Legal AlertMASAK Updated Suspicious Transaction Notification Guidelines for Payment and Electronic Money Institutions.

6 June 2024

On 5 June 2024, the Financial Crimes Investigation Board (“MASAK”) announced the publication of an updated version of the Suspicious Transaction Reporting Guide (“Guide“) for the Payment and Electronic Money Institutions operating within the scope of Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions. The Guide incorporates feedback from industry representatives and associations, as well as the National Risk Assessment Report on Combating Money Laundering and Terrorism Financing.

The update introduces several key changes and innovations, including:

  1. The Suspicious Transaction Reporting Form has been simplified to encompass current financial technologies.
  2. Considering the evolving types of crimes, new types of suspicious transactions have been defined. The Guide now includes scenarios such as the customer acting in haste to conduct transactions or requesting that transactions be carried out secretly; existence of a search warrant by local, foreign, or international authorities against a customer; numerous customers transferring accumulated balances to a common bank account; suspicions that transfers made by a customer are used for illegal betting/gambling sites or related crimes; judicial/administrative requests concerning transactions carried out by the customer or through the obliged parties; and information, notifications, or intelligence from other obliged parties suggesting that transactions conducted by the customer might be related to criminal activities.
  3. The existing transaction types have been more broadly defined, and new types specific to the sector have been added, including credit transactions, foreign exchange/cash trading and arbitrage transactions, investment transactions, POS transactions, and card transactions.
  4. The Guide has been updated to include a more detailed definition of various account types that obliged parties encounter. These include non-term/term accounts, credit accounts, check/bill accounts, digital wallets, payment accounts, and accounts opened for POS services.
  5. New reporting categories such as terrorist organization information and Financing of the Proliferation of Weapons of Mass Destruction have been introduced.
  6. Checkpoints have been established to enhance the quality of reports, enabling more effective analysis of suspicious transactions.
  7. Reference value tables have been updated, and new information about types of identity verification and financial institutions mediating the transactions has been added.
  8. A number of new categories of suspicion have been added, including unlicensed payment and electronic money services, failure to declare transactions on behalf of others, pyramid sales schemes (Ponzi schemes), financing the proliferation of weapons of mass destruction, and illegal bill payment center activities, illegal aid and fundraising and abuse of non-governmental organizations making the selection of a suspicion category mandatory.

EMIS ONLINE system has been renamed as MASAK ONLINE 2.0. It has also been redesigned with the latest technology to provide Payment and Electronic Money Institutions with a more secure and flexible structure for payments.

Suspicious transaction notifications to be made after 07.06.2024 should be sent only in accordance with the principles and procedures specified in the Guide.

Please find the full text of the Guide and the Suspicious Transaction Reporting Form at the following link: