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The Communiqué Amending the General Communiqué of the Financial Crimes Investigation Board No. 19 (“Communiqué”) Regarding Communiqué No. 32 (“Amending Communiqué”) was published in the Official Gazette dated 27 June 2026 and numbered 33293, and entered into force upon publication.
Pursuant to Article 4/C of the Communiqué, titled “General Principles Regarding the Remote Identification of Natural Persons Who Are Not Turkish Nationals,” which was added by the Amending Communiqué, natural persons who are not Turkish nationals may, subject to certain conditions, be accepted as customers through remote identification using a passport that complies with the ICAO 9303 standard and has near-field communication (NFC) capability.
However, customers acquired through this method will be classified within the high-risk category and will be subject to additional restrictions with respect to money transfers and cash transactions.
The principal amendments introduced by the Amending Communiqué are set out below.
- Remote identification by passport has been introduced for natural persons who are not Turkish nationals
Principles have been established enabling obliged parties to carry out the identification of natural persons who are not Turkish nationals remotely, through the use of a passport.
In this context, the passport used for remote identification must comply with the ICAO 9303 standard and must have near-field communication (NFC) capability. Whether the identity information contained in the passport's chip matches the information printed on the passport will be verified using near-field communication. If this verification cannot be completed, a business relationship may not be established through remote identification.
Remote identification will be carried out via video call by personnel who have received specific training for this purpose. This requirement does not preclude the use of artificial-intelligence-based applications that meet the conditions set out in the Communiqué for the purposes of liveness detection or photograph comparison.
- Address verification has been established as a precondition for money transfers and cash withdrawals
Address information obtained within the scope of remote identification by passport must be verified on a risk-based approach, either through certain documents or through the relevant country's publicly accessible databases.
Address verification may be carried out through a certificate of residence, address-based utility bills (such as electricity, water or natural gas) issued in the name of the relevant person, a document issued by any public institution, or the relevant country's publicly accessible databases.
Address verification must be completed within three months at the latest. No money transfer or cash withdrawal transaction may be carried out before address verification has been completed.
- Customers acquired through this method will be classified within the high-risk category
Customers acquired through remote identification by passport will be classified within the high-risk category and will be subject to monitoring and control measures appropriate to that classification.
In this context, the measures set out in Article 26/A of the Regulation on Measures Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism ("Regulation"), referenced in Article 6 of the Communiqué, will be taken into account, and (i) for the purpose of verifying the customer's identity information, a money transfer must be made from a domestic or foreign bank account, or from a bank or credit card, that is consistent with the customer's identity information; and (ii) within the scope of this transfer, it will be verified that the distinguishing information contained in the money transfer messages is consistent with the information obtained from the customer during remote identification.
This transfer and verification process must be completed before any other transaction is carried out on the customer's account.
The IP/port information, device identifier, geolocation, browser information and similar technical data obtained from the electronic environment used during the identification process, together with the information contained in the passport, will be evaluated on a risk-based approach.
If this evaluation identifies circumstances giving rise to suspicion, the remote identification process will be terminated.
- Restrictions have been introduced on money transfer and cash withdrawal transactions
Pursuant to the Amending Communiqué, incoming and outgoing money transfers relating to accounts opened through remote identification by passport have been restricted.
Funds may be credited to an account opened under this method only from bank accounts opened abroad in the name of the person concerned. Likewise, outgoing transfers abroad from such an account may only be made to bank accounts opened in the name of that same person.
A limited framework has also been established with respect to cash withdrawals. No cash withdrawal may be made before address verification has been completed. However, where identification has been carried out in accordance with the second paragraph of Article 6 of the Communiqué, cash withdrawal transactions may be permitted, or the restrictions otherwise applicable to money transfers may not apply.
Where a cash deposit or cash withdrawal transaction is carried out on the accounts of these customers, the risks associated with non-face-to-face transactions will also be taken into account.
- The application has also been extended to persons authorised to represent legal entities
In the remote identification of legal entities registered with the trade registry, the identification of the natural person who is not a Turkish national and who is authorised to represent the legal entity may also be carried out in accordance with the principles set out in the Communiqué, in addition to the elements set out in the first paragraph of Article 7 of the Regulation, titled “Identification of Legal Entities Registered with the Trade Registry.”
- Obliged parties are subject to procedural, guidance and notification obligations
Obliged parties intending to accept customers through remote identification by passport must take the measures necessary to identify, rate, monitor and mitigate the risks associated with this method.
Obliged parties must also prepare an implementation guide covering customer recognition, risk management, monitoring and control activities. Institutions required to establish a compliance programme must incorporate these measures into their institutional policies and procedures.
Within one month of commencing customer acceptance under this method, notification must be made to the Presidency of MASAK regarding the measures taken and the procedures and guides established.
Nationals of countries designated as high-risk may not be accepted as customers through remote identification by passport. In addition, statistical information regarding customers accepted under this method must be sent to the Presidency in the last month of each calendar quarter, on a calendar-year basis.
- Assessment
The amendments made to the Communiqué by the Amending Communiqué enable natural persons who are not Turkish nationals to be accepted as customers through remote identification by passport. However, this possibility has been introduced together with strict verification requirements, address verification, high-risk classification, money transfer restrictions, cash withdrawal limitations and notification obligations to MASAK.
This significant development, which enables persons who are not Turkish nationals to become customers by means of their passports, also places on obliged parties the responsibility of developing their technical and administrative infrastructure in this regard and implementing the necessary arrangements effectively and securely.
For this reason, it is important for obliged parties intending to accept customers using this method to review their technical infrastructure, internal policies and procedures, lists of risky countries, customer acceptance processes and monitoring/control mechanisms, in a manner consistent with the requirements set out in the Communiqué.
- Effective Date
The Amending Communiqué, the provisions of which will be executed by the Minister of Treasury and Finance, entered into force on 27 June 2026.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
