Introduction: Cross-Border Money Transfers Are Regulated Financial Services in Turkey

International money transfers have become one of the most important segments of the global fintech industry.

Consumers and businesses increasingly expect to transfer funds between countries through:

• mobile applications;
• digital wallets;
• international payment platforms;
• payment institutions;
• electronic money institutions;
• remittance networks.

Türkiye is a significant market for such services because of its international trade, tourism, expatriate population, foreign investors and substantial commercial links with Europe, the Middle East, Central Asia and other regions.

However, providing a cross-border money transfer service involving Turkish customers is not merely a technology business.

Under Turkish law, money transfer and money remittance activities fall within the regulated payment-services framework established principally by Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions.

Article 12 expressly identifies both account-based money transfers and money remittance as regulated payment services. Article 13 further provides that persons other than the Central Bank of the Republic of Türkiye (“CBRT” or “TCMB”) and legally recognised payment service providers cannot provide payment services.

For international fintech companies, the regulatory analysis becomes even more important because Turkish law imposes specific rules on cooperation between a Turkish payment institution and a non-resident foreign legal entity.

Article 19 of the Payment Services Regulation permits qualifying cooperation, but only where strict conditions are satisfied and, in the relevant model, the foreign legal entity has obtained permission from the CBRT. The service must relate to payments in which at least one of the sender or recipient is located abroad.

Accordingly, an international remittance company cannot safely assume that a licence issued in the United Kingdom, European Union, United States, UAE or another jurisdiction automatically authorises it to provide payment services directly to customers in Türkiye.

The Turkish regulatory perimeter must be analysed separately.

This guide explains the principal cross-border money transfer licensing and compliance requirements in Turkey as of July 2026.

1. What Is a Money Transfer Under Turkish Payment Law?

Turkish payment law distinguishes several forms of fund transfer.

Article 12(1)(b) covers transactions involving the transfer of funds held in a payment account, including:

• one-off transfers;
• direct debits;
• payment-card transactions;
• standing orders.

Article 12(1)(ç) separately regulates “para havalesi,” or money remittance.

This distinction is important because not every international transfer is legally a “money remittance” under the narrow statutory definition.

2. What Is “Money Remittance” Under Law No. 6493?

Law No. 6493 specifically defines money remittance as a payment service in which funds are transferred by the sender to the recipient, or to a payment service provider acting on behalf of the recipient, without opening a payment account in the name of the sender or recipient.

This is the classic remittance structure.

For example:

A customer in Istanbul gives TRY 20,000 to a licensed remittance provider.

The customer does not open a payment account.

The provider arranges for the equivalent amount to be delivered to the recipient in Germany.

This can fall within the Article 12(1)(ç) money-remittance category.

By contrast, where the customer already maintains a payment account and the transaction is executed by transferring funds from that account, Article 12(1)(b) may become the more relevant regulatory category.

The product should therefore be classified according to its actual account and fund structure.

3. Cross-Border Transfer Is Not a Separate Licence Category

There is no standalone Turkish licence called:

International Money Transfer Licence

or

Cross-Border Fintech Licence.

Instead, the Turkish entity must hold the appropriate payment-service authorisation under Article 12.

For a remittance company, this will commonly include Article 12(1)(ç).

Where the product uses payment accounts, other Article 12 categories can also become relevant.

The CBRT’s current public registers show the precise payment-service permissions held by each payment and electronic money institution, including whether the relevant institution has Article 12(1)(ç) authority.

A fintech’s commercial description therefore does not establish the scope of its legal licence.

4. Who Can Legally Provide Cross-Border Payment Services in Turkey?

Law No. 6493 recognises the following categories as payment service providers:

• banks;
• electronic money institutions;
• payment institutions;
• PTT within its statutory authority.

The law expressly provides that persons other than recognised payment service providers and the CBRT cannot provide payment services.

An ordinary Turkish software company therefore cannot collect customers’ funds and conduct international remittances merely because it has contracts with foreign payment businesses.

It must either:

1. obtain the necessary Turkish payment institution authorisation; or
2. operate in a structure where the actual regulated service is lawfully provided by an authorised Turkish payment service provider.

5. A Payment Institution Must Obtain CBRT Authorisation

A company seeking to operate as a payment institution must obtain permission from the CBRT.

Law No. 6493 requires an ordinary payment institution to satisfy conditions including:

• establishment as a Turkish joint-stock company;
• suitable significant shareholders and controllers;
• registered shares issued against cash;
• appropriate paid-in capital;
• sufficient management and personnel;
• technical infrastructure;
• complaint-handling units;
• measures protecting customer funds and information;
• a transparent ownership structure.

A cross-border remittance startup should therefore not be structured as an ordinary low-capital software company if it intends to provide the regulated payment service itself.

6. 2026 Own-Funds Requirement for Money Transfer Companies

The statutory paid-in capital requirement should not be confused with the institution’s ongoing prudential obligations.

The CBRT increased minimum own-funds levels effective 30 June 2026.

The current minimums are:

• TRY 20 million for the specified bill-payment category;
• TRY 40 million for other payment institutions, excluding the separate pure Account Information Service category;
• TRY 105 million for electronic money institutions.

A payment institution providing money remittance under Article 12(1)(ç) generally falls within the ordinary payment-institution category.

Accordingly, the relevant headline minimum is currently:

TRY 40 million.

This is an ongoing own-funds obligation, not merely a one-time incorporation requirement.

7. A Foreign Money Transfer Licence Does Not Automatically Passport Into Turkey

One of the most important issues for foreign fintech companies is the absence of a general payment-services passport.

A company licensed by:

• the FCA;
• an EU financial regulator;
• a US money transmitter regulator;
• a UAE authority;
• another foreign authority

does not automatically become entitled to provide regulated payment services directly in Türkiye.

Turkish payment legislation operates independently.

A foreign company’s overseas licence can be important in demonstrating regulatory credibility, particularly when seeking cooperation permission under Article 19.

But it does not replace the Turkish legal structure.

8. Article 19: Cooperation With Foreign Payment Companies

The Payment Services Regulation contains a specific framework allowing Turkish payment institutions to provide services together with non-resident legal entities.

Article 19 provides that a Turkish institution may cooperate with a foreign legal entity authorised under the relevant framework, but the cooperation must be limited to payment services where at least one of the sender or recipient is located outside Türkiye.

Therefore:

Turkey → Germany

can potentially fall within Article 19.

France → Turkey

can potentially fall within Article 19.

But:

Istanbul → Ankara

cannot be provided under the Article 19 cross-border cooperation framework merely because a foreign fintech company participates in the transaction.

Both parties being located domestically removes the transaction from this particular cooperation structure.

9. The Foreign Partner Needs CBRT Permission in the Relevant Cooperation Model

Article 19(7) requires the foreign legal entity participating in the regulated cooperation to obtain CBRT permission.

The application requires substantial documentation concerning matters such as:

• the proposed cooperation;
• the parties’ respective rights and obligations;
• the foreign company’s corporate activities;
• organisational structure;
• intended Turkish operations;
• business model;
• customer benefits;
• local organisational arrangements;
• home-country regulatory permission;
• audited financial statements;
• AML/CFT compliance.

The CBRT may request additional information and documents and will assess whether the cooperation contributes to the payments ecosystem and benefits customers.

This is not therefore a simple commercial partnership notification.

It is a regulatory approval process.

10. The Foreign Partner Must Be Properly Regulated in Its Home Country

The foreign legal entity must generally be authorised by the competent authority in its home jurisdiction to provide payment services or issue electronic money.

Article 19 requires evidence of the foreign entity’s regulatory status or, where applicable under the wording of the rule, evidence from the competent authority that its activities are not prohibited or restricted.

The CBRT also seeks information regarding AML/CFT compliance and whether the foreign partner has faced relevant sanctions in its home jurisdiction.

For an international remittance company, regulatory history can therefore directly affect its ability to enter the Turkish market.

11. The Foreign Company Cannot Be the Sole Visible Face of the Service

Article 19 contains a particularly important customer-facing restriction.

The foreign legal entity cannot become the sole visible face of the payment service toward the Turkish customer.

It also cannot use advertising, documents, branding or public statements in a manner that creates the impression that it independently holds a Turkish operating licence.

Nor may it establish a website designed to target Turkish-resident customers in a manner inconsistent with the Article 19 framework.

This has significant implications for:

• branding;
• mobile applications;
• customer agreements;
• websites;
• marketing campaigns.

The Turkish licensed institution must remain visibly involved in the regulated service.

12. The Turkish Payment Institution Remains Responsible to the Customer

Using an international partner does not allow the Turkish regulated institution to outsource its legal liability.

Article 19 expressly states that the Turkish institution remains responsible to Turkish-resident customers for the services provided through the cooperation.

The relevant transactions are also included in the institution’s regulatory prudential calculations.

The Turkish provider therefore cannot respond to a customer complaint by saying:

“The international company handled the transfer, so this is not our responsibility.”

From the Turkish regulatory perspective, the domestic institution remains responsible for compliance with the applicable framework.

13. Current CBRT-Approved Cross-Border Partnerships

As of July 2026, the CBRT’s current Article 19(7) public list identifies the following approved cooperation relationships:

• Lidio Ödeme Hizmetleri A.Ş. and Global Collect Services B.V.;
• Lidio Ödeme Hizmetleri A.Ş. and Dlocal Limited;
• Moka United Ödeme Hizmetleri ve Elektronik Para A.Ş. and TransferGo Lithuania UAB;
• Moka United Ödeme Hizmetleri ve Elektronik Para A.Ş. and Wise Payments Ltd.

The list demonstrates that international remittance and payment companies can participate in the Turkish market through approved partnership structures.

However, the fact that some companies have obtained permission does not create a general exemption for other foreign fintechs.

Each relevant cooperation must be structured within the regulatory framework.

14. Not Every Foreign Vendor Relationship Requires Article 19 Approval

Article 19 also recognises that some relationships with foreign companies remain outside the special cooperation framework.

Where a Turkish payment institution uses a foreign company in connection with its services but no direct or indirect customer relationship is created between the Turkish customer and the foreign legal entity, Article 19’s cooperation regime may not apply in the same manner.

This distinction can be important for:

• technical software vendors;
• cybersecurity providers;
• cloud providers;
• back-office infrastructure companies.

However, other rules concerning outsourcing, information systems and cross-border data may still apply.

“Outside Article 19” does not mean “outside regulation.”

15. Cross-Border Cooperation Can Trigger Additional Capital Requirements

The CBRT has authority to require additional own funds where an institution cooperates with foreign legal entities under Article 19.

The CBRT can also require:

• the Turkish institution;
• the foreign partner

to maintain collateral under principles determined by the Bank.

Therefore, a Turkish remittance company’s financial model should not assume that the ordinary TRY 40 million minimum always represents the maximum prudential requirement.

A significant international partnership may generate additional capital or collateral expectations.

16. The CBRT Can Restrict or Terminate the Foreign Cooperation

Regulatory approval is not irrevocable.

Article 19 expressly empowers the CBRT to require a Turkish payment institution to:

• restrict;
• terminate

a cooperation relationship with a foreign legal entity.

The commercial agreement should therefore anticipate regulatory intervention.

A cross-border partnership contract should contain provisions addressing:

• regulatory termination;
• data return;
• customer migration;
• outstanding transaction settlement;
• regulatory cooperation.

17. Cross-Border Transaction Records Must Be Kept in Turkey

Article 19 requires documents and records relating to payment transactions conducted through the approved cooperation to be retained within Türkiye by the Turkish institution.

This requirement has important technology implications.

A foreign remittance platform cannot assume that all regulatory evidence may exist only on foreign servers.

The Turkish institution must be able to produce records for:

• CBRT supervision;
• dispute resolution;
• AML review;
• transaction reconstruction.

Record architecture should therefore be planned before technical integration begins.

18. Foreign Partner Systems Do Not Always Have to Be Located in Turkey

The Regulation creates a nuanced approach.

Where:

• all transactions relating to the cooperation pass through the Turkish institution’s information systems; and
• the Turkish institution retains the audit trails,

the foreign partner’s own information systems are not necessarily required to be located in Türkiye solely because of Article 19.

This should not be confused with a general permission to move Turkish payment data abroad.

Other requirements can still apply under:

• CBRT information systems regulation;
• KVKK;
• outsourcing rules.

19. Payment Funds From Foreign Partners Are Protected Funds

The Payment Services Regulation’s safeguarding rules expressly treat funds received from foreign legal entities participating in an Article 19 cooperation as payment funds.

The institution must separate payment funds from its own funds and use them only for execution of the relevant payment transactions.

Unpaid payment funds must be transferred to a dedicated safeguarding account at a bank within the regulatory timetable. The Regulation also requires customer-level records and daily reconciliation between the institution’s records and the safeguarding bank’s account statements.

This means international remittance float is not free corporate liquidity.

20. Foreign Currency Is Particularly Important in Cross-Border Transfers

Unlike purely domestic transfers, international remittances frequently involve foreign exchange.

The Turkish Payment Services Regulation creates a specific FX framework for payment institutions.

Where both parties to the transaction are located in Türkiye and use domestic payment service providers, payment institutions cannot conduct the payment transaction in foreign currency under the rule; such transactions are generally required to be conducted in Turkish lira.

However, where one party is located abroad, the institution may conduct foreign-exchange activity relating to the payment service subject to the specific regulatory conditions.

This creates an important distinction between:

FX trading as an independent business, and

FX conversion ancillary to an international payment.

21. Payment Institutions Cannot Become General FX Dealers

A payment institution’s ability to convert currency for a cross-border transfer does not create unrestricted authority to conduct general foreign-exchange business.

The Regulation permits relevant FX activity only where it is connected with the provision of the payment service and the statutory conditions are satisfied.

For account-based transactions, the FX amount cannot exceed the payment amount and the converted foreign currency must not remain in the customer’s payment account beyond the permitted period.

For account-free transfer/remittance activity, the FX conversion and remittance transactions must be technically linked and capable of being identified as related transactions.

A cross-border money transfer company should therefore not design a speculative FX trading product around its payment licence.

22. Foreign Currency Payment Accounts for Turkish Residents Are Restricted

The Regulation establishes the general principle that payment institutions should not open foreign-currency payment accounts for Turkish residents or allow foreign currency to remain in such accounts as an ordinary stored balance.

Where one party to a payment is abroad and the cross-border payment is agreed to be made in foreign currency, limited foreign-currency holding is permitted subject to timing requirements.

For foreign currency deposited for an outbound payment, the currency should generally no longer remain in the customer’s payment account by the end of the next business day.

For foreign currency received from abroad, it generally should not remain in the same customer’s payment account for more than one month, subject to the regulatory conditions and the CBRT’s power concerning specified risk-management cases.

A remittance wallet should therefore not be designed as an unrestricted foreign-currency savings account.

23. Exchange Rates and Fees Must Be Transparent

Cross-border money transfer products often generate revenue through:

• transfer fees;
• commissions;
• foreign exchange spreads.

Turkish payment regulation requires customers to receive information regarding relevant transaction amounts, fees and exchange rates.

For payment transactions, the provider must supply information concerning the total fee and, where applicable, the exchange rate used.

Where an additional charge is connected to the use of a payment instrument, the customer must generally be informed before the transaction is initiated.

A business should therefore avoid marketing a transfer as:

“free”

where revenue is effectively generated through an undisclosed or misleading FX spread.

24. Cross-Border Transfer Execution Times Can Differ

The Payment Services Regulation establishes general execution timelines for domestic payment transactions.

However, where either the sender’s or recipient’s payment service provider is located abroad, the parties may agree on a different execution period from the ordinary domestic timetable.

This flexibility recognises the reality of international payment chains.

Cross-border transfers may involve:

• correspondent institutions;
• foreign payment systems;
• time-zone differences;
• compliance review;
• foreign holidays.

Nevertheless, the expected completion time should be communicated clearly to the customer.

25. MASAK Regulation Is Central to International Remittance

Cross-border remittance represents a particularly important AML/CFT risk.

Payment and electronic money institutions are subject to Türkiye’s financial crime framework administered by MASAK.

MASAK’s current guidance confirms that payment institutions—except specified institutions exclusively providing limited services such as bill-payment intermediation, Payment Initiation Services or Account Information Services—fall within the formal compliance-programme regime.

A money remittance institution is therefore generally expected to maintain a full AML programme covering:

• corporate policies;
• risk management;
• monitoring;
• compliance officer;
• compliance unit;
• training;
• internal audit.

26. Customer Identification Must Occur Before Relevant Transactions

Article 3 of Law No. 5549 requires obliged institutions to identify persons carrying out transactions, together with persons on whose behalf or account those transactions are conducted, before the relevant transaction where customer-due-diligence rules require identification.

MASAK describes customer-due-diligence requirements as including not only identity verification but also broader measures necessary to understand the customer and the relationship.

For international remittance, this can include understanding:

• sender identity;
• recipient information;
• purpose of transfer;
• source of funds;
• destination country;
• expected transfer activity.

High transaction speed cannot replace customer due diligence.

27. Electronic Transfer Messages Are an AML Control Point

MASAK specifically treats electronic transfers as an area requiring financial-institution controls.

Its compliance criteria require institutions to monitor whether mandatory information in electronic transfer messages is present and to establish processes to correct missing information.

MASAK’s broader guidance also identifies electronic-transfer measures as part of financial institutions’ customer-due-diligence responsibilities.

For cross-border transfers, payment messaging should therefore preserve appropriate sender and beneficiary information throughout the payment chain.

Incomplete information should create a compliance alert rather than being silently ignored.

28. International Sanctions and High-Risk Countries

Cross-border payments create greater exposure to:

• sanctioned persons;
• terrorist-financing risks;
• proliferation-financing risks;
• high-risk jurisdictions.

MASAK’s current Compliance Programme Regulation requires institutions to include advanced controls concerning asset-freezing decisions and to continuously monitor customers and transactions against potential matches.

The rules expressly require electronic-transfer sender and recipient information to be taken into account in this monitoring.

MASAK’s September 2025 Enhanced Measures Guide additionally addresses:

• high-risk customers;
• technological risk;
• financial relationships with risky countries.

Sanctions screening should therefore occur both at onboarding and transaction level.

29. Suspicious International Transfers Must Be Reported

Law No. 5549 requires suspicious transactions—including attempted transactions—to be reported where there is information, suspicion or a reason for suspicion that assets are derived from unlawful activity or are being used for unlawful purposes.

The law also prohibits disclosure of the fact that a suspicious transaction report has been submitted, subject to statutory exceptions.

MASAK maintains a dedicated suspicious transaction reporting guide for payment and electronic money institutions and operates the MASAK Online system for electronic reporting.

Relevant cross-border indicators may include:

• rapid transfers to high-risk jurisdictions;
• repeated transactions inconsistent with customer income;
• numerous unrelated beneficiaries;
• unexplained third-party funding;
• attempts to fragment transfers;
• unusual remittance patterns.

30. MASAK Records Must Generally Be Retained for Eight Years

Under Law No. 5549 and the implementing framework, obliged entities must retain relevant AML documents, books, records and identity-verification materials for eight years, calculated according to the applicable starting point.

Cross-border payment companies may also be subject to additional or longer sector-specific record retention obligations under payment legislation.

Accordingly, the retention policy should be based on the longest applicable regulatory period, rather than simply deleting data after the MASAK period expires.

31. Remote Customer Onboarding for International Remittance

Payment and electronic money institutions can establish customer relationships remotely where the relevant regulatory conditions are satisfied.

MASAK General Communiqué No. 19 specifically provides that payment and electronic money institutions conduct remote identification using the methods and safeguards established by the relevant payment-sector information systems rules.

Remote onboarding must also be risk based.

MASAK requires collection of information including matters such as:

• purpose and nature of the relationship;
• source of funds;
• average income;
• estimated monthly transaction volume;
• expected transaction number.

This is particularly important for remittance apps that promise account setup within minutes.

32. 2026 Reform for Foreign Customers

A particularly relevant development for cross-border fintech occurred in June 2026.

MASAK General Communiqué No. 32, published on 27 June 2026, introduced a framework enabling remote identification through passports for certain non-Turkish natural persons and foreign representatives of Turkish trade-registry companies, subject to the conditions in the amended regulation.

This can materially improve onboarding for international fintech businesses serving foreign customers.

However, remote identification remains subject to risk-management and technical requirements.

It should not be treated as an exemption from KYC.

33. Cross-Border Money Transfers and KVKK

International remittance companies process substantial personal information.

This may include:

• sender identity;
• recipient identity;
• bank/payment account details;
• transaction amounts;
• transaction history;
• device information;
• fraud indicators;
• KYC documents.

The Turkish Personal Data Protection Authority published a dedicated Good Practices Guide for the Payment and Electronic Money Sector in July 2026.

The Guide expressly covers entities involved in money remittance services and addresses issues including:

• controller/processor roles;
• processing conditions;
• data transfers;
• data security.

A remittance company’s privacy compliance should therefore be specifically designed for financial data.

34. Payment Abroad and Personal Data Abroad Are Different Legal Questions

One of the most important compliance distinctions is:

sending money abroad is not the same thing as sending personal data abroad.

A payment may lawfully be cross-border under Article 19 while customer data sharing with the foreign partner must separately comply with KVKK.

The business should therefore perform two analyses:

Payment Regulation

Is the foreign payment cooperation authorised?

Data Protection

Is the personal data transfer to the foreign entity lawful under KVKK Article 9?

One approval does not automatically satisfy the other.

35. Cross-Border Remittance Agreements

The agreement between the Turkish institution and foreign partner should be detailed.

It should address matters including:

• services covered;
• territories;
• currencies;
• sender and recipient responsibilities;
• settlement;
• fees;
• exchange rates;
• AML/KYC;
• sanctions;
• transaction screening;
• data sharing;
• record retention;
• cybersecurity;
• customer complaints;
• regulatory cooperation;
• termination.

Article 19 itself requires the approval application to include a contract showing the parties’ rights and obligations.

The contract should therefore be drafted as a regulatory document, not merely a commercial partnership agreement.

36. Customer Complaints Must Remain Manageable in Turkey

Because the Turkish institution remains responsible to the domestic customer, the cross-border model should provide a local mechanism through which Turkish customers can:

• submit complaints;
• obtain transaction information;
• challenge errors;
• request assistance.

Article 19’s approval documentation also specifically considers the structure through which Turkish customers will be able to communicate problems and have those problems resolved.

A customer should not be forced to contact only a foreign call centre that denies responsibility under Turkish payment law.

37. Foreign Representatives Are a Separate Structure

A Turkish payment institution may also use representatives, including in certain circumstances representatives located abroad.

The Regulation imposes separate rules concerning overseas representation, including consideration of the local regulatory environment, supervisory access and the representative’s legal ability to conduct relevant payment activity.

This structure should not be confused with Article 19 foreign-company cooperation.

The correct model depends on the foreign party’s role.

38. Cross-Border Remittance vs Electronic Money

International money transfer should also be distinguished from electronic money.

A simple Article 12(1)(ç) remittance generally transfers money without opening accounts for the sender or recipient.

By contrast, an international wallet may allow customers to:

• load funds;
• maintain balances;
• transfer value;
• make payments.

That structure may require analysis under the electronic-money framework as well as the relevant payment-service permissions.

The CBRT’s current register shows that electronic money institutions may hold Article 12(1)(ç) money-remittance permission in addition to electronic-money issuance authority.

Therefore, a fintech must determine whether it is providing:

remittance only

or

remittance plus stored-value electronic money.

39. Crypto Assets Are Not a Shortcut for Cross-Border Payments

A company should not assume that converting fiat into crypto before sending value abroad removes payment regulation.

Türkiye maintains a separate regulatory framework governing crypto asset service providers, while the CBRT also continues to maintain restrictions concerning the use of crypto assets in payments.

A cross-border business involving:

• fiat collection;
• conversion;
• crypto transfer;
• fiat payout

may therefore interact with several regulatory regimes rather than none.

The correct analysis should follow the entire money and asset flow.

40. Foreign Fintech Market Entry Options

A foreign money transfer company generally has three strategic routes to the Turkish market.

Establish a Turkish Payment Institution

The company can establish a Turkish A.Ş. and seek the necessary CBRT payment-service permissions.

This offers greater control but requires:

• licensing;
• capital;
• local management;
• AML;
• cybersecurity;
• ongoing supervision.

Acquire an Existing Licensed Institution

A foreign investor can potentially acquire a Turkish payment or electronic money institution holding the required licence scope.

However, the acquisition may itself require CBRT share-transfer approval and extensive regulatory due diligence.

Partner With an Authorised Turkish PSP

The international company can potentially cooperate with a Turkish institution under Article 19 where the regulatory conditions are satisfied.

This is the model reflected in the CBRT’s current partnerships involving international payment companies such as Wise Payments and TransferGo.

The appropriate structure depends on how much commercial and regulatory control the foreign company requires.

41. Compliance Due Diligence for Cross-Border Money Transfer Companies

An investor or commercial partner should examine at least:

Licence Scope

Does the Turkish institution hold Article 12(1)(ç) or the other permissions required by the actual model?

Article 19 Approval

Is the foreign cooperation specifically authorised where required?

Foreign Partner Status

Is the foreign institution properly regulated in its home jurisdiction?

AML Programme

Does the Turkish provider maintain an operational MASAK compliance framework?

Sender and Recipient Screening

Are electronic-transfer data and sanctions controls reliable?

Foreign Exchange

Are FX conversions genuinely connected to payment transactions?

Safeguarding

Are cross-border payment funds correctly segregated?

Record Location

Are Article 19 transaction records available in Türkiye?

Data Protection

Are international personal data transfers lawful?

Consumer Complaints

Can Turkish customers obtain effective local support?

These issues should be examined before entering into a cross-border fintech investment or strategic cooperation.

42. Current Enforcement Risk

The CBRT actively supervises Turkish payment and electronic money institutions.

In its January 2026 announcement concerning 2025 supervisory activity, the CBRT reported:

• 7 licence cancellations;
• 14 temporary licence suspensions;
• restrictions on dividend distribution at 12 institutions;
• administrative fines totalling TRY 373,243,560.30 across 72 institutions;
• 331 files concerning suspected unauthorised payment-service activity referred to prosecutors and/or courts.

This demonstrates that licensing and compliance requirements are actively enforced.

43. Unlicensed Money Transfer Can Create Criminal Exposure

Law No. 6493 imposes criminal sanctions for operating as a payment institution without the required permission.

Persons who conduct activities requiring authorisation without obtaining it may face:

• imprisonment from one to three years;
• judicial fines of up to 5,000 days.

The law also sanctions creating the impression of being an authorised payment or electronic money institution without the required licence.

Cross-border remittance startups should therefore resolve the Turkish licensing perimeter before collecting customer money.

44. Common Cross-Border Money Transfer Compliance Mistakes

Mistake 1: “We Are Licensed in Europe, So We Can Serve Turkey”

A foreign licence does not automatically replace Turkish authorisation.

Mistake 2: “All International Transfers Are Article 12(ç) Remittances”

Not necessarily.

Account-based transactions may fall within Article 12(1)(b), while Article 12(1)(ç) specifically concerns remittance without opening a payment account for sender or recipient.

Mistake 3: “A Foreign Partner Does Not Need CBRT Approval”

Article 19(7) can expressly require the foreign partner to obtain CBRT permission.

Mistake 4: “The Foreign Brand Can Be the Only Customer-Facing Company”

Not under the Article 19 cooperation framework described above. The foreign entity cannot be the sole visible face toward the Turkish customer.

Mistake 5: “Foreign Currency Can Stay in the Wallet Indefinitely”

Turkish-resident payment accounts are subject to specific restrictions concerning foreign-currency balances.

Mistake 6: “International Transfers Are Exempt From MASAK”

The opposite is generally true: cross-border transfers require particularly strong AML, sanctions and electronic-transfer controls.

Mistake 7: “Once Article 19 Approval Is Obtained, Data Can Be Freely Transferred Abroad”

Payment authorisation and KVKK international data-transfer compliance are separate legal requirements.

Practical Cross-Border Money Transfer Compliance Checklist

Before launching an international remittance service involving Türkiye, management should verify the following.

Payment Classification

Is the product an account-based money transfer or Article 12(1)(ç) money remittance?

Turkish Licence

Which Turkish entity provides the regulated payment service?

Licence Scope

Does the current CBRT authorisation cover the exact transaction model?

Foreign Partner

Is the overseas entity properly authorised in its home state?

Article 19

Does the cooperation require CBRT permission?

Customer-Facing Structure

Is the Turkish licensed institution appropriately visible?

