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ARTICLE · 13 DECEMBER 2021

Regulation On Sharing Of Secret Information

ELIG Gürkaynak Attorneys-at-Law
ELIG Gürkaynak Attorneys-at-Law
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ELIG Gürkaynak Attorneys-at-Law

ELIG Gürkaynak Attorneys-at-Law

ELIG Gürkaynak Attorneys-at-Law is an eminent, independent Turkish law firm based in Istanbul. The...

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Regulation on Sharing of Secret Information ("Regulation") issued by the Banking Regulation and Supervision Agency ("BRSA") has been published in the Official Gazette numbered 31501 and dated June 4, 2021...

TurkeyFinance and Banking
Gönenç Gürkaynak
Gönenç Gürkaynak
Nisa Aybüke Eroğlu
Nisa Aybüke Eroğlu
Nazlı Nil Yukaruç
Nazlı Nil Yukaruç
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I. Introduction

Regulation on Sharing of Secret Information ("Regulation") issued by the Banking Regulation and Supervision Agency ("BRSA") has been published in the Official Gazette numbered 31501 and dated June 4, 2021 and will enter into force on January 1, 2022. The purpose of the Regulation is to determine the scope, form, procedures and principles regarding the sharing and transfer of bank secret and customer secret information, and the Regulation introduces detailed regulations regarding the confidentiality obligation. In this regard, we will focus on the new regulations introduced by the Regulation.

II. What is New?

 A. Confidentiality of "Customer Secret"

The Regulation defines the "customer secret". As per Article 4/3 of the Regulation, information of a real or legal person, which are collected after establishing a customer relationship with banks specific to banking activities, are defined as customer secrets. Any information showing that a

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