Phased System Planned to Enter into Force on January 1, 2026
A new system introducing a declaration requirement for high-value money transfers in Türkiye is targeted to enter into force on January 1, 2026. The draft regulation aims to limit unregistered money movements, make the purpose of transactions visible in a standardized format, and harmonize audit processes among banks.
The regulation is being designed to cover all money transfers such as EFT, wire transfers, and cash deposits, across all channels without distinction, including mobile banking, internet banking, ATMs, and branch transactions.
Tiered Threshold System
The system will operate based on three amount thresholds:
- Transactions between TRY 200,000 and TRY 2,000,000
- A brief declaration regarding the nature of the transaction will be requested from the sender or recipient.
- If general categories such as “personal payment,” “debt,” or “other” are selected, an additional description of at least 20 characters will be mandatory.
- In banks’ digital channels, ready-made option menus and linked description fields will be used according to transaction type.
- Transactions between TRY 2,000,000 and TRY 20,000,000
- A “Cash Transaction Declaration Form” will be required.
- The nature of the transaction will be specified as concretely as possible on the form.
- If general expressions are preferred, an additional description of at least 20 characters will be requested.
- It is envisaged that this form will be regularly archived within banks’ systems and supported by verifiable information when necessary.
- Transactions of TRY 20,000,000 and above
- The declaration form at this level will be supported with detailed explanations and supporting documents.
- Banks may request invoices, contracts, or equivalent documents.
- The aim is to leave a verifiable trail regarding both the source and the transaction in high-value money movements and to facilitate risk-based supervision.
Transactions Without Declarations
For amounts above the specified thresholds:
- Transfers with no declaration or with incomplete declarations will not be processed.
- Banks may strengthen customer verification steps for transactions above these thresholds (additional checks, additional document requests, etc.).
- To reduce the administrative burden for banks, it is planned to automate processes with standard declaration options, mandatory field controls, and text boxes in screen flows.
Implementation Timeline and Banks’ Preparations
According to the publicly shared draft framework:
- An explanation requirement starting from the TRY 200,000 threshold,
- A declaration form starting from TRY 2,000,000,
- Detailed explanation and document support for transactions above TRY 20,000,000
have been adopted as principles.
The target effective date is January 1, 2026. The rules, to be applied simultaneously across banking channels, are expected to increase transparency and traceability in the financial system.
Given the draft nature, there is a possibility that technical details and threshold values may change until the final legislation is issued. However, core principles such as the tiered system, declaration form requirement, and request for supporting documents are similarly expressed across different sources.
In this process, banks are expected to:
- Update their internal procedures,
- Adapt their digital channels (mobile, internet, ATM) to the new declaration flow,
- Complete staff training, and
- Carry out customer information activities.