Legal AlertLimits Concerning Identification Has Been Changed in Prepaid Card, Life Insurance Contracts and E-Money Transactions

31 March 2021

The Communiqué on the Amendment of the “Financial Crimes Investigation Board General Communiqué (No: 5)” (No: 18) (“Amending Communiqué “) published in the Official Gazette dated 26.02.2021 and numbered 31407 shall enter into force as of 01.05.2021. With the amendment, the monetary amounts based on identification have been updated within the scope of simplified measures, and implementation requirements have been arranged. The amendments brought by the said Amending Communiqué are as follows:

1- Amendments Brought by the Communiqué

  • In cases where money laundering or terrorist financing is suspected, the simplified measure shall not be applied. The subject shall be reported to the Financial Crimes Investigation Board (“MASAK”) as a suspicious transaction report. Simplified measures shall not be used in transactions that are considered risky.
  • In life insurance contracts, the limit on transactions that can be made by merely taking identity information without the need for confirmation documents when determining the identity of natural persons has been increased. According to this:

– The limit, which was set as 3000 TL and below for the total premium amount to be paid within 1 year, has been amended as 5000 TL and below transactions.

– The limit set as single premium transactions with a premium amount below 7500 TL has been amended as transactions below 12.500 TL.

  • With the amendment introduced, the simplified measure may be implemented for the Individual pension contract linked to the group in addition to the Employer group pension contracts.
  • For sales of prepaid cards, which cannot be used for fund transfer and are only used for cash withdrawal or purchase of goods and services, the upper limits of transactions, for which identification is not required, have been amended. Accordingly:

– The limit that should not exceed the cash withdrawal amount within the same year has been increased from 300 TL to 500 TL.

– For single-use transactions that cannot be reloaded, the limit that shall not exceed the amount of heavy money has been increased from 750 TL to 1250 TL.

– In transactions that can be reloaded, the limit that shall not exceed the total loading limit and in any case the total balance within a month has been increased from 750 TL to 1250 TL.

  • The upper limits of transactions for electronic money institutions that do not require identification have been increased. In Transactions Regarding the Procurement of Electronic Money:

– The limit that shall not exceed the cash withdrawal amount within the same year has been increased from 300 TL to 500 TL.

– If there is no possibility of reloading, the limit that shall not exceed the amount of funds stored electronically has been increased from 750 TL to 1250 TL.

– The limit, which shall not exceed the total loading amount and in any case the total balance within a month for those who can be reloaded, has been increased from 750 TL to 1250 TL.

In Transactions Regarding Mobile Payment Services:

The limit that shall not exceed the one-time transaction amount has been increased from 300 TL to 500 TL.

–  The limit that shall not exceed the monthly transaction amount has been increased from 750 TL to 1250 TL.

  • The scope of simplified measures has been expanded in transactions where the client is a listed company.
  • Government Business Enterprises are also included in the scope of simplified measures.
  • For legitimate betting companies, a simplified measure may also be applied if the users make transactions with their own credit cards.

You may reach the full Turkish version of the Amending Communiqué via the link below:

resmigazete.gov.tr/eskiler/2021/02/20210226-5.htm