Responsibility

Does the agreement recognise the Turkish institution’s regulatory responsibility?

Capital

Does the Turkish institution satisfy the current TRY 40 million minimum own-funds requirement and any additional requirement?

Safeguarding

Are funds received from customers or foreign partners correctly protected?

Foreign Exchange

Is FX activity strictly connected with payment services?

FX Balances

Are foreign-currency holding periods correctly controlled?

AML/KYC

Are sender and beneficiary identities and risk factors assessed?

Electronic Transfer Data

Are required payer and beneficiary details preserved in the transaction chain?

Sanctions

Are sender and recipient screened against relevant freezing and sanctions measures?

Suspicious Transactions

Is MASAK Online reporting operational?

Records

Are transaction and regulatory records maintained in Türkiye where required?

KVKK

Are personal data transfers to the foreign partner legally structured?

Customer Information

Are fees, exchange rates and expected execution times transparent?

Frequently Asked Questions About Cross-Border Money Transfers in Turkey

Are international money transfers regulated in Turkey?

Yes. Money transfer and money remittance are regulated payment services under Law No. 6493.

What is money remittance under Turkish law?

Money remittance is the transfer of funds by the sender to a recipient or a payment service provider acting for the recipient without opening a payment account in the name of the sender or recipient.

Who regulates money transfer companies?

The Central Bank of the Republic of Türkiye regulates and supervises payment and electronic money institutions.

What licence does a remittance company need?

A pure account-free remittance provider will generally need Article 12(1)(ç) permission. Additional permissions may be required where the model involves payment accounts or other regulated services.

Can a foreign money transfer company directly serve Turkish customers using its foreign licence?

A foreign licence does not create automatic Turkish passporting rights.

Can a Turkish payment company partner with Wise, TransferGo or another foreign provider?

Potentially, where Article 19 conditions and CBRT permission requirements are satisfied. The CBRT currently lists approved cooperation structures involving Wise Payments Ltd. and TransferGo Lithuania UAB through Moka United.

Does the foreign company need CBRT permission?

For the cooperation structure regulated by Article 19(7), yes.

Can the foreign company advertise itself as independently licensed in Turkey?

It cannot use branding or communications in a way that creates the impression that it independently holds a Turkish operating licence within the Article 19 cooperation model.

Who is responsible to the Turkish customer?

The Turkish licensed institution remains responsible under Article 19 for the regulated service provided to its Turkish-resident customer.

Can international payments be made in foreign currency?

Cross-border payment institutions can conduct FX conversion connected with the payment service where the regulatory conditions are satisfied.

Can a Turkish resident keep a permanent USD balance with a payment institution?

The Regulation establishes a general restriction against foreign-currency payment accounts for Turkish residents, with limited cross-border payment exceptions and specific timing requirements.

What is the minimum own-funds requirement for a remittance payment institution in 2026?

For the general payment-institution category, the headline minimum is TRY 40 million from 30 June 2026, subject to the detailed prudential framework.

Are remittance companies subject to MASAK?

Yes. Payment institutions providing ordinary money remittance are generally subject to the formal MASAK compliance-programme regime.

Does remote KYC apply?

Payment and electronic money institutions may use remote identification under the applicable regulatory framework. The 2026 MASAK amendments also introduced passport-based remote identification possibilities for specified foreign customers.

Does KVKK apply to international remittance?

Yes. The July 2026 payment/e-money data-protection guide expressly addresses money-remittance activities and international data transfers.

Conclusion: How to Structure a Cross-Border Money Transfer Business in Turkey

Cross-border money transfer regulation in Turkey is built around a combination of payment licensing, foreign-partner regulation, safeguarding, foreign-exchange rules, AML/KYC and data protection.

The first legal question should always be:

What type of payment service is actually being provided?

An account-based international transfer can fall within Article 12(1)(b).

A classic account-free remittance falls within Article 12(1)(ç).

Law No. 6493 specifically defines money remittance as a transfer made without opening a payment account for the sender or recipient.

This distinction matters because the payment institution’s licence must match the actual product.

An institution authorised only for one payment category should not assume it can provide every type of international transfer.

The second key issue is the foreign partnership.

Turkish regulation expressly allows payment institutions to cooperate with non-resident payment companies in cross-border services, but this is not an unrestricted outsourcing model.

Article 19 limits the relevant cooperation to transactions where at least one of the sender or recipient is located outside Türkiye.

The foreign partner must satisfy regulatory conditions and, under Article 19(7), obtain CBRT permission for the relevant cooperation model. The CBRT examines the foreign entity’s authorisation, financial position, AML/CFT compliance, business model and proposed Turkish operations.

The Turkish institution remains responsible.

This is perhaps the most important structural principle.

The international partner cannot become the sole visible face of the service and create the impression that it independently holds a Turkish payment licence.

The domestic regulated institution must remain appropriately visible and responsible toward the Turkish customer.

The current CBRT list demonstrates how this model can work in practice.

As of July 2026, authorised cooperation structures include Moka United’s partnerships with Wise Payments Ltd. and TransferGo Lithuania UAB, alongside Lidio’s partnerships with Global Collect Services B.V. and Dlocal Limited.

This provides an important roadmap for international fintech companies.

But every new partnership still requires its own regulatory analysis.

Financial capacity must also be considered.

From 30 June 2026, the minimum own-funds requirement for the ordinary payment institution category is TRY 40 million.

Article 19 additionally allows the CBRT to impose extra capital or collateral obligations in connection with foreign cooperation arrangements.

A remittance business plan should therefore budget for more than technology and marketing.

Regulatory capital is a permanent part of the operating model.

Safeguarding is equally important.

Funds received from foreign entities under Article 19 cooperation are expressly treated as payment funds, meaning they must be appropriately separated and protected within the Turkish safeguarding framework.

This prevents the remittance provider from using customer transfer funds as ordinary operating cash.

Foreign exchange creates another critical layer.

Turkish payment institutions do not obtain a general foreign-exchange dealing licence merely because they provide international transfers.

FX conversion is permitted in qualifying cross-border transactions only where it is related to the underlying payment service and the regulatory conditions are satisfied.

Turkish-resident customers are also subject to restrictions concerning the maintenance of foreign-currency balances in payment accounts.

Foreign currency intended for outbound transfers generally should not remain in the relevant payment account beyond the specified short period, while incoming foreign currency is subject to its own holding limit.

This means an international remittance company must distinguish between:

transferring foreign currency, and

providing a foreign-currency deposit-like account.

The latter is not automatically permitted.

AML compliance is arguably even more important than ordinary licensing.

International remittances naturally involve geographic, sanctions and source-of-funds risks.

MASAK requires customer due diligence, transaction monitoring and suspicious transaction reporting and treats electronic transfers as a specific financial-institution risk area.

Sender and recipient information should remain traceable throughout the payment chain.

Institutions must also monitor customers and transactions against applicable asset-freezing and sanctions requirements, including the sender and beneficiary information appearing in electronic transfer messages.

Remote onboarding has become increasingly important for international payment companies.

The existing MASAK framework allows payment and electronic money institutions to use regulated remote-identification methods, while the June 2026 amendments expanded the framework for passport-based remote identification of specified foreign natural persons and foreign representatives.

This development can significantly improve digital remittance models serving international users.

However, it does not eliminate the need for:

• risk classification;
• source-of-funds analysis;
• sanctions screening;
• ongoing transaction monitoring.

Personal data creates another separate regulatory layer.

The July 2026 KVKK/TÖDEB Good Practices Guide is particularly relevant because it expressly addresses payment and electronic money businesses including money remittance providers.

A company may therefore need both:

CBRT approval for the payment relationship, and

a lawful KVKK mechanism for the international data transfer.

These are separate requirements.

For foreign fintech companies considering entry into Türkiye, the practical options are therefore:

establish and license a Turkish payment institution;

acquire an existing licensed Turkish institution;

or

partner with an authorised Turkish payment service provider under a properly structured Article 19 model.

The correct choice depends on the company’s desired control over:

• customers;
• branding;
• pricing;
• settlement;
• technology;
• compliance.

For a full local operation, licensing offers greater control but also creates substantial capital and compliance obligations.

A partnership can reduce the need for a new licence but requires the foreign company’s role to remain within the CBRT-approved structure.

The Turkish market should therefore not be approached through the assumption:

“We already have an international remittance platform, so we can simply add Turkey.”

The better approach is:

classify the transfer → identify the Turkish regulated entity → determine the Article 12 licence scope → analyse Article 19 → obtain foreign cooperation permission → design safeguarding → structure FX → implement MASAK/KVKK → integrate systems → launch only after regulatory approval.

Finally, enforcement risk is substantial.

The CBRT’s 2025 supervisory results demonstrate active licence cancellations, suspensions, administrative fines and referrals of suspected unlicensed payment activity to judicial authorities.

Law No. 6493 also provides criminal sanctions for persons operating as payment institutions without the required authorisation.

For founders, international payment groups and investors, the central rule is therefore straightforward:

Cross-border does not mean outside Turkish regulation. Once a Turkish customer sends or receives funds through a regulated payment service, Turkish licensing, AML, safeguarding and customer-protection rules can become directly relevant.

Legal Disclaimer: This publication provides general information concerning cross-border money transfer, international payment and money-remittance regulation in Türkiye as of July 2026. It does not constitute legal, financial, tax or regulatory advice. The required permissions depend on the precise payment flow, customer location, use of payment accounts, foreign partner, currencies, settlement structure and services offered. Each international money transfer business model should therefore be individually reviewed under Law No. 6493, the current CBRT Payment Services Regulation, MASAK legislation and KVKK before Turkish market entry.