Amendments Introduced Under the Financial Crime Investigation Board General Communiqué (Serial No. 31)

Certain provisions of the Financial Crimes Investigation Board General Communiqué (Serial No. 5), published in the Official Gazette dated April 9, 2008 and numbered 26842 (the “General Communiqué”), have been amended by the Communiqué on the Amendment of the Financial Crimes Investigation Board General Communiqué (Serial No. 5) (Serial No. 31), published in the Official Gazette dated January 7, 2026 and numbered 33130 (the “Amending Communiqué”). The main amendments are summarized below:

Pursuant to Article 2.1 of the General Communiqué, simplified due diligence measures were not permitted for transactions classified as high risk. With the Amending Communiqué, this restriction has been extended to cover cases where the customer is a foreign politically exposed person, and it has been explicitly stipulated that simplified measures may not be applied in such cases as well.

Under the Amending Communiqué, in relation to insurance and pension companies, the requirement to verify identity information in accordance with the relevant provisions of the Regulation on Measures Regarding the Prevention of Laundering of Proceeds of Crime and the Financing of Terrorism, published in the Official Gazette dated January 9, 2008 and numbered 26751 (the “Regulation”) and to obtain a specimen signature in connection with loss and indemnity payments made to third parties other than the policyholder or the insured has been abolished, provided that such payments are made through a bank account that is consistent with the third party’s identity information and that the identity details are duly verified.

For intermediary services provided to electronic commerce service providers by medium, large and very large-scale electronic commerce intermediary service providers, through the establishment of a business relationship in electronic form for the purpose of conducting electronic commerce transactions and delivering orders on an electronic commerce marketplace, it has become mandatory, prior to customer onboarding, to carry out a fund transfer from a bank account consistent with the prospective customer’s identity information to a verification account established by the obliged entity for this purpose, in order to verify the customer’s identity.

Detailed provisions have been introduced with respect to identity verification procedures for bank accounts opened upon the written request of public institutions and organizations for the purpose of making mandatory payments. In this context, for accounts opened to ensure the execution of payments that are required to be made to beneficiaries under the relevant legislation, the requirement to separately verify the customer’s identity information in accordance with Article 6 of the Regulation, and to obtain a specimen signature has been abolished, provided that identity verification is carried out in accordance with the relevant provisions of the Regulation no later than prior to the payment to the beneficiary. In addition, it has been stipulated under the Article 19 of the Regulation that the frequency of ongoing monitoring of the customer within the scope of a continuous business relationship and the updating of information, documents, and records relating to the customer may be reduced.

With respect to bank accounts opened upon the written request of public institutions and organizations for the purpose of making mandatory payments, the use of such accounts will not be permitted until identity verification has been completed in accordance with the relevant provisions of the Regulation. It is further stated that, in relation to transactions conducted through such accounts, the obligations regarding identification of persons acting on behalf of another under Article 17 of the Regulation and the verification of the beneficial owner under Article 17/A of the Regulation may not be applicable.

The amendments introduce a stricter compliance framework for high risk transactions and foreign politically exposed persons, while at the same time providing a more streamlined and operationally efficient regime for insurance payments and mandatory payments made through public institutions.