Using Crypto in the Payment Leg (Turkey): A Founder’s Field Guide

World Economic Forum – Fictional Q&A Session

---

1. “What is the underlying pattern here? How does Turkish law ‘see’ crypto in payments?”

Well… if you zoom out far enough, Turkish law on crypto in the payment leg rests on three big principles, like three roots feeding one old tree:

1. The Turkish lira is the only king at the checkout.
2. Payment rails are systemic infrastructure, not playgrounds.
3. Crypto is an asset, not a means of payment.

In 2021, the Central Bank of the Republic of Türkiye (CBRT) issued the Regulation on the Disuse of Crypto Assets in Payments, which did something very simple and very strict: it said crypto assets cannot be used directly or indirectly in payments, and payment/e-money institutions cannot intermediate transfers between crypto platforms and merchants.

Later, in 2024–2025, Turkey finally adopted a proper crypto asset framework under the Capital Markets Law: defining crypto assets as intangible digital assets, licensing crypto-asset service providers (platforms, custodians), and tying them tightly to CMB and MASAK supervision.

So the pattern is this:

• You may own crypto, trade it, invest in it.
• You may not use it as the “payment leg” when a Turkish resident buys goods or services.

It’s like saying: you can have gold bars, futures contracts, art NFTs, but when you step up to the POS or the payment gateway, the system wants lira or other permitted instruments, not your favourite token.

Like every tree has many branches, the legal system does too; but the trunk here is clear: the moment of payment in Turkey is a protected ritual, and crypto is politely but firmly kept outside the temple.

---

2. “So is crypto legal or illegal in Turkey? Why does it feel like both?”

It feels like Schrödinger’s asset, I know.

The reality as of 2025 looks like this:

• Legal:
  • Buying, selling, holding crypto on licensed or compliant platforms.
  • Treating crypto as an intangible asset in your balance sheet, subject to accounting and tax rules.
  • Building regulated platforms, custody services, wallets with proper licensing and AML controls.
• Prohibited:
  • Using crypto directly or indirectly as a means of payment for goods or services.
  • Payment & e-money institutions building business models that integrate crypto into payment flows, or intermediating between merchants and exchanges.

Think of it like this:

Crypto is allowed to live in the investment and asset universe, but not in the retail payment universe. Two different sets, overlapping in people’s hearts and wallets, but legally kept apart by a fairly thick line.

Gödel would smile: inside the system, we try to express one thing – “crypto is not money” – while the market keeps treating parts of it like money. That tension never fully resolves; it just moves between statutes, circulars, and enforcement actions.

---

3. “What exactly does the CBRT Regulation ban in the payment leg?”

Let’s be concrete, like in a kitchen ticket line.

The 2021 CBRT Regulation says, in essence:

• Crypto assets shall not be used directly or indirectly in payments.
• No service can be provided that involves the use of crypto assets in payments.
• Payment and e-money institutions may not:
  • develop business models that use crypto in providing payment services or issuing e-money,
  • or intermediate fund transfers between crypto platforms and merchants.

Translated to founder-speak:

• You cannot let customers pay you “in crypto” for a product/service targeted at Turkish residents, whether B2C or B2B, online or offline.
• You cannot build a licensed payment institution that silently converts crypto in the background and settles merchants in TRY as part of one integrated service.
• You cannot be the magical bridge from “user’s wallet at exchange” → “merchant’s bank account” as your core payment product.

The law is worried that if the payment leg goes crypto, the State loses visibility, monetary control, and systemic stability. The regulator wants the final settlement layer in Turkey to remain anchored in lira and supervised rails.

Like a parent who insists kids sit at the table for dinner, even if they spend the rest of the day roaming the woods.

---

4. “As a founder, what payment flows are clearly off-limits?”

Let me answer this like a risk chef doing mise en place. Here are red-zone patterns under current Turkish rules:

1. “Pay with Bitcoin / USDT” button for Turkish users
   • Direct or indirect use of crypto as a payment method = prohibited.
2. Merchant settlement flow built on crypto
   • User pays in crypto → your system aggregates → you settle merchant in TRY as a single payment service?
   • That’s exactly the “indirect” use + intermediation the CBRT tried to shut down.
3. POS terminals or QR systems that natively accept crypto
   • Hardware/software that integrates crypto at the checkout level is fundamentally at odds with the “no crypto in payments” rule.
4. Embedding exchange accounts into your checkout as a ‘one-click pay’ option
   • “Log in to X exchange and pay your cart directly from your balance” – if you wrap this into a payment service, you are walking straight into the prohibition.
5. Advertising or operating as a “crypto payment gateway” in Turkey
   • Positioning your product in the market as using crypto for payments to Turkish merchants is asking for enforcement visits, especially now that platforms and VASPs are under tighter CMB/MASAK scrutiny.

In set-theory terms:

If Set P = “activities that are payment services”, and Set C = “activities that use crypto assets”, Turkish law basically says:

• P ∩ C = forbidden region for licensed payment institutions in Turkey.

You can live in P (pure payments with fiat) or in C (pure crypto exchange/investment), but you can’t sell P∩C as a regulated payment product in the domestic market.

---

5. “Okay, but what is still possible? How can I be crypto-friendly without breaking the rules?”

Now we’re in the yellow zone – and here nuance matters.

Under today’s framework:

• Crypto is legal to own and trade, subject to AML/CTF rules and new licensing requirements for platforms.
• The CBRT Regulation focuses specifically on using crypto in payments and on payment/e-money institutions.

So, structures that tend to be more defensible (if done carefully and with proper legal advice) include:

1. Separation of investment and payment layers
   • User sells crypto on an exchange, receives TRY in their own bank account, and then
   • uses that TRY to pay you through ordinary payment rails (card, transfer, FAST, etc.).
   • The crypto sale and the payment are two distinct legal acts, not one integrated payment service.
2. Accepting only TRY, while being transparent that users may fund themselves however they like
   • Your invoices, contracts, and systems all state pricing and settlement in lira or other accepted fiat.
   • You do not offer or promote any integrated “pay from your crypto balance” function.
3. Corporate crypto on the treasury side, not the checkout side
   • A Turkish company can, in principle, hold crypto as an investment asset on its balance sheet.
   • That is a very different question from letting customers pay in crypto.
4. Building or integrating with licensed crypto platforms
   • If you operate on the exchange / custody side as a licensed crypto-asset service provider under the new 2024 rules, your product is not a payment instrument but a capital markets / asset service.

But there is a thin line between:

• “We run a separate exchange where users can convert,” and
• “We promise merchants a payment solution that just happens to use crypto inside.”

The more your customer journey feels to users like “paying in crypto,” the more risk you’re taking that a regulator will treat you as being in the forbidden zone, even if your lawyers can draw clever diagrams.

Like parenting: it’s not just what you say the rules are, it’s how the kid actually experiences the boundaries.

---

6. “How do the 2024–2025 crypto regulations and FATF pressure change the founder’s risk map?”

In 2024, Turkey brought crypto assets formally into the Capital Markets Law, defined them as a distinct class of intangible digital assets, and put crypto-asset service providers (CASPs) under the Capital Markets Board (CMB) with licensing obligations and sanctions.

Key patterns:

• CASPs must obtain licenses within tight timelines (e.g. applications by mid-2025, authorization by 2026).
• Platforms owe 1% of revenues to CMB and 1% to TÜBİTAK to support blockchain tech and oversight.
• MASAK treats CASPs as fully-fledged obliged entities, with travel rule obligations and enhanced AML monitoring, especially after Turkey’s FATF grey-list experience and subsequent reforms.

For you as a founder, this means:

• If you touch crypto at any scale, you are now very much on the radar of CMB, MASAK, CBRT – three different “parents” with different tempers.
• The State is trying to prove to FATF and global markets that it can control virtual asset flows just as tightly as it controls bank wires and e-money.
• Any attempt to blur the line between regulated payments and crypto flows will be scrutinized not just as a technical issue, but as a money-laundering and financial stability issue.

If debt is like poetry written with numbers, AML is like reading the footnotes under each verse: who paid whom, for what, from where. Crypto doesn’t remove that; it makes the question sharper.

---

7. “What are the real-world consequences if I get this wrong?”

We’re not talking about a gentle tap on the wrist.

Under the crypto and payments framework, you’re staring at several layers of possible pain:

• Administrative fines from CBRT or CMB for operating in violation of payment or crypto-asset regulations.
• MASAK sanctions for AML/CTF breaches, including failure to apply the travel rule or report suspicious transactions.
• Criminal exposure in serious cases involving illegal betting, fraud proceeds, or willful evasion of financial controls.
• Forced business model surgery – being ordered to cease certain services, shut down certain flows, or effectively localize operations.

For a startup that built its narrative around being “the crypto payment solution of Turkey,” that’s not just a fine. That’s identity death.

Khalil Gibran wrote, “Your pain is the breaking of the shell that encloses your understanding.” In regulatory life, that’s almost true: every enforcement wave breaks some companies and forces the survivors to finally understand the system they’re living in.

---

8. “So what is your actual advice to a founder who loves crypto but has to live in Turkey’s legal reality?”

Think like a chef, not a gambler.

1. Respect the checkout as sacred.
   • Keep the payment leg in Turkey clean: lira, allowed instruments, regulated providers.
   • Let crypto live before or after that leg – as investment, treasury, loyalty, collateral – not as the instantaneous medium of settlement for your Turkish customers.
2. Separate your sets.
   • Set P: payment services under Law 6493 and CBRT rules.
   • Set C: crypto asset services under CMB + MASAK.
   • Design your architecture so P and C interact, but don’t merge into a single black box.
3. Assume regulators are not stupid.
   • If users feel like they are “paying in crypto,” the Board may eventually treat you like a crypto payment provider—even if your documentation says otherwise.
   • Clever structures that exist purely to cosmetically dodge the prohibition age badly.
4. Invest in legal and compliance as if they were your core infra.
   • In a world where Turkey is trying to prove post–grey list virtue to FATF, compliance is not just cost; it’s existential.
5. Keep a “plan B” in your drawer.
   • If tomorrow CBRT or CMB says, “Stop this specific crypto-related service,” know how you can pivot to:
     • pure fiat payments, or
     • a pure capital-markets/asset model,
     • without losing your entire value proposition.

TS Eliot again: “For us, there is only the trying. The rest is not our business.”

For you, as a founder in Turkey playing with crypto, “the trying” means:

• Trying to understand the spirit of the rules, not just the letter.
• Trying to build something honest, where the merchant, the customer and the State are not treated as enemies but as stakeholders with different fears.
• Trying to accept that, like Gödel showed, no system – legal or human – will ever be complete. There will always be grey zones, anxiety, and days when a single regulatory footnote triggers your own ADHD-level panic.

But that doesn’t mean you shouldn’t build.
It just means you must build like an adult: with maps, not fantasies; with internal controls, not just marketing decks; with respect for the old tree of the law, even as you grow your own branches in the direction of what’s next.

Contact