On June 13, 2025, the Financial Crimes Investigation Board (MASAK), affiliated with the Republic of Türkiye Ministry of Treasury and Finance, published an announcement regarding the “Suspicious Transaction Reporting (STR) Guide (“the Guide“) for Electronic Commerce Intermediary Service Providers. The obligations outlined in the Guide are presented below for your attention.
- In the Guide announced by the Financial Crimes Investigation Board (MASