Blockchain Comparative Guide

1 Legal and enforcement framework

1.1 What general regulatory regimes and issues should blockchain developers consider when building the governance framework for the operation of blockchain/distributed ledger technology protocols?

Developers should bear in mind the following crypto-related laws, issued by the Central Bank (CB) and the Financial Crimes Investigation Board (FCIB), respectively:

• the CB Regulation Prohibiting the Use of Crypto Assets for Payments;
• the FCIB Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism; and
• the FCIB Essentials on the Responsibilities Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism.

In addition, the Law on the Regulation of Broadcasts via Internet and Prevention of Crimes Committed Through Such Broadcasts and the Law on the Protection of Personal Data should be considered as part of a readiness plan by both developers and legal practitioners given the specifics, such as the use cases and design features of a blockchain protocol.

The CB Regulation Prohibiting the Use of Crypto Assets for Payments is the first and only crypto-specific secondary legislation in Türkiye. It does not stem from a primary law (an act of Parliament) regarding crypto-assets. Rather, its purpose is:

• to define what crypto-assets are; and
• to prohibit the use of crypto-assets in payments and payment services until a detailed crypto-specific law has been enacted, which is expected after the general and presidential elections on 14 May 2023.

In essence, the regulation bans the direct and indirect use of crypto assets in:

• payment transactions; and
• payment services and electronic currency issuance.

1.2 How do the foregoing considerations differ for public and private blockchains?

The regulations mentioned in question 1.1 apply to both public and private blockchains. That said, each type may have its own upsides and downsides on a case-by-case basis. For example, from a know-your-customer (KYC) and data privacy perspective, private blockchains are advantageous by design to comply with the FCIB's KYC and data privacy requirements, as the people who will be granted authorisation (at reading and/or verifying levels) to access the blockchain and the acceptance criteria for the nodes are already embedded in the network rules or consensus protocol. The scope of application of general laws and regulations may also vary in case of a private blockchain that is a platform-as-a-service for business-to-business members and transactions.

1.3 What general regulatory issues should users of a blockchain application consider when using a particular blockchain/distributed ledger protocol?

As a rule, the users of a blockchain application are subject to all laws and regulations in force. The main issue in practice is the ability to prove which users are subject to which laws and regulations for what reason concerning their use of the blockchain application. In this context, the verification of identities is a prerequisite. Apart from the precedents that we have seen in various common law countries (eg, the United States, the United Kingdom and Singapore) which have imposed injunctions on crypto-wallets, the applicability of a law or regulation in Türkiye – a civil law country – still depends on the verification of the relevant real or legal persons, as there is no blockchain-specific legislation regulating this matter otherwise.

1.4 Which administrative bodies are responsible for enforcing the applicable laws and regulations? What powers do they have?

Taking into consideration the legislation mentioned in question 1.1, the CB and the FCIB are the regulators on the frontlines in the blockchain space.

However, in line with the recent laws, discussions and legal actions emerging in developed countries, the Capital Markets Board is expected to become the lead regulatory body once the long-awaited crypto law has been enacted. The first signals from the pre-legislative discussions in the parliamentary commissions have confirmed this expectation. In addition, certain roles and responsibilities may be assigned to the Banking Regulation and Supervision Agency and the Information and Communication Technologies Authority, depending on:

• the design of blockchains;
• smart contract protocols; and
• the purpose of crypto-assets to be minted or issued in the future.

From a tax perspective, the Ministry of Finance – and in particular the Revenue Administration – will be the governmental body that imposes the tax regulations.

1.5 What is the regulators' general approach to blockchain?

The government has announced in its various action plans the introduction of new regulations on blockchain and integration of the e-State website (the official website of the state through which various governmental services are provided) with blockchain infrastructure for different use cases.

Likewise, the main opposition party and its alliance have adopted a similar approach in their political programmes. Given the high volume of crypto-assets in Türkiye, regulatory action is likely to increase.

Government bodies and some official institutions have been faster in acting to bring their own blockchain use cases.

At the end of the third quarter of 2021, the CB announced that it had completed the pilot test studies within the scope of the CB Digital Turkish Lira Development Project. At the end of 2022, the first phase of the studies was completed and the first payment transaction on the Digital Turkish Lira Network was successfully carried out. In 2023, the aim is to move to the subsequent phases of the pilot test studies, with the participation of certain banks and financial technology companies.

The Istanbul Settlement and Custody Bank – the central clearing and settlement institution of the Istanbul Stock Exchange – has created the BiGA Project to establish infrastructure that facilitates the transfer of dematerialised gold at specific standards, with its physical equivalent kept in safe custody, using blockchain technology.

1.6 Are any industry or trade associations influential in the blockchain space?

Many associations and communities have been established in different blockchain spaces; as yet, however, none of them has a leading position or high-level representation in, or influence over, the Turkish crypto community and the local blockchain space.

2 Blockchain market

2.1 Which blockchain applications and protocols have become most embedded in your jurisdiction?

The trends in blockchain applications and protocols in Türkiye reflect those emerging around the globe.

Bitcoin and Ethereum have captured the greatest user interest. To celebrate Ethereum Merge in 2022, ETH Istanbul organised an event with the participation of more than 100 prominent names in the sector.

Solana also has a large local community. In February 2023, the Solana x Jump x Circle Hacker House held a five-day event at which many speakers took to the stage and workshops were also held.

Avalanche is another closely followed network – not least because the founder of Avalanche, Emin Gün Sirer, is a Turkish academic. Avalanche has organised hackathons and workshops in Istanbul. TOGG, Türkiye's brand-new local electric automobile brand, has also announced that it is cooperating with Avalanche for its Web3 applications.

Non-fungible tokens (NFTs) are another hot issue for Turkish crypto users. The successful collections of some renowned digital artists – such as Murat Pak, Refik Anadol and Tarık Tolunay – have driven interest, making it easier for the Turkish community to adopt NFTs.

Finally, the centralised crypto exchanges (CEXs) have played a central role in bringing crypto-assets into daily use as payment and investment instruments. BTCTurk and Paribu are the leading CEXs.

2.2 What potential new applications/protocols are most actively being explored?

Aptos, Polygon, Starknet, Arbitrum and Lens Protocol are closely followed by local crypto users.

2.3 Which industries within your jurisdiction are making material investments within the blockchain space?

The leading industries are:

• banking and finance;
• fintech and payment services;
• digital art;
• property development and real estate;
• proptech;
• education; and
• capital markets.

Players in these sectors have been eagerly exploring opportunities and preparing for material investments once a regulatory regime has been introduced.

2.4 Are any initiatives or governmental programmes in place to incentivise blockchain development in your jurisdiction?

Many hackathons are organised periodically. In this context:

• Digiathon was organised by the Digital Transformation Office of the President in November 2022;
• the Akbank ReFi Hackathon was organised in partnership with Akbank and Avalanche in September-October 2022; and
• Avalanche organized the Avalanche Hack in December 2021.

There is also a busy hackathon calendar, especially in Istanbul. The winning projects in these competitions are awarded incentives.

There are also innovation and research centres in many universities which provide support for emerging technologies, in particular blockchain projects. At the Scientific and Technological Research Council, a Blockchain Research Laboratory has been established to support projects developed with blockchain technology.

Within the scope of the Digital Transformation Programme of the Ministry of Industry and Technology, blockchain-based venture projects may be eligible for incentives if they pass specific evaluations.

3 Cryptocurrencies

3.1 How are cryptocurrencies and/or virtual currencies defined and regulated in your jurisdiction?

The Central Bank (CB) Regulation Prohibiting the Use of Crypto Assets for Payments introduced the following definition of 'crypto-assets': "intangible assets that are digitally created with distributed ledger or similar technology and distributed through digital networks and that are not fiat currency, bank money, electronic currency, (a medium of) payment, security, or other capital market instruments."

Although the market is complying with the regulation, its provisions remain controversial, as the letter and spirit of the regulation mean that it is generally applicable – which is the core element of an act of Parliament, rather than a secondary regulation issued by a government or regulatory body. Accordingly, it would be safe to wait for the expected crypto-law to be enacted to see the final and legally valid definition of 'crypto-assets'.

3.2 What anti-money laundering provisions apply to cryptocurrencies?

The Financial Crimes Investigation Board (FCIB) Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism sets forth the anti-money-laundering regime in line with the relevant guidance and decisions of the Financial Action Task Force. Various responsibilities are imposed on crypto-asset service providers, the most fundamental of which is to notify the FCIB of suspicious transactions.

A 'suspicious transaction' arises where there is any information, suspicion or reasonable grounds to suspect that the assets which are the subject of the transaction that has been or is being carried out or attempted to be carried out within or through the obliged parties:

• were acquired through illegal means; or
• are being used for illegal purposes, for terrorist activities or by terrorist organisations, terrorists or those who finance terrorism.

Suspicious transactions include those suspected of being linked, among other things, to:

• tax evasion;
• qualified fraud;
• capital markets-related crimes;
• pyramid schemes; or
• crimes relating to the financial sector.

Clues as to the existence of suspicious transactions might include:

• high-volume transactions made at short intervals through a newly opened account;
• piecemeal transactions made to avoid the amount limits;
• the transfer of purchased assets to unsafe countries;
• the withdrawal of assets to a private wallet within a short space of time;
• the use of the same IP address to access several accounts; and
• incompatible financial profile and transactions.

3.3 What consumer protection provisions apply to cryptocurrencies?

There are no consumer protection regulations specific to crypto-assets. However, the laws and regulations regarding advertising and promotion for the sale, promotion and collection of money apply to crypto-asset projects.

As for advertising, the following universal basic principles are adopted under Turkish law:

• Advertisements and claims must be accurate and substantiated, and must not be misleading; and
• All types of advertisements must clearly indicate that they are advertisements, regardless of the medium.

Business cooperations and endorsements must be presented as advertisements with appropriate hashtags or any other proper means according to the medium.

3.4 How are cryptocurrencies treated from a tax perspective?

The taxation of crypto-assets is not yet regulated in Türkiye.

3.5 What regulatory requirements apply to a cryptocurrency trader/exchange?

Pursuant to the CB Regulation Prohibiting the Use of Crypto Assets for Payments, the direct or indirect use of crypto-assets in payments and the provision of related services are prohibited. In this context, crypto-asset exchanges are prohibited from making payment transactions in crypto-assets.

Pursuant to the FCIB Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism, crypto-asset exchanges are classified as crypto-asset service providers with various responsibilities, including:

• customer due diligence;
• suspicious transaction reporting;
• the provision of information and documents; and
• periodic reporting.

3.6 How are initial coin offerings and securities token offerings defined and regulated in your jurisdiction?

Token offerings are not yet regulated in Türkiye. However, as in the United States, there could be a debate in Türkiye as to whether crypto-assets constitute investment contracts, and ultimately whether initial coin offerings (ICOs) and securities token offerings (STOs) are subject to the registration requirements for the issuance of capital market instruments. Although there are no established practices or regulations on investment contracts, the Capital Markets Law defines 'investment contracts' as a type of capital market instrument, just as the US Securities Act of 1933 includes investment contracts within the definition of 'securities'. The Capital Markets Board (CMB) has not claimed regulatory authority so far to open the same discussion as the Securities and Exchange Commission has done in the United States. The common view is that the CMB will be granted clear authority under the awaited crypto-law, and that ICOs and STOs will then be regulated via secondary legislation by the CMB.

4 Smart contracts

4.1 Can a smart contract satisfy the legal requirements of a legal contract under the laws of your jurisdiction? What will be considered when making this determination?

Smart contracts were first introduced by computer scientist Nick Szabo in 1996 and have not since been classified as legal contracts. Accordingly, it is still controversial to consider a smart contract as a legal contract; and the situation in Türkiye is no exception.

Contracts are regulated by the Code of Obligations. The elements regarding the existence and validity of a contract in the code mostly conflict with the technicalities and operation of blockchain. Moreover, the courts are not as flexible as their counterparts in common law jurisdictions to bring their own lex ferenda interpretations to create a new law without any basis in an act of Parliament. In conclusion, there is a need for a new law that would regulate the requirements for smart contracts to be classified as legal contracts with the relevant criteria.

The following elements will be crucial in determining whether a specific smart contract could be classified as a legal contract:

• verification of the parties' identities;
• the attribution of any legal personality or capacity to crypto-wallets;
• the parties' will and consent, based on the first two points above;
• the timing of the parties' offer and acceptance regarding the subject matter of the contract;
• the legal status of the use of the private key as a legally binding signature;
• the conditions for revocation ex tunc and cancellation ex nunc; and
• a language requirement based on the coding of the smart contract.

4.2 Are there any regulatory or governmental guidelines or policies within your jurisdiction which provide guidance on regulating/defining smart contracts?

No such regulatory or governmental guidelines or policies have been published.

