Introduction
For any technology-driven company, having seamless access to banking services is crucial. For crypto companies in Türkiye, however, opening and maintaining a bank account remains one of the most significant—and sometimes existential—challenges. Despite Türkiye’s progressive approach to company establishment and 100% foreign ownership, the local banking sector is highly risk-averse toward cryptocurrency-related businesses.
This article explores why banking remains a pain point for crypto startups in Türkiye, what practical strategies can increase your chances, and what the future may hold as regulation evolves.
1. Why is Banking So Difficult for Crypto Companies in Türkiye?
a) Regulatory Uncertainty
- Lack of sector-specific regulation: While the Turkish government works on comprehensive crypto asset laws, most banks are still guided by traditional risk policies.
- MASAK guidelines: Crypto companies must comply with anti-money laundering (AML) and know-your-customer (KYC) requirements, but this alone does not guarantee banking access.
b) Bank Risk Appetite
- Most mainstream banks in Türkiye view crypto clients as “high risk” due to international regulatory scrutiny, FATF gray lists, and concerns over money laundering or sanctions exposure.
- Even with a fully registered and tax-paying company, simply mentioning “crypto” in your articles of association or website can lead to an automatic rejection.
2. Typical Requirements for Opening a Bank Account
Even for non-crypto companies, Turkish banks demand:
- Company registration documents (Trade Registry Gazette, tax certificate, articles of association)
- Proof of address (office lease agreement)
- Valid IDs and tax numbers for all shareholders/directors
- Detailed business plan and financial projections
- Declaration of ultimate beneficial owners (UBOs)
- Recent bank references (if available)
For crypto companies, additional scrutiny includes:
- AML/KYC program documentation and internal procedures
- Full disclosure of business model and client base (are you an exchange, wallet provider, consultancy, etc.?)
- Evidence of regulatory notifications to MASAK
- Risk assessments and cybersecurity policies
- Contracts with clients and suppliers (if available)
- Source of funds for initial deposits
3. Which Banks Are More Open to Crypto Companies?
a) Private and Participation Banks
While public banks are almost always closed to crypto, some private banks (especially those with international partners or fintech orientation) and participation banks may consider applications, particularly if the company can demonstrate strong compliance culture.
b) Fintech-Friendly Banks
Some new-generation digital banks or fintech-focused branches are experimenting with crypto clients, especially for startups with clean international capital and clear business models.
c) International Banking
Some companies resort to opening accounts with international banks (e.g., in the EU, UAE) for operational payments, though this does not replace the need for a local Turkish account for tax and compliance purposes.
4. Practical Strategies for Success
a) Early Engagement
Start the bank account opening process before incorporating your company, by consulting with several banks about their requirements and crypto policies. Build a relationship with a specific branch manager or business banking officer.
b) Professional Presentation
Prepare a detailed compliance file with:
- Copies of MASAK notifications
- AML/KYC program and manual
- Risk assessment reports
- CVs of founders, showing reputable professional backgrounds
- Third-party legal opinions (from a Turkish lawyer) on the legality of your business
c) Transparency and Proactivity
- Disclose your business model honestly, but focus on your compliance and security measures.
- Offer to restrict services to non-sanctioned countries and to provide regular compliance updates.
d) Using Intermediaries
Some corporate services firms and legal consultants in Türkiye specialize in helping crypto companies find banking partners. These intermediaries can provide introductions and vouch for your compliance credentials.
5. Common Pitfalls and Mistakes
- Omitting or hiding crypto activities (if discovered later, leads to account closure and reputational damage)
- Incomplete compliance documentation
- Trying only state-owned banks
- Underestimating the need for ongoing relationship management (banks periodically review client risk)
6. What If You Cannot Open a Bank Account?
a) Alternative Payment Solutions
Consider reputable payment service providers (PSPs), digital wallets, or e-money institutions licensed in Türkiye for operational payments, but beware of transaction limits and compliance restrictions.
b) International Operations
If your startup is export-oriented, you may rely on international accounts for non-TRY transactions, but Turkish corporate taxation and compliance will still require a local account.
c) Waiting for Regulatory Change
The draft Crypto Asset Law in Türkiye is expected to include a licensing regime and potentially mandate that licensed crypto companies be provided access to banking services. However, until the law passes and is implemented, there is no legal obligation for banks to accept crypto clients.
7. Future Outlook: Will Things Get Better?
- Regulatory clarity will be key: Once the new Crypto Asset Law comes into effect, banks are expected to be more open to servicing licensed companies.
- Institutionalization: As the crypto sector becomes more institutionalized and oversight increases, banks will likely feel more comfortable.
- Potential for crypto-friendly banking products: Demand is rising for special accounts and services for crypto firms—watch the fintech space for innovation.
8. Recommendations for CEOs and Founders
- Start early and consult multiple banks
- Hire a compliance-focused Turkish law firm
- Invest in documentation and internal controls
- Avoid shortcuts or incomplete disclosure
- Maintain open lines of communication with your bank
9. Conclusion
Opening a bank account for a crypto company in Türkiye is currently challenging but not impossible. Persistence, preparation, and compliance are the keys to success. As the legal landscape matures and crypto businesses become more mainstream, it is expected that banking access will gradually improve. Until then, proactive planning and professional advice remain the best tools for any crypto CEO navigating Türkiye’s banking sector.
Stj.Öğr.Esmanur AKTAŞ
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