Downloading a sectoral guide does not complete a compliance update. Current guidance matters most in customer due diligence, transaction monitoring and the reasoning recorded for a suspicious transaction report.
Establish the business’s obliged-entity status
Businesses do not all have identical MASAK obligations. Assess the actual activity, services and relevant rules to determine obliged-entity status and any compliance-programme or officer requirements. Merely holding a business bank account does not place a company in the same regulated category as a bank. Use the current guide for the correct sector.
A threshold and a suspicion are different
Suspicion cannot be reduced to a high transaction amount. Activity inconsistent with the customer profile, third-party involvement, unexplained flows and contradictory documents should be assessed together. Listed indicators are examples; an unlisted pattern can still create suspicion. A conviction is not required before reporting, and unusual activity is not automatically an offence.
Turn an alert into an explainable case
Record when the alert arose, relevant transactions, customer information and the analyst’s assessment. Explain the actual pattern rather than simply copying transaction data. Responsibilities and access rights should be clear across review, decision and reporting. Check the current deadlines, procedure and electronic channel against the applicable guidance.
Confidentiality and system changes go together
Do not disclose a suspicious transaction report to the customer or unauthorised persons. A guidance update can affect scenario thresholds, training, data fields and audit records. Risk-based testing, sample-case review and a documented change history are more useful than merely uploading a new form. JURIVEX can help assess applicable requirements together with internal processes.
How to organise your application file
Set out events chronologically and match each payment, instruction and reply to its record. Keep original files and capture screenshots with dates and URLs. Retain proof of delivery for written applications. If a statement changes, preserve the earlier version as well. Avoid publishing identity and account information on public channels.
Frequently asked question
Is updating the suspicious transaction report form enough?
A form update alone does not cover the whole compliance process. Review the business’s obliged-entity status, sector guidance, risk assessment, alert review, reporting workflow and confidentiality rules together.
DISCUSS YOUR CASE
Assess your company’s MASAK compliance needs
We can review your business activities, customer and transaction controls, and reporting procedures to assess your options under Turkish law.
A brief summary and important dates are enough for an initial enquiry. Send documents only when requested by our lawyers, through the channel they specify. Do not share passwords, one-time codes or wallet keys.
Sources and legislation
MASAK: Sectoral Suspicious Transaction Reporting Guides
Law No. 5549 on Prevention of Laundering Proceeds of Crime
MASAK: Regulation on Compliance Programmes
Related reading
Financial Crime & MASAK
Fund Trading Halt or Frozen Bank Account? Distinguishing Liquidation from Asset Measures
Prepared on 30 September 2026. General information under Turkish law. Available remedies and deadlines depend on the particular records. No outcome or recovery is guaranteed. The image is illustrative.