4.3 What parts of traditional contract might smart contracts be able to replace?

Smart contracts are expected to replace traditional contracts concluded using communication tools without the parties' physical presence. The most common use case for such contracts is for the purchase of goods on the Internet.

The acceptance of computer programming language as a contract language and private keys as a new type of legally binding e-signature under new legislation will be required if smart contracts are to replace or co-exist alongside traditional contracts in the future.

4.4 What parts of traditional contracts might smart contracts be unable to replace?

Under Turkish law, some contracts must be made in official written form to be valid and binding. This means that the contract must be drafted and/or certified by officially authorised bodies or offices (eg, notaries public or land registries). Examples include:

• real estate sales contracts;
• car sales contracts; and
• preliminary contracts for real estate sales.

Smart contracts cannot replace such traditional contracts until new laws have been introduced to revise such conditions specifically.

4.5 What issues might present themselves in your jurisdiction with regard to judicial enforcement of smart contracts?

Smart contracts are self-executing computer programs that automatically enforce certain functions coded within them. It is still controversial to consider a smart contract as a binding legal contract. In this context, the following issues will be the first discussion points to conclude judicial enforcement:

• verification of the parties' identities;
• the attribution of any legal personality or capacity to crypto-wallets;
• the parties' will and consent, based on the first two points above;
• the timing of the parties' offer and acceptance regarding the subject matter of the contract;
• the legal status of the use of the private key as a legally binding signature; and
• a language requirement based on the coding of the smart contract.

4.6 What are some practical considerations that parties should consider when drafting a smart contract?

Parties should ensure that:

• the smart contract complies with Turkish law, including contract law, data protection law and other relevant regulations;
• the smart contract terms are clear, specific and unambiguous, to avoid disputes or misunderstandings;
• each party's rights, obligations and performance criteria are clearly defined in detail;
• the parties are accurately identified and verified, to ensure they have the legal capacity to enter into the contract and prevent fraud or misrepresentation;
• the smart contract is designed to integrate with traditional legal systems to facilitate judicial enforcement in case of disputes or breaches; and
• the smart contract is transparent and accountable, to ensure that the parties can access relevant information and monitor the contract's performance and compliance.

Since the smart contract is an electronic record, it can be accepted as evidence. By requesting the appointment of an expert by the court, the contract can be examined by people with technical knowledge.

4.7 How will the foregoing considerations differ when smart contracts are running on a private versus public blockchain?

The requirements for private and public blockchains are identical, since no legal basis has been established on this subject under Turkish law.

5 Data and privacy

5.1 What specific challenges or concerns does blockchain present from a data protection/privacy perspective?

One of the key features of blockchain is immutability, which means that once data is stored on the blockchain, it cannot be deleted or modified. This presents a challenge for data protection and privacy. More work may be required to comply with the rights of data subjects, such as the right to be forgotten or to rectify inaccurate data. As blockchains run on the Internet, their global reach without boundaries may present challenges in complying with the requirements of Turkish data protection law for the cross-border transfer of personal data. Smart contracts, which are self-executing computer programs, can contain personal data which may be processed automatically without human intervention. This presents challenges in ensuring that the data processing is lawful, fair and transparent, as required under Turkish data protection law. Blockchain is not immune to data breaches, and any breach of data stored on the blockchain can have severe consequences for the data subjects. This presents challenges for data controllers in ensuring the security of data stored on the blockchain and complying with their obligations to report data breaches to the Turkish data protection authorities.

Anonymity is a feature of blockchain transactions; however, anonymity does not necessarily equate to privacy, as it may still be possible to identify individuals through other means, such as through data analytics or the use of metadata.

5.2 What potential advantages can blockchain offer in the data protection/privacy context?

• Blockchains can provide enhanced data security by encrypting and decentralising data, making unauthorised access or tampering more difficult. This can help data controllers to comply with their obligations to protect personal data.
• Blockchains can provide greater transparency in data processing by allowing data subjects to see how their data is being used and by whom. This can help to build trust and accountability between data controllers and data subjects.
• The immutability of records on the blockchain can help data controllers to maintain accurate and reliable records of data processing activities, which can be used to demonstrate compliance with Turkish data protection law.
• Smart contracts can automate data processing activities, reducing the risk of human error and ensuring that data processing is carried out consistently and transparently.
• Blockchains can manage and store consent records, allowing data controllers to easily demonstrate that they have obtained valid consent from data subjects to process their personal data.
• Blockchains can facilitate data portability by allowing data subjects to easily transfer their personal data between data controllers, as required under Turkish data protection law.
• Anonymity is a feature of blockchain transactions, as users can be identified by a pseudonym rather than their real name.

