The Principles Regarding Remote Identitiy Verification For Natural Persons Who Are Not Turkish Nationals

The Financial Crimes Investigation Board General Communiqué (Serial No. 19) (the “Communiqué”), published in the Official Gazette dated April 30, 2021 and numbered 31470, regulated the procedures and principles for remote identification of Turkish natural persons and legal entities registered with the trade registry. Since the Communiqué did not include any provision regarding non-Turkish natural persons, identification of such persons could only be carried out through face-to-face methods.

With the Communiqué Amending the Financial Crimes Investigation Board General Communiqué (Serial No. 32) (the “Amendment Communiqué”), published in the Official Gazette dated June 27, 2026 and numbered 33293, the procedures and principles for accepting non-Turkish natural persons as customers through remote identification were introduced.

You may find below the details of the new process allowing remote identification through passports.

1. Identification Process

Pursuant to the Amendment Communiqué, remote identification may only be carried out through passports that comply with the International Civil Aviation Organization’s (the “ICAO”) Doc 9303 standard and include near-field communication (the “NFC”) and chip features. Obliged entities must verify through NFC that the information on the passport matches the information stored in the passport chip. Without such verification, the person cannot be accepted as a customer.

Identification must be carried out by personnel through a video call. During the video call, the person and the information on the passport submitted must be assessed together to determine whether the information matches. In addition, artificial intelligence-supported systems that meet the requirements for liveness detection or facial comparison under Article 4/9 of the Communiqué may be used.

The remote identification rules prescribed under the Communiqué for identity documents must also apply to passport-based identification to the extent applicable. In addition, the passport’s compliance with Doc 9303 and information obtained during the identification process, such as IP address and geographical location, must be assessed together. If a suspicious circumstance is identified as a result of this assessment, the remote identification process must be terminated.

The address information declared by the person during identification must be subsequently verified. Address verification, which may be carried out through a certificate of residence, an invoice issued within the last three months, a public authority document or publicly available databases of the relevant country, must be completed within three months at the latest. Until such verification is completed, the relevant customer must not be allowed to carry out money transfer or cash withdrawal transactions.

For remote identification of legal entities registered with the trade registry, the identification of the non-Turkish natural person authorized to represent the legal entity must also be carried out in accordance with the principles set out above.

2. Preparation of the Compliance Guide

Under the Amendment Communiqué, obliged entities must prepare a separate implementation guide setting out the procedures and principles regarding customer due diligence, risk management and control processes before starting customer onboarding. Obliged entities that are required by the Financial Crimes Investigation Board (the “FCIB”) to establish a compliance program, such as banks and crypto asset service providers, must also include the principles regarding this process in their policies and procedures.

Citizens of countries identified as high-risk in the procedures and guides prepared by obliged entities must not be accepted as customers through passport-based remote identification. However, there is no obstacle to applying face-to-face identification methods for such persons.

Within one month from the start of customer onboarding through passport based remote identification, the measures adopted in this regard and the prepared procedures and guides must be notified to the Presidency of Financial Crimes Investigation Board (the “Presidency”).

3. Determination of the Risk Group

Pursuant to the Amendment Communiqué, persons accepted as customers through passport-based remote identification must be classified as high-risk. In this respect, in addition to the measures prescribed under the Regulation on Measures Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism, published in the Official Gazette dated September 1, 2008, the customer’s identity must also be verified through a money transfer.

Accordingly, the customer must carry out a money transfer from a bank account, debit card or credit card that is compatible with their identity information. This transfer and control process must be completed before any other transaction is carried out from the customer account.

As a rule, funds may only be sent to the customer account approved through the above method from bank accounts opened abroad in the customer’s own name. Similarly, if funds are transferred abroad from this account, such amounts may only be transferred to bank accounts opened in the customer’s own name. However, pursuant to Article 6 of the Communiqué, if the customer subsequently physically appears before the institution, their identity is verified face-to-face and their signature specimen is obtained, money transfers may be carried out without being subject to these restrictions.

4. Subsequent Acquisition of Turkish Citizenship

If a person accepted as a customer through passport-based remote identification subsequently acquires Turkish citizenship or becomes a taxpayer in Türkiye, the obliged entity must obtain the necessary information and documents electronically and add them to the customer

file.

5. Notifications to the Presidency

In addition to notifying the Presidency of the procedures and guides, obliged entities are also required to notify the Presidency of statistical information regarding persons accepted as customers through passportbased remote identification. Pursuant to the Amendment Communiqué, these notifications must be submitted to the Presidency in the last month of each three-month period, based on the calendar year.

6. Conclusion

With the Amendment Communiqué, it has become possible to accept non-Turkish natural persons as customers through passport-based remote identification. However, this process introduces additional control, verification, risk management and notification obligations for obliged entities. Therefore, before starting customer onboarding processes, obliged entities should update their relevant policies, procedures and implementation guides, align their technical and operational infrastructure with the principles set out under the Communiqué and fulfill their notification obligations before FCIB within the prescribed periods.