Important Changes in the MASAK Compliance Regulation

With the amendment published in the Official Gazette dated August 22, 2025 and numbered 32994, important regulations and changes were made in the "Regulation on the Compliance Program Regarding Obligations for the Prevention of Laundering of Criminal Proceeds and Financing of Terrorism."

Development and Investment Banks have been obligated to establish compliance programs. The deadline for appointing a compliance officer and deputy has been set as October 31, 2025, and the deadline for establishing a compliance program as November 30, 2025. Electronic gaming and betting operators operating in electronic environments will exclusively appoint compliance officers without establishing a compliance program.

Istanbul Clearing and Custody Bank Inc. has been obligated to exclusively appoint a compliance officer without establishing a compliance program. Compliance officer qualifications will come into effect on December 25, 2025, and under the transitional provision, those who have been serving for at least 6 months and do not meet certain conditions will be able to take the authorization exam for 2 years.

A person who has conducted an examination or audit on an obligated party within the last two years cannot be appointed as a compliance officer or deputy. In the event that a compliance officer or deputy is dismissed or leaves, both the obligated party and the officer are required to notify MASAK in writing with reasons within 10 days.

In conclusion, these changes require comprehensive compliance processes, particularly for the finance sector and actors conducting electronic gaming/betting activities. Failure to comply with deadlines and qualification requirements may result in serious sanctions during audits.