6 Cybersecurity

6.1 What specific challenges or concerns does blockchain present from a cybersecurity perspective?

Public blockchains that are strong on decentralisation and security (out of three elements of the blockchain trilemma) and private blockchains with robust node acceptance and consensus protocols run with low-risk contingency. That said, the global blockchain space has seen numerous instances of cyber hacking of smart contract protocols, with varying degrees of severity. This has put smart contract protocols under the spotlight, which is the first subject of concern.

Another cybersecurity concern relates not to the innate features of blockchains, but rather to their operation. The custody of digital assets by centralised exchanges presents a significant risks for crypto-asset investors. A sizeable number of crypto-asset transactions are executed in Türkiye, and consequently Turkish investors have suffered from a loss of funds due to cyber hacking and cyberattacks against various blockchain protocols around the world.

6.2 What potential advantages can blockchain offer in the cybersecurity context?

Blockchain offers a structure which gives users the ability and discretion to determine how to manage and share their own personal data, in contrast to Web 2.0 models, where a wide range of personal data is shared with or without the permission of the user. This is a critical design advantage against belligerent actors.

As pointed out in question 6.1, public blockchains that are strong on decentralisation and security are more solid designs from a cybersecurity perspective, as they can impose physical and monetary (with proof-of-work and proof-of-stake consensus) limitations against cyberattacks.

Given the increase in cyberattacks and hackings in recent years, blockchain bridges and smart contracts – and more specifically, the coding in different use cases (eg, decentralised finance and decentralised autonomous organisation applications) – have proved to be the Achilles' heel of the blockchain space. They should thus be subject to increased auditing and scrutiny, as cyberattacks and hackings against them will ultimately affect the value of crypto-assets and the mass adoption of Layer-1 blockchains.

6.3 What tools and measures could be implemented to mitigate cybersecurity risk?

All centralised exchanges and blockchain protocols are advised to implement and continuously improve their own cybersecurity (risk, monitoring, and development) policies. The essential requirements of such policies should also be embedded in new laws and regulations. Actors should additionally gear up with skilled human and digital resources. Accordingly, the following measures should reinforce and feed into each other to ultimately create a virtuous cycle against cybersecurity risks:

• up-to-date policies and their effective implementation;
• periodic internal and external audits of software, coding and employees; and
• the allocation of skilled human and upgraded digital resources.

7 Intellectual property

7.1 What specific challenges or concerns does blockchain present from an IP perspective?

Blockchains operate globally, which means that IP assets stored on the blockchain may be subject to different IP laws in different jurisdictions. This presents a challenge in ensuring that IP assets are adequately protected and enforced in each jurisdiction. While blockchain can provide transparency in IP transactions, it may also raise privacy concerns – especially if sensitive IP assets are involved. It is important for IP owners to carefully consider the privacy implications of storing IP assets on the blockchain and to implement appropriate measures to protect sensitive information. Smart contracts can be used to automate IP licensing and enforcement; but there may be challenges in ensuring that the terms of the smart contract comply with Turkish IP laws. For example, rights transfer agreements based on intellectual property must be made in writing according to Turkish law. Smart contracts cannot fulfil this requirement. Therefore, a transfer of rights in accordance with the law cannot be realised.

Blockchain can also make it difficult to enforce IP rights, especially if the infringing activity is taking place on a decentralised network. It can be challenging to identify the infringing party and to take appropriate legal action to stop the infringement. In addition, due to the nature of blockchains, it is not possible to delete data. This prevents the termination of the infringement.

7.2 What type of IP protection can blockchain developers obtain?

Blockchain developers can obtain:

• patents for their novel, non-obvious and industrially applicable inventions related to blockchain technology, including new algorithms, data structures and software systems;
• copyrights for their original works, such as the software code used to create a blockchain platform. Copyright protection applies automatically upon creation and registration is not required;
• trademarks to protect their brand names, logos and other identifying marks. Trademarks provide exclusive rights to use the mark in connection with certain goods and services, and registration is required to obtain trademark protection; and,
• industrial design protection for the visual appearance of their blockchain platform, such as the layout, colour scheme and graphical user interface. Industrial design protection is available for a limited time and is subject to registration.

