing its regulatory position. The broader lesson is the value of examining a proposed model in detail and seeking regulatory engagement where the boundaries are uncertain. Other businesses must assess their own rights, services and operating arrangements independently.

Separately, our legal challenge concerning the CBRT’s restriction on crypto asset payments attracted international media coverage. It reflects our interest in both advising on existing rules and testing their legal boundaries through litigation. Client confidentiality limits the detail we can share about other matters.

Sources: Public coverage of the separate payment-ban challenge