Financial Technologies and Payment Systems
Regulatory structuring for payment institutions, electronic money institutions, and crypto asset service providers within the TCMB, CMB, and FIU framework.
Financial technologies operate at the intersection of payment services, electronic money issuance, open banking, digital asset services, and AML/KYC frameworks. In Turkey, this sector is subject to a multi-layered regime in which the TCMB, CMB, BRSA, and FIU produce parallel regulation and supervision within their respective jurisdictions. Our office provides legal counsel and regulatory management to a broad fintech ecosystem, ranging from payment institutions to electronic money institutions, from open banking service providers to crypto asset service providers.
We assist our clients with the preparation and execution of licensing processes under Law No. 6493 (payment institutions, electronic money institutions), the structuring of activity authorization packages within TCMB regulations, the contractual design of open banking and outsourcing arrangements, and the establishment of internal policies and governance frameworks. Under the crypto asset service provider regime introduced by Law No. 7518 in 2024, we conduct end-to-end structuring for CMB activity authorization applications, internal system requirements, custody of customer assets, and FIU compliance programs. We collaborate with financial institutions' compliance teams in designing suspicious transaction reporting processes, Travel Rule implementation, and supervisory cycles.
Our practice encompasses diverse client profiles ranging from fintech start-ups at formation stage to mature payment actors, from bank-partnership models to cross-border payment service providers. Topics frequently pursued alongside data protection law include customer onboarding processes, alternative authentication systems, and biometric KYC infrastructure. In commercial partnerships (API integrations, point-of-sale partnerships, commission and risk-sharing arrangements), we design contract architecture and regulatory compliance in tandem.
Sound solutions in financial regulation require more than statutory and regulatory text—they demand understanding of the regulator's current stance, informal guidance, and prevailing industry practices. Our office regularly monitors TCMB announcements, CMB policy decisions, and FIU guidance; we aim to provide our clients not merely with compliance, but with a regulatory strategy that is both implementable and commercially sustainable.