They can also protect their trade secrets, such as the algorithms and protocols used in their blockchain platforms. Trade secrets are protected through confidentiality agreements and non-disclosure agreements, and are not publicly disclosed.

7.3 What are the best open-source platforms that could be used to protect developers' innovations?

In line with global trends, GitHub is the leading choice for developers in Türkiye to share their code with others and collaborate on projects while retaining control over their intellectual property.

7.4 What potential advantages can blockchain offer in the IP context?

Blockchain can provide a tamperproof and transparent record of the creation, ownership and transfer of IP assets. Due to the nature of blockchains, keeping a timestamp makes it easy to determine who is the real creator. This can help to prevent IP infringements and provide evidence of ownership in case of a dispute.

Blockchain technology can facilitate the resolution of IP disputes by providing an objective and transparent record of IP transactions. This can reduce the need for expensive and time-consuming litigation and provide a faster, more efficient means of resolving IP disputes. Smart contracts can be used to automate IP licensing and enforcement, making it easier for IP owners to manage and enforce their IP rights. For example, smart contracts can:

• automatically enforce royalty payments;
• provide for automatic licence renewal; and
• track the usage of IP assets.

Blockchain can provide for greater transparency and accountability in IP transactions, making it easier for IP owners to track the usage and transfer of their IP assets. This can help to prevent IP theft and improve trust between IP owners and licensees.

Blockchain is a decentralised technology, which means that IP assets stored on the blockchain can be accessed from anywhere in the world. This can facilitate the international transfer and licensing of IP assets, making it easier for IP owners to expand.

8 Trends and predictions

8.1 How do you think the regulatory landscape in your jurisdiction will evolve in the blockchain space over the next two years? Are any pending changes currently being considered?

The government has announced in its various action plans the introduction of new regulations on blockchain and the integration of the e-State website (the official website of the state through which various governmental services are provided online) with blockchain infrastructure for different use cases.

Likewise, the main opposition party and its alliance have adopted a similar approach in their political programmes. Given the high volume of crypto-assets in Türkiye, the regulatory landscape in the blockchain space is likely to evolve rapidly in the short and medium term.

8.2 What regulatory changes would you like your jurisdiction to implement to further advance the blockchain industry?

The essential elements to ensure clarity will be crucial in introducing regulatory changes. The basis should be an act of Parliament modelled on the EU Regulation on Markets in Crypto-Assets, which specifies, among other things:

• a definition of 'crypto-assets' along with the relevant fundamental concept;
• the operations, roles and responsibilities of crypto-asset service providers;
• the authorised regulatory bodies for secondary legislation; and
• the conditions for crypto-asset issuance.

More specifically, the Capital Markets Law, the Banking Law, the Commercial Code, the Code of Obligations and the Civil Procedure Law should be harmonised to effectively introduce and set out the legal basis for blockchain, smart contracts and leading use cases, and digital assets.

8.3 What is the largest impediment within your jurisdiction to the adoption of blockchain technology?

The delay in the enactment of new laws and regulations. The private sector and certain government bodies are eager to explore and invest in the blockchain space. Thus far, we have witnessed vast de facto interest and limited investment. Blockchain has huge potential to take off with the right regulatory platform; and once it does, the sky is the limit, given the ingrained advantages of Türkiye – specifically, a young population and a propensity for the swift adoption of new technologies, with daily use cases and state-of-the-art online banking infrastructure in place.

9 Tips and traps

9.1 What are your top tips for effective use of blockchain technologies in your jurisdiction and what potential sticking points would you highlight?

The tokenisation of real-world assets and blockchain enterprise solutions are two categories that will gain momentum once the first pieces of legislation have been introduced. Keep an eye out for the regulatory changes outlined in question 8.2. As the next generations take the reins of Turkish companies, Türkiye is ready to explore new use cases of emerging technologies – in particular, blockchain and artificial intelligence – both domestically and internationally. Cross-border projects with their roots in Türkiye may extend as far as the United States, the United Kingdom, the European Union, Switzerland, Dubai, Hong Kong, and Singapore. Accordingly, regulatory changes in these jurisdictions should be closely followed, in order to come up with a regulatory readiness plan that is also in tune with the dynamics and regulatory landscape of Türkiye.

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.