TURKISH AML UPDATE: NEW RULES FOR THE REMOTE IDENTITY VERIFICATION OF FOREIGN CUSTOMERS

On 27 June 2026, the Turkish Financial Crimes Investigation Board (“MASAK”) published the Communiqué Amending the MASAK General Communiqué (Serial No. 19) (Serial No. 32) (“Communiqué”) in the Official Gazette (No. 33293), introducing a new legal framework governing the remote identification of foreign customers under Turkish anti-money laundering (“AML”) legislation.

With the newly introduced Article 4/C, non-Turkish natural personsand foreign representatives of legal entities registered with the Turkish Trade Registry may, subject to certain conditions set out in the Communiqué, be accepted as customers through remote identity verification.

Prior to this amendment, remote identity verification for the establishment of a continuous business relationship was available only for Turkish nationals for certain obliged entities. With the new regulation, the scope of this practice has been expanded, making it possible for non-Turkish natural persons and foreign representatives of legal entities registered with the Turkish Trade Registry to be onboarded remotely, to be accepted as customers through remote identity verification, provided that the required technical, operational and compliance requirements are satisfied.

The Communiqué not only expands the scope of remote identity verification but also establishes detailed technological and operational standards to be followed. Accordingly, remote identity verification may only be carried out by using International Civil Aviation Organization (“ICAO”) Doc 9303-compliant passports containing a Near Field Communication (“NFC”) enabled electronic chip equipped with. The passport chip must be successfully read through NFC technology; otherwise, the remote identity verification process cannot be completed. In this respect, the identity verification process must be conducted through a real-time video interview by personnel who have received specific training on remote passport verification. In addition, artificial intelligence-based solutions may be used for purposes such as liveness detection and biometric facial comparison, provided that they satisfy the security and technical requirements prescribed by the Communiqué.

The Communiqué also introduces significant new compliance obligations for obliged entities carrying out remote customer onboarding. In particular, all customers onboarded through remote passport verification will be classified as high-risk customers and will therefore be subject to enhanced customer due diligence, ongoing monitoring, transaction scrutiny and control measures throughout the business relationship.

Furthermore, the Communiqué introduces detailed technical and operational requirements for obliged entities carrying out remote customer onboarding. In particular, obliged entities are required to verify customers’ identity and address information in accordance with the procedures prescribed under the Communiqué, ensure that the initial funding transaction is carried out through a bank account or payment instrument held in the customer’s own name, apply certain transaction restrictions until the verification process has been completed, and implement additional control measures for customers onboarded through remote identity verification. Accordingly, obliged entities intending to implement remote customer onboarding should carefully review the technical, operational and compliance requirements introduced by the Communiqué and update their internal policies, procedures and systems accordingly.

However, as of the date of this Newsletter, MASAK has not published any supplementary guidance, implementation guidelines or explanatory materials regarding the practical application of these technical and operational requirements. Accordingly, the implementation of the new framework is expected to develop further in light of any future guidance or clarifications issued by MASAK, as well as evolving market practice.

The Communiqué further provides that obliged entities may not accept, through this method, customers who are nationals of countries designated as high-risk under the obliged entity’s internal risk assessment framework.

In addition, obliged entities implementing remote onboarding for foreign customers are required to take the necessary measures for identifying, assessing, monitoring and mitigating risks; to prepare implementation guidelines relating to customer due diligence, risk management, monitoring and control activities; and to adopt the necessary internal policies and procedures. Obliged entities required to maintain a compliance programme must also incorporate these measures into their internal policies and procedures.

Furthermore, obliged entities are required to notify MASAK within one month from the commencement of remote onboarding activities regarding the measures adopted and the procedures and implementation guidelines prepared. They are also required to submit statistical reports to MASAK on a quarterly basis concerning customers onboarded under this framework.

On the other hand, the Communiqué also expressly includes Crypto Asset Service Providers among the obliged entities subject to the remote identity verification rules and introduces certain technical amendments to the terminology used throughout the Communiqué.

Although the amendment significantly facilitates the remote onboarding of foreign customers, it also introduces a comprehensive compliance framework requiring obliged entities to implement enhanced technological controls, stricter customer due diligence measures, ongoing monitoring mechanisms and additional reporting obligations. Accordingly, obliged entities intending to onboard foreign customers remotely should carefully assess whether their existing AML framework, internal policies and procedures, technological infrastructure, and customer onboarding processes fully comply with the new requirements before implementing this onboarding model.

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