The Financial Crimes Investigation Board of Türkiye ("MASAK") announced on May 14, 2024, that it has updated the Suspicious Transaction Reporting Guide ("Guide") and the MASAK Online system, which regulate the procedures and principles regarding suspicious transaction reports specific to the banking sector.
With the update, new suspicious transaction types, especially those made through social media, e-commerce platforms, crypto assets, and virtual POS, have been added to the Guidelines. Some of the newly added suspicious transaction types are as follows:
- Non-compliant spending with the financial profile from POSs belonging to social media platforms,
- High-value transfers from social media platforms,
- High-value spending at payment points belonging to e-pins/games or other virtual environments,
- Spending or high-value transfers that are not compliant with the financial profile on e-commerce platforms,
- High-value and one-way transfers with legal betting platforms that are incompatible with the financial profile,
- Suspicious transactions related to virtual POSs,
- Transfers from e-money and payment institutions to crypto asset service providers ("CASPs"),
- Depositing or withdrawing Turkish Lira to CASP accounts on a regular and continuous basis,
- High-value and fragmented transfers from the assets of CASP customers in CASP accounts to CASP company partners or company employees,
- A customer operating as a CASP making a significant portion of crypto asset transfers with crypto asset wallets identified as being used in illegal activities,
- A large disproportion between the capital and transaction volume of a customer operating as a CASP and requesting an increase in transaction limits,
- A customer not declaring their activity despite conducting transactions like a CASP,
- High-value and one-way transfers between authorized institutions or related parties with CASPs.
In addition, in version 2.0 of the Guide, It is stated that suspicious transaction notifications shall be sent electronically by the obliged parties, except in mandatory cases, and in mandatory cases where electronic submission is not possible, suspicious transaction notifications shall be prepared and transmitted in paper form. In the new guide, the suspicious transaction reporting form has been simplified so that the reports can be analyzed more quickly and effectively by MASAK, and the explanations regarding filling out the form have been given in more detail.
In addition, the procedures and principles regarding "transaction postponement requests" in the new guide and the access processes to the MASAK Online System have also been simplified.
On the other hand, the categories "Terrorist Organization Information" and "Financing the Proliferation of Weapons of Mass Destruction" have been added to the notification categories, the reference value tables have been updated, and the selection of the suspicion category has been made mandatory.
Suspicious transaction notifications must be sent in accordance with the principles and procedures set out in the Guide after the date of 09.05.2024,.
The MASAK Online system, which allows reporting electronically, has also been redesigned with current technology and made available to the obliged parties as MASAK Online 2.0.
The full text of the Guide can be found at the following link:
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.