Introduction: International Remittance Is a Regulated Fintech Business in Turkey

International remittance has become one of the most significant areas of financial technology.

Consumers no longer necessarily visit a bank branch to send money to another country. Modern remittance companies allow customers to initiate international transfers through:

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

Türkiye represents an important market for international remittance services because of its substantial international trade, migrant and expatriate communities, tourism industry, international workforce and commercial relationships with Europe, the Middle East, Central Asia and other regions.

However, international remittance services in Turkey are regulated financial services.

A fintech company cannot simply develop a mobile application, receive customer funds and transfer those funds abroad without analysing Turkish payment-services legislation.

The principal regulatory framework is established by Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions.

Under Law No. 6493, “money remittance” is a specifically defined payment service. The statutory definition concerns the transfer of funds to a recipient without opening a payment account in the name of the sender or recipient.

International remittance businesses may also fall within other Article 12 payment-service categories where they operate payment accounts or provide additional payment functionality.

The principal financial regulator is the Central Bank of the Republic of Türkiye (“CBRT” or “TCMB”).

Where an international fintech wishes to operate together with a Turkish payment institution, the Payment Services Regulation provides a special cross-border cooperation mechanism under Article 19.

This regime is particularly important because the CBRT expressly permits approved Turkish payment service providers to provide services together with authorised foreign legal entities. The current CBRT list includes approved partnerships involving Wise Payments Ltd., TransferGo Lithuania UAB, Dlocal Limited and Global Collect Services B.V.

International remittance compliance therefore requires analysis of several regulatory layers:

• CBRT licensing;
• Law No. 6493;
• foreign fintech cooperation;
• regulatory capital;
• safeguarding of customer funds;
• foreign exchange;
• MASAK AML/KYC;
• sanctions and transaction monitoring;
• KVKK data protection;
• cybersecurity.

This guide explains the principal legal requirements for international remittance services in Turkey as of July 2026.

1. What Is International Remittance?

International remittance generally refers to a service through which a sender located in one jurisdiction transfers money to a recipient located in another jurisdiction.

A typical example may involve:

Sender in Türkiye → Turkish payment institution → foreign payment partner → recipient abroad

or:

Sender abroad → foreign payment institution → Turkish payment institution → recipient in Türkiye

International remittance can serve:

• individuals sending money to family members;
• employees transferring earnings;
• international students;
• expatriates;
• small businesses;
• international merchants.

The legal classification depends on how the money is transferred.

The fact that money crosses a border does not itself create a separate category called an “international remittance licence.”

Instead, Turkish law classifies the underlying payment service.

2. Money Remittance Has a Specific Legal Definition

Law No. 6493 distinguishes money remittance from account-based transfers.

Under the statutory definition, money remittance concerns a payment service where funds are transferred for the benefit of a recipient without opening a payment account in the name of the sender or recipient.

This distinction is extremely important.

Consider two examples.

Example A: Classic Money Remittance

A customer enters a remittance application.

The customer pays TRY 25,000.

No payment account is opened in the customer’s name.

The institution arranges payment of the corresponding amount to the recipient abroad.

This may fall within the statutory money-remittance category.

Example B: International Transfer From a Payment Account

The customer maintains a permanent payment account with the fintech.

Money is stored in that account.

The customer instructs the institution to transfer money from the account to a foreign recipient.

This may involve the separate regulated categories governing payment accounts and transfers of funds.

Therefore:

A fintech must analyse the product architecture before determining which CBRT authorisations are required.

3. International Remittance Is Not a Separate Standalone Licence

There is no single Turkish licence formally called:

International Remittance Licence

or

International Money Transfer Licence.

Instead, the fintech must hold the relevant payment-service permission under Law No. 6493.

A pure money-remittance provider commonly requires authorisation corresponding to the statutory money-remittance activity.

Where the business also operates payment accounts, transfers funds from those accounts or issues electronic money, additional regulatory permissions may become necessary.

For this reason, a company should not simply tell the CBRT:

“We are a remittance startup.”

It should prepare a detailed diagram explaining:

• how customers provide funds;
• whether payment accounts are opened;
• where funds are held;
• who transfers the money;
• how foreign partners participate;
• how recipients receive funds.

The licence should match the actual flow.

4. Who Can Provide International Remittance Services?

Turkish payment law restricts regulated payment services to legally recognised payment service providers.

Depending on the service, these include institutions such as:

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

An ordinary software company cannot itself become a money-remittance provider merely because a licensed bank processes the transaction somewhere in the background.

A technology company may potentially provide:

• software;
• APIs;
• fraud tools;
• customer-interface technology;

without becoming the regulated payment provider.

However, once it itself:

• receives customer money;
• undertakes the transfer;
• controls payment execution;
• enters the payment-services contract with the customer,

the licensing analysis changes substantially.

5. A Foreign Remittance Licence Does Not Automatically Work in Turkey

One of the most important issues for international fintech companies is the absence of automatic passporting.

A remittance company may already be regulated in:

• the United Kingdom;
• the European Union;
• the United States;
• the UAE;
• Singapore;
• another jurisdiction.

That licence may demonstrate that the business is already regulated and supervised internationally.

But it does not automatically replace Turkish authorisation.

Türkiye operates its own payment-services regulatory regime.

Foreign fintech companies should therefore avoid the assumption:

“We are licensed in Europe, so we can simply activate Turkish customers.”

The Turkish regulatory structure must be established separately.

6. Three Main Market Entry Models for Foreign Remittance Fintechs

An international remittance company generally has three potential routes.

Option One: Establish a Turkish Payment Institution

The foreign group can establish a Turkish joint-stock company and seek the necessary CBRT operating permission.

This structure provides substantial control over:

• customers;
• pricing;
• branding;
• local operations;
• transaction infrastructure.

However, it also creates significant regulatory obligations.

Option Two: Acquire an Existing Turkish Institution

An international fintech may acquire an already licensed payment or electronic money institution.

This can reduce the need to build an institution from the beginning.

However, regulated share acquisitions can require CBRT permission and extensive regulatory due diligence.

Option Three: Partner With a Turkish Licensed Payment Service Provider

The foreign remittance provider can operate together with a Turkish payment institution under the cross-border cooperation framework established in Article 19 of the Payment Services Regulation.

This has become a particularly important route for international fintech companies.

7. Article 19 Is the Key Rule for Foreign Remittance Partnerships

Article 19 regulates services offered together with foreign legal entities.

The provision allows a Turkish institution to cooperate with foreign legal entities that have obtained the necessary CBRT permission.

However, this mechanism is specifically cross-border.

The Regulation states that the cooperation may be used only where:

at least one of the sender or recipient is located abroad.

It cannot be used for payment services where both sender and recipient are located in Türkiye.

Therefore:

Ankara → London may qualify.

Berlin → Istanbul may qualify.

Istanbul → Izmir cannot be transformed into an Article 19 international cooperation transaction merely because a foreign fintech sits somewhere in the technical chain.

This restriction is fundamental.

8. The Foreign Partner Requires CBRT Approval Under the Article 19 Framework

Article 19 does not create an unrestricted ability for Turkish payment institutions to partner with any foreign remittance company.

The foreign legal entity must obtain CBRT permission under the regulatory structure.

The application process requires detailed information concerning the proposed cooperation.

The Regulation contemplates examination of matters such as:

• contractual arrangements;
• rights and obligations of the parties;
• foreign entity’s corporate structure;
• foreign regulatory status;
• intended business model;
• organisational arrangements;
• financial condition;
• proposed services;
• AML/CFT controls.

The CBRT may also request additional documentation.

For foreign fintech companies, Article 19 approval should therefore be treated as a financial regulatory application, not merely a commercial partnership filing.

9. The Foreign Partner Must Be Properly Authorised Abroad

The regulatory framework requires the foreign entity participating in the cross-border structure to have an appropriate legal basis for conducting the relevant financial activity in its home jurisdiction.

This is commercially logical.

The CBRT will generally want to understand:

• who regulates the foreign company;
• what services it may provide;
• whether its licence remains valid;
• whether material regulatory sanctions have occurred;
• whether its AML framework is reliable.

A foreign remittance company’s regulatory history can therefore influence its Turkish market-entry strategy.

10. Current CBRT-Approved International Payment Partnerships

The Article 19 regime is not merely theoretical.

The CBRT currently publishes the approved cooperation structures.

As of July 2026, the list includes:

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

This provides an important precedent for foreign fintech strategy.

International remittance companies can participate in Türkiye through regulated cooperation.

But every new partnership still requires its own legal and regulatory structure.

11. The Foreign Fintech Cannot Be the Sole Visible Face

One of the most important Article 19 restrictions concerns how the service appears to Turkish customers.

The foreign legal entity cannot become the sole visible face of the service.

The Regulation prevents the foreign company from using documentation, advertising or public communications in a way that creates the impression that it independently holds a Turkish operating permission. It also restricts Turkish-targeted internet structures that create the same impression.

This has direct implications for:

• websites;
• mobile applications;
• logos;
• customer agreements;
• onboarding;
• advertising;
• customer support.

A foreign remittance company operating under Article 19 should therefore not design the Turkish customer journey as though the Turkish licensed payment institution does not exist.

12. The Turkish Institution Remains Responsible

The Article 19 structure does not eliminate the responsibilities of the Turkish payment institution.

The domestic institution remains responsible for fulfilling its Turkish regulatory obligations in relation to services provided through the foreign partnership.

This means that responsibility cannot simply be outsourced to the international remittance company.

The Turkish provider must remain capable of:

• supervising transactions;
• protecting customer funds;
• handling complaints;
• complying with MASAK;
• providing records to regulators;
• ensuring appropriate customer treatment.

The foreign partnership is therefore a cooperation model, not a regulatory liability transfer.

13. International Remittance Funds Must Be Safeguarded

Customer money is one of the most important areas of remittance regulation.

The Payment Services Regulation treats funds received in connection with qualifying Article 19 foreign cooperation as payment funds.

Payment institutions must separate payment funds from their own corporate funds and use them only for payment transactions.

Unpaid payment funds must be transferred to dedicated protection accounts maintained at banks.

The Regulation also requires customer-level tracking and reconciliation of protected payment funds.

This means an international remittance institution cannot use customer transfer balances as:

• working capital;
• acquisition financing;
• operating liquidity.

The funds legally belong within the protected payment-services architecture.

14. Payment Funds Must Be Held in the Appropriate Currency

The Regulation provides that payment funds are generally held in safeguarding accounts opened in the currency in which those funds were received.

Where maintaining an account in the relevant foreign currency is impossible or would create unreasonable cost, conversion to another currency may be permitted under the regulatory framework.

This is particularly important for remittance businesses operating multiple currency corridors.

A company may process:

• EUR;
• USD;
• GBP;
• TRY;
• other currencies.

Treasury systems should therefore distinguish:

customer payment funds

from

the company’s own FX exposure and corporate cash.

15. Daily Reconciliation Is an Important Control

Safeguarding is not merely about opening a special bank account.

The institution must maintain records that allow payment funds to be tracked on a customer-by-customer basis.

It must also reconcile its own records with bank statements according to the regulatory framework.

For a remittance fintech processing thousands of transactions, this means the ledger architecture must be capable of answering:

• which customer provided the funds;
• how much was provided;
• which transaction relates to those funds;
• whether settlement occurred;
• how much remains protected.

Weak reconciliation can create both financial and regulatory risk.

16. International Remittance and Foreign Exchange

International remittance often requires conversion between currencies.

For example:

A customer pays TRY in Türkiye.

The recipient receives EUR in Germany.

The transaction therefore includes:

1. payment service;
2. foreign exchange.

Turkish payment institutions are not automatically authorised to operate as general foreign-exchange dealers merely because they provide international payments.

The Payment Services Regulation contains specific rules allowing FX transactions where the conversion is connected with the payment service.

Where both parties are located in Türkiye and use Turkish payment service providers, payment institutions cannot generally conduct the transaction in foreign currency under this framework.

Where one party is located abroad, FX conversion may be provided subject to the regulatory conditions.

17. FX Must Be Ancillary to the Payment

A payment institution cannot use its international-remittance permission as a general currency-trading licence.

The currency conversion must be linked to the underlying payment.

For payment-account transactions, the FX amount must not exceed the payment amount and the currency should not remain indefinitely in the customer’s account.

For transfers conducted without a payment account, the Regulation requires the FX transaction and the associated transfer or remittance transaction to remain technically linked so their relationship can be identified.

In practical terms:

FX exists to enable the remittance—not to create an independent speculative currency service.

18. Foreign Currency Wallets Require Particular Care

Many international fintech products advertise:

“Hold ten currencies in one account.”

This type of feature should not be automatically imported into a Turkish payment-institution model.

Turkish rules impose restrictions on foreign-currency payment accounts and how long certain foreign-currency balances can remain where Turkish residents are involved.

Accordingly, there is a significant legal distinction between:

currency temporarily held for execution of an international payment, and

a permanent multi-currency deposit-like balance.

A Turkish remittance app should therefore obtain separate legal analysis before implementing long-term foreign currency wallets.

19. Exchange Rate Transparency

International remittance pricing can be complex.

The customer may pay:

• an explicit transfer fee;
• an FX commission;
• an embedded exchange-rate margin.

A compliant pricing structure should clearly communicate the financial effect of the transaction.

For consumer-facing fintech companies, transparency is especially important because advertising a remittance as:

“zero fee”

may be misleading where the company earns a substantial undisclosed amount through the FX rate.

The customer should be able to understand:

• how much money is being sent;
• the currency conversion;
• applicable fees;
• approximately how much the recipient will receive.

Transparency is both a consumer-law and trust issue.

20. MASAK Is Central to Remittance Compliance

International remittance is considered a particularly sensitive financial-crime area because money moves:

• rapidly;
• electronically;
• across borders.

Payment and electronic money institutions therefore operate within the Turkish AML/CFT framework administered by MASAK.

For payment institutions providing ordinary money-remittance services, AML compliance is not an optional add-on.

The institution should maintain an operational compliance structure capable of addressing:

• customer identification;
• beneficial ownership;
• transaction monitoring;
• suspicious transaction reporting;
• sanctions risks;
• high-risk countries;
• record retention.

21. KYC Must Cover the Sender

The remittance institution must understand who is sending the money.

Customer due diligence may require information concerning:

• identity;
• residence;
• occupation or business;
• expected transaction activity;
• source of funds;
• purpose of the relationship.

The required depth should reflect risk.

A customer sending TRY 2,000 to a relative may present a different risk profile from a customer repeatedly transferring significant amounts to unrelated recipients in multiple high-risk jurisdictions.

The compliance programme should recognise this difference.

22. Recipient Information Is Also Important

International remittance AML controls should not focus exclusively on the sender.

The recipient is another key part of the transaction.

Systems should preserve sufficient information concerning:

• recipient identity;
• destination jurisdiction;
• account or payment details;
• relationship to the sender where appropriate.

Electronic payment chains that lose beneficiary information can create major regulatory problems.

A fintech should therefore ensure its foreign partners do not strip important payment-message data during technical processing.

23. Electronic Transfers Require Complete Information

MASAK’s regulatory framework pays particular attention to electronic transfers.

Financial institutions must maintain controls to verify that legally required electronic-transfer information is present and establish processes where information is missing.

This is especially relevant for international remittance because the transfer may pass through several institutions before reaching the recipient.

The transaction architecture should preserve reliable payer and beneficiary information throughout the chain.

24. Suspicious Transaction Reporting

Payment and electronic money institutions must report suspicious transactions to MASAK.

MASAK’s current payment/e-money sector reporting framework has been specifically modernised to reflect fintech transaction types, evolving criminal typologies and electronic reporting through MASAK Online.

Examples of remittance patterns potentially requiring investigation include:

• numerous transfers to unrelated recipients;
• unexplained high-volume remittances;
• transfers inconsistent with customer income;
• repeated use of multiple senders for one beneficiary;
• rapid movement of recently received funds;
• suspicious high-risk-country exposure.

The existence of a transaction threshold does not eliminate the need to investigate suspicious behaviour.

25. Suspicious Transactions Must Be Reported Promptly

Under MASAK General Communiqué No. 13, a suspicious transaction must generally be reported no later than ten business days after the suspicion arises.

Where delay could prejudice the matter, reporting must occur immediately.

Remittance compliance systems should therefore contain:

• alert escalation;
• compliance review;
• documented decisions;
• prompt submission capability.

An unresolved transaction-monitoring alert should not remain open indefinitely.

26. Tipping-Off Is Prohibited

A customer should not be told that a suspicious transaction report has been filed merely because the customer asks why a transaction is under compliance review.

Confidentiality around suspicious transaction reporting is a central part of the AML framework.

Customer-support personnel should therefore receive appropriate training.

A seemingly helpful message such as:

“Your transfer is delayed because we reported you to MASAK”

can create serious compliance problems.

27. Remote KYC Is Particularly Important for Remittance Fintechs

International remittance companies usually compete on:

• speed;
• low cost;
• mobile onboarding.

Requiring every customer to visit a physical branch would undermine that model.

Turkish regulation allows regulated financial institutions to use approved remote identity-verification procedures.

This means a customer may potentially open a relationship through:

• mobile devices;
• remote identity technology;
• compliant electronic verification.

However, speed must not reduce verification quality.

The fintech should be able to prove later:

• which person was identified;
• what evidence was used;
• when verification occurred;
• which risk checks were performed.

28. Major 2026 Development: Passport-Based Remote Identification for Foreign Customers

A particularly relevant development for international remittance businesses occurred in June 2026.

MASAK announced that Communiqué No. 32, published on 27 June 2026, amended General Communiqué No. 19 and introduced a framework allowing remote identification through passports for specified:

• non-Turkish natural persons; and
• foreign representatives of Turkish trade-registry companies.

This is potentially significant for fintech companies serving:

• tourists;
• expatriates;
• foreign professionals;
• international business customers.

However, passport-based onboarding does not eliminate:

• sanctions screening;
• risk assessment;
• ongoing monitoring.

29. High-Risk Countries Require Enhanced Attention

International remittance naturally creates country risk.

Transactions involving jurisdictions with:

• weak AML controls;
• terrorism-financing concerns;
• sanctions exposure;
• political instability

may require enhanced measures.

A robust system should incorporate geographic risk into customer and transaction scoring.

Possible controls may include:

• additional documentation;
• source-of-funds inquiries;
• management approval;
• enhanced monitoring;
• lower transaction limits.

The objective is not automatically to reject every cross-border transaction.

The objective is to apply controls proportionate to the risk.

30. Sanctions and Asset-Freezing Controls

Remittance providers should maintain effective screening against applicable asset-freezing and sanctions measures.

Screening should consider both:

• sender;
• recipient.

Where legally required, relevant controlling persons or beneficial owners may also need to be checked.

The sanctions engine should be capable of handling:

• transliteration;
• spelling variations;
• aliases;
• foreign alphabets.

A simple exact-name search can produce dangerous false negatives.

31. Cash-Based International Remittance Creates Additional Risk

Some remittance models allow customers to:

• pay cash;
• collect cash.

Cash increases financial-crime risks because it can reduce traceability compared with transfers from a regulated bank account.

A fintech using cash agents or representatives should therefore consider:

• agent due diligence;
• transaction limits;
• source-of-funds controls;
• cash reconciliation;
• fraud monitoring.

The institution remains responsible for ensuring that its distribution model does not undermine AML controls.

32. Representatives and Agents

International remittance businesses frequently rely on distributed networks.

A Turkish payment institution may provide services through representatives subject to the applicable regulatory regime.

However, using a representative does not move regulatory responsibility away from the licensed institution.

The institution should ensure that representatives properly apply:

• customer identification;
• documentation;
• transaction controls;
• branding requirements.

A poorly controlled representative network can become one of the highest-risk components of a remittance business.

33. Customer Funds Cannot Be Used as Company Money

Safeguarding deserves repetition because it is one of the most serious risks in remittance.

Consider a fintech that receives TRY 100 million in customer transfer instructions but has not yet paid foreign recipients.

That TRY 100 million does not become the company’s ordinary commercial cash simply because it temporarily appears in accounts connected with the institution.

Payment funds are subject to safeguarding and segregation obligations.

The company should not use such money to:

• pay salaries;
• finance marketing;
• repay investors;
• acquire another business.

34. International Remittance and Electronic Money Are Different

International remittance and electronic money are related but legally distinct concepts.

A classic remittance transaction can occur without the customer maintaining a stored balance.

By contrast, an electronic money business may allow a customer to:

• load value;
• maintain an electronic balance;
• transfer value;
• spend the balance.

A remittance fintech that introduces a reusable digital balance should therefore consider whether it is moving from:

money remittance

into

electronic money issuance plus payment services.

This distinction materially changes the regulatory capital position.

35. Electronic Money Institutions Face a Higher 2026 Own-Funds Threshold

From 30 June 2026, the CBRT increased minimum regulatory own-funds requirements.

The current headline minimums are:

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

Accordingly, the decision to create a stored-value remittance wallet can substantially increase the regulatory financial burden.

A fintech should make this decision before—not after—building its product.

36. The Headline TRY 40 Million Is Not Necessarily the Entire Capital Requirement

The current TRY 40 million figure is a minimum own-funds floor for the relevant general payment-institution category.

Actual required own funds can also depend on the institution’s regulatory calculation framework and activities.

Article 19 arrangements may additionally create regulatory expectations relating to foreign cooperation.

Therefore, founders should maintain:

regulatory capital + operating capital + contingency buffers.

The company’s financial plan should not spend regulatory capital as though it were ordinary startup runway.

37. International Remittance Records Must Be Accessible

A regulated Turkish institution should be able to reconstruct a transaction long after it occurred.

Records may need to show:

• sender;
• recipient;
• transfer amount;
• exchange rate;
• fees;
• time of transaction;
• foreign partner;
• settlement;
• KYC information;
• compliance checks.

Under the Article 19 cooperation model, transaction documents and records are required to remain available within the Turkish regulatory architecture.

Technical integration should therefore provide local regulatory access.

38. International Remittance and KVKK

Remittance companies process extensive personal data.

Examples include:

• identity data;
• passport details;
• contact information;
• payment account information;
• beneficiaries;
• transaction histories;
• device information;
• AML risk data.

The Turkish Personal Data Protection Authority’s July 2026 sector guide expressly identifies money remittance services among the payment-sector activities for which the guide was prepared. The guide addresses controller/processor relationships, lawful processing, transfers and data security.

This makes KVKK an important component of remittance compliance.

39. International Payment Does Not Automatically Authorise International Data Transfer

This distinction is particularly important.

A payment may legally need to reach:

Türkiye → Germany.

But customer personal data also flowing from Türkiye to a foreign group company or foreign technology provider creates a separate question under KVKK Article 9.

Therefore:

CBRT approval concerns the payment-service architecture.

KVKK concerns the lawful processing and transfer of personal data.

One does not automatically authorise the other.

40. Foreign Partner Agreements Should Address Data Protection

The agreement between a Turkish payment institution and an international remittance provider should address:

• controller/processor roles;
• customer data;
• AML information;
• transfer mechanisms;
• security measures;
• breach notification;
• data-return obligations;
• retention.

Where customer data leaves Türkiye, the institution should determine whether an appropriate Article 9 mechanism is available.

International group membership does not create a blanket exemption.

41. Cybersecurity Is Particularly Important for Remittance Platforms

International remittance businesses are attractive targets for:

• account takeover;
• identity fraud;
• credential theft;
• payment diversion;
• API attacks.

The CBRT’s current regulatory framework continues to include a dedicated information-systems regime for payment and electronic money institutions.

A remittance company should therefore maintain controls including:

• multi-factor authentication;
• secure customer onboarding;
• encryption;
• API authentication;
• fraud detection;
• penetration testing;
• vulnerability management;
• logging;
• incident response.

Payment security and AML should work together.

42. Fraud Detection and AML Are Different but Connected

A fraud team may detect:

• account takeover;
• stolen card use;
• fake identities.

An AML team may detect:

• structuring;
• suspicious beneficiaries;
• criminal proceeds;
• sanctions exposure.

The same transaction may trigger both systems.

For example:

A newly created account receives money from multiple unrelated persons and immediately sends several transfers to one overseas recipient.

This can be:

• fraud;
• money laundering;
• both.

The teams should therefore have clear escalation pathways.

43. Customer Agreements for Remittance Services

International remittance customers should receive clear contractual information.

The agreement should explain matters such as:

• identity of the regulated payment provider;
• scope of the service;
• fees;
• exchange rate methodology;
• transaction execution;
• customer authentication obligations;
• complaints;
• error handling;
• circumstances in which transactions may be suspended.

Where a foreign partner is involved, the agreement should accurately describe the parties’ respective roles.

Customers should not have to discover the regulatory structure only after something goes wrong.

44. Marketing International Remittance Services

Marketing should avoid misleading expressions.

Problematic claims may include:

• “completely free transfers” where an undisclosed FX margin applies;
• “instant worldwide transfers” where some corridors require compliance review or settlement delays;
• “licensed in Turkey” where only the Turkish partner holds the relevant licence.

The Article 19 framework makes the last issue especially important because the foreign entity cannot create the impression that it independently holds a Turkish operating licence.

45. Complaints and Failed Transfers

International transfers can fail for many reasons:

• incorrect recipient details;
• foreign compliance review;
• sanctions screening;
• correspondent institution rejection;
• technical failure.

Customer-support systems should allow the Turkish institution to determine:

• where the transfer is;
• whether it was rejected;
• whether money should be refunded;
• what information can lawfully be disclosed.

The domestic institution should not simply redirect every complaint to the foreign partner.

Under the regulated cooperation structure, local responsibility remains important.

46. M&A Due Diligence for Remittance Companies

Investors acquiring a remittance fintech should conduct dedicated regulatory due diligence.

The review should cover:

Licence Scope

Does the institution actually hold the required money-remittance and other payment-service permissions?

Foreign Partnerships

Are Article 19 relationships appropriately authorised?

Regulatory Capital

Does the business satisfy the 2026 own-funds requirements?

Safeguarding

Do protected funds reconcile with customer obligations?

FX

Is currency conversion strictly ancillary to regulated payments?

MASAK

Does KYC, sanctions and transaction monitoring actually work?

Data

Are foreign transfers compliant with KVKK?

Cybersecurity

Has the platform suffered material incidents?

Complaints

Are failed-transfer or refund issues systemic?

Remittance transaction volume alone does not demonstrate regulatory quality.

47. Common International Remittance Compliance Mistakes

Assuming an Overseas Licence Is Enough

It is not.

Türkiye has its own payment regulatory regime.

Treating Every Cross-Border Transfer as Money Remittance

Account-based transfers and account-free remittance are legally distinct.

Forgetting Article 19 Approval

Foreign cooperation can require specific CBRT permission.

Allowing the Foreign Company to Appear as the Turkish Licensed Provider

The Article 19 framework restricts this.

Treating Customer Funds as Working Capital

Payment funds are subject to safeguarding.

Offering General FX Trading

FX activity must remain appropriately connected to the payment service.

Ignoring Beneficiary Screening

Both sides of an international transfer can create AML risk.

Using Permanent Foreign-Currency Wallets Without Analysis

Turkish payment-account rules impose important limitations.

Assuming CBRT Permission Covers Personal Data Transfers

KVKK Article 9 requires a separate analysis.

Practical International Remittance Compliance Checklist

Before launching international remittance services involving Türkiye, management should verify:

Business Classification

Is the service classic account-free remittance or account-based money transfer?

Turkish Provider

Which legal entity provides the regulated payment service?

CBRT Licence

Does the licence cover every function actually provided?

Foreign Partner

Is the foreign payment company appropriately regulated?

Article 19

Has CBRT permission been obtained where required?

Customer Interface

Is the Turkish regulated entity properly visible?

Safeguarding

Are customer payment funds segregated?

Reconciliation

Can payment funds be tracked by customer?

Foreign Exchange

Is currency conversion ancillary to the transfer?

Pricing

Are fees and exchange-rate effects transparent?

AML/KYC

Is sender identification adequate?

Beneficiary Screening

Are recipient risks monitored?

Sanctions

Are relevant names screened?

Transaction Monitoring

Can unusual cross-border behaviour be detected?

Suspicious Transaction Reporting

Can MASAK reports be submitted within required deadlines?

Remote Identification

Are onboarding procedures compliant, including the 2026 foreign-passport rules where applicable?

Records

Can the Turkish institution reproduce complete transaction records?

KVKK

Are international data transfers lawfully structured?

Cybersecurity

Are remittance applications and APIs adequately protected?

Frequently Asked Questions About International Remittance Services in Turkey

Are remittance services regulated in Turkey?

Yes. Money remittance is expressly regulated under Law No. 6493.

What is money remittance under Turkish law?

It generally refers to transferring funds to a recipient without opening a payment account in the name of the sender or recipient.

Who regulates remittance companies?

The principal regulator for payment institutions is the Central Bank of the Republic of Türkiye.

Does a foreign remittance licence work automatically in Turkey?

No. A foreign licence does not create automatic passporting into Türkiye.

Can a foreign remittance company partner with a Turkish payment institution?

Yes, subject to the Article 19 framework and CBRT permission where applicable.

Must one party to an Article 19 transaction be abroad?

Yes. The cooperation is limited to payment services where at least one of the sender or recipient is abroad. It cannot be used where both are located in Türkiye.

Are Wise and TransferGo currently involved in CBRT-approved structures?

Yes. The CBRT currently lists Moka United’s approved cooperation with Wise Payments Ltd. and TransferGo Lithuania UAB.

Can the foreign remittance company be the only visible provider?

Not within the Article 19 cooperation structure described by the Regulation. The foreign company cannot become the sole visible face toward the customer or create the impression that it independently holds Turkish permission.

Are remittance funds protected?

Yes. Payment funds are subject to segregation and safeguarding requirements, including dedicated bank protection accounts.

Can a payment institution convert currency?

For qualifying cross-border payments, FX conversion may be conducted where it remains connected with provision of the payment service and regulatory conditions are met.

What is the 2026 minimum own-funds requirement?

The current minimum for the relevant general payment institution category is TRY 40 million, effective from 30 June 2026. Electronic money institutions have a TRY 105 million minimum.

Are remittance providers subject to MASAK?

Yes. Payment institutions are obliged entities under the AML framework, and money-remittance providers generally require robust KYC, monitoring and suspicious transaction procedures.

How quickly must suspicious transactions be reported?

Generally within ten business days after suspicion arises, and immediately where delay would be prejudicial.

Can foreign customers be onboarded remotely?

The remote-identification framework applies subject to regulatory conditions, and the June 2026 MASAK reform introduced passport-based remote identification for specified non-Turkish customers and foreign representatives.

Does KVKK apply to remittance companies?

Yes. The July 2026 payment/e-money sector guide expressly addresses companies providing money-remittance services.

Conclusion: How to Establish a Legally Compliant International Remittance Business in Turkey

International remittance services in Turkey are regulated financial services requiring careful coordination between payment licensing, cross-border cooperation rules, AML, foreign exchange, safeguarding and data protection.

The first step is correctly classifying the payment service.

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

However, many modern fintech products go beyond this basic model.

A mobile remittance company may also:

• maintain payment accounts;
• issue electronic money;
• provide wallets;
• perform FX conversion.

Every additional function should be analysed separately against the CBRT licence categories.

For foreign fintech companies, one of the most important legal developments is the Article 19 cross-border cooperation framework.

The Regulation allows Turkish payment institutions to cooperate with approved non-resident legal entities, provided that at least one side of the payment transaction is abroad.

This creates a practical route into the Turkish market for established international payment companies.

The current CBRT list demonstrates that this route is being used in practice by companies including Wise, TransferGo, Dlocal and Global Collect through Turkish payment service providers.

Nevertheless, Article 19 is not equivalent to passporting.

The foreign entity cannot simply act as though it independently possesses a Turkish licence.

The customer-facing structure must preserve the role and responsibility of the regulated Turkish payment institution.

The foreign company cannot become the sole visible face of the service or create the impression that it independently holds Turkish operating permission.

This means branding, customer agreements and technology architecture should be designed together with the regulatory structure.

Financial protection of customers is equally important.

Payment funds must remain segregated from the institution’s own assets and be transferred into regulated safeguarding accounts where required.

The institution must also maintain customer-level records and reconciliation controls.

This requirement should fundamentally affect treasury management.

A remittance company cannot operate on the assumption that money awaiting transfer belongs to the company.

Foreign exchange represents another major legal issue.

International remittances often require currency conversion, but a payment licence does not create unrestricted authority to conduct foreign-exchange trading.

The current Payment Services Regulation permits qualifying FX transactions where one party is abroad and the conversion remains directly related to the payment service.

The payment institution should therefore maintain a clear relationship between:

FX transaction → underlying remittance transaction.

The company’s software should be capable of demonstrating that relationship.

AML compliance should be equally integrated into the technology.

International remittance presents significant risks involving:

• unidentified parties;
• high-risk jurisdictions;
• sanctions;
• structuring;
• criminal proceeds.

MASAK requires payment institutions to operate effective suspicious transaction reporting mechanisms, and the sector-specific reporting infrastructure has been updated for modern fintech transaction types.

Where suspicion arises, reporting must generally occur within ten business days and immediately where delay creates risk.

Fintech companies should therefore build automated transaction monitoring that supports—not replaces—professional compliance judgment.

Remote onboarding is becoming increasingly practical.

The June 2026 reform enabling passport-based remote identification for specified foreign customers may significantly improve international fintech onboarding in Türkiye.

This can benefit remittance companies serving international residents and foreign business customers.

But remote onboarding should remain risk based.

A digital onboarding process should collect enough information to understand:

• who the customer is;
• why transfers are expected;
• where the money comes from;
• who is receiving it.

Data protection must also be designed into the product.

The Personal Data Protection Authority’s July 2026 sector guide specifically identifies money-remittance services among the payment-sector activities covered and provides guidance concerning processing grounds, data transfers and security.

This is especially important because cross-border payments naturally create pressure to transfer personal data internationally.

However, payment authorisation and personal-data transfer authorisation are separate questions.

A CBRT-approved Article 19 structure does not automatically satisfy KVKK Article 9.

Likewise, a valid KVKK data-transfer mechanism does not itself authorise the financial service.

Both regulatory layers must be addressed.

For foreign fintech companies, the strategic market-entry decision generally comes down to three models:

establish a Turkish licensed institution;

acquire an existing licensed payment/e-money institution;

or

partner with a Turkish licensed institution under the Article 19 framework.

A company seeking complete control over its:

• customer relationship;
• pricing;
• settlement;
• regulatory strategy

may prefer a local licensed subsidiary.

A company seeking faster market access may prefer cooperation with an established Turkish PSP.

However, the latter route necessarily creates greater dependence on the domestic institution because the Turkish PSP remains central to regulatory compliance.

Financial capacity should also form part of the market-entry decision.

From 30 June 2026, the relevant general payment institution category is subject to a minimum own-funds requirement of TRY 40 million, while electronic money institutions face TRY 105 million.

These are not merely incorporation costs.

They are ongoing regulatory financial requirements.

A startup that intends to build a stored-value remittance wallet should therefore consider whether the electronic-money model justifies the substantially higher financial threshold.

The ideal compliance sequence for an international remittance fintech is:

classify the service → determine the Turkish provider → identify CBRT licence scope → choose local licence vs Article 19 partnership → obtain required approvals → establish safeguarding → structure FX → implement MASAK/KYC → design KVKK data transfers → build cybersecurity → launch only within the approved regulatory model.

Ultimately, the central principle is straightforward:

International remittance may cross borders, but it does not cross outside Turkish financial regulation.

When a Turkish customer sends or receives money through a fintech platform, Law No. 6493, the CBRT framework, MASAK and KVKK can all become relevant.

For founders, investors and international payment groups, regulatory architecture should therefore be treated as part of the remittance product itself.

A successful remittance company does not merely move money quickly.

It must also be able to explain:

who is providing the payment service, where customer funds are protected, who the foreign partner is, why the transaction is permitted, how the customer was identified and how every transfer can be reconstructed for regulators.

That is the foundation of a sustainable international remittance business in Türkiye.

Legal Disclaimer: This publication provides general information concerning international remittance and cross-border payment services in Türkiye as of July 2026. It does not constitute legal, financial, tax or regulatory advice. The correct regulatory structure depends on the precise money flow, use of payment accounts, currencies, foreign partners, customer locations, wallet features and technology architecture. Every international remittance business should therefore be individually assessed under Law No. 6493, the current CBRT Payment Services Regulation, MASAK legislation and KVKK before Turkish market entry or launch.