Payment and Electronic Institutions Suspicious Transaction Reporting Guide and MASAK Online System Updated

Pursuant to Article 4 titled “Suspicious Transaction Notification” of the Law No. 5549 on Prevention of Laundering Proceeds of Crime (“Law”),  if there is any information, suspicion, or circumstance requiring suspicion that the assets subject to transactions carried out or attempted to be carried out by or through obligated parties have been obtained by illegal means or used for illegal purposes, such transactions must be reported to the Presidency of the Financial Crimes Investigation Board (“MASAK“) by the obligated parties.

In accordance with the obligation mentioned above, Article 28 of the Regulation on Measures to Prevent Laundering Proceeds of Crime and Financing of Terrorism (“Regulation”) stipulates that MASAK may issue guidelines on how to make such notifications.

Within this context, MASAK has issued 11 Suspicious Transaction Reporting Guides, each specific to a different sector, in accordance with the General Communique of the Financial Crimes Investigation Board (Serial No: 13) (“Communique“).

With the announcement (“Announcement”) made by MASAK made on  5 June 2024, it was announced that the Suspicious Transaction Notification Guideline (“Guideline”) and the Form, which regulate the procedures and principles regarding Suspicious Transaction Notifications specific to the payment and electronic money institutions sector, have been updated, and that the MASAK Online 1.0 system, which enables electronic notification, has been updated and switched to the MASAK Online 2.0 system.

Updates to the Guidelines are summarized in the Announcement as follows:

• The Suspicious Transaction Reporting Form has been simplified to cover all current financial technologies,
• Sector-specific transaction and account types have been added,
• New suspicious transaction types have been added considering evolving and changing crime typologies,
• Terrorist organization information and categories for the Financing of the Proliferation of Weapons of Mass Destruction have been added to the reporting categories,
• Control points aimed at improving the quality of reports have been added to the explanation section related to suspicious transactions,
• Reference value tables have been updated, and codes have been changed,
• Sections for identification type and information on the Financial Institution Mediating the Transaction have been added,
• New suspicion categories have been added, and the selection of a suspicion category has been made mandatory.

It was also stated that these updates were made in consideration of the opinions and suggestions received from sector representatives and sector associations and the National Risk Assessment Report on Combating Money Laundering and Financing of Terrorism.

Simultaneously with the update of the Guideline and Form, the MASAK Online 1.0 system, which enables electronic reporting, has also been updated and redesigned as MASAK Online 2.0, and it has been made available for use by obligated parties.

You can access the full text of the Guideline through this link (only available in Turkish).