I. Introduction
Two communiqués issued by the Ministry of Treasury and Finance under the Financial Crimes Investigation Board (MASAK) framework were published in the Official Gazette of 23 September 2026 and took effect the same day, with no transition period. General Communiqué No. 34 requires obliged parties to report immediately, and to postpone, transactions that persons designated by the UN Security Council attempt to carry out. General Communiqué No. 33 doubles or more than doubles the thresholds below which simplified customer due diligence may be applied to certain life insurance, prepaid card, e-money and mobile payment products.
The two changes pull in opposite directions within the same know-your-customer framework: one tightens controls for specific persons, the other widens the room for lighter checks in low-risk transactions. Banks, payment and e-money institutions, insurers, pension companies and other obliged parties under Law No. 5549 on the Prevention of Laundering Proceeds of Crime will need to address both at once.
II. Reporting and Postponing Transactions by UN-Designated Persons
The obligation applies to transactions that persons, entities or organisations designated in UN Security Council listing decisions seek to carry out, where the decisions fall within Law No. 6415 on the Prevention of the Financing of Terrorism or Law No. 7262 on the Prevention of the Financing of the Proliferation of Weapons of Mass Destruction. Information on the decisions and the designated persons is received through the Ministry of Foreign Affairs and published on MASAK’s website.
Obliged parties take these measures under the relevant legislation, in particular Article 19/A of Law No. 5549. That article allows the Minister of Treasury and Finance, where assets are suspected of being linked to laundering or terrorist financing, to suspend a transaction, or refuse to allow it, for seven business days. Postponing the transaction and reporting it to MASAK without delay gives the Minister the opportunity to use that power before the transaction is completed.
No time limit is set beyond “without delay”. In practice this means:
• MASAK announcements should be fed into customer and transaction screening systems promptly.
• Internal procedures should set out in writing who postpones a matching transaction, who reviews the match and who reports it, and in what order.
• Branches, agents, representatives and commercial agents are themselves obliged parties under the communiqué, so the process must run wherever the transaction takes place, not only at head office.
III. Higher Thresholds for Simplified Due Diligence
MASAK General Communiqué No. 5 allows simplified customer due diligence for specified low-risk transactions. The amendment raises the monetary thresholds and leaves the conditions of use as they were.
• Life insurance. Insurers and pension companies may record a customer’s identification details without verification documents for pension contracts, payroll-deduction pension plans and life insurance policies below certain premium levels. Pension products are not subject to an amount limit, so only the life insurance thresholds change: total premiums payable within a year rise from TRY 10,000 to TRY 20,000, and single premiums from TRY 25,000 to TRY 50,000.
• Anonymous prepaid cards and e-money. These may be sold or issued without identity verification up to TRY 5,500, up from TRY 2,750. The limit applies to the loaded amount for non-reloadable products and to monthly loads and the balance for reloadable ones. The products still cannot be used for fund transfers and may be used only with the holder physically present at the merchant, or for purchases and bill payments on trust-marked e-commerce sites.
• Mobile payments. For payment services provided through electronic communications services, transactions may be carried out without identity verification up to TRY 2,500 per transaction, up from TRY 1,000, and TRY 6,500 per month, up from TRY 2,750. Fund transfers remain excluded. Use is limited to purchases of goods and services and bill payments, but without the physical-presence or trust-mark condition that applies to prepaid cards.
IV. General Assessment
Both communiqués took effect on publication with no transition period, so the reporting and postponement obligation has applied since 23 September 2026. Obliged parties that want to use the new thresholds will need to update product limits, system parameters and the amounts in customer terms. The higher thresholds do not make simplified due diligence mandatory, and they do not mean due diligence may be simplified for every transaction below them. MASAK’s guidance on simplified measures states that simplified due diligence may not be applied where laundering or terrorist financing is suspected; the matter must instead be reported to MASAK as a suspicious transaction.
The two changes meet in products that can be used without identity verification. A transaction by a designated person must be reported and postponed whatever its amount, yet with anonymous prepaid cards, e-money and mobile payments the obliged party cannot tell who the user is. Amount limits, usage restrictions and monitoring rules should therefore be designed with that risk in mind, and assessed in the same compliance exercise that introduces the new thresholds.
The listing communiqué sets no separate sanction. Under Law No. 5549, however, an obliged party that carries out a transaction the Minister has suspended or refused, in breach of that decision, faces an administrative fine equal to the transaction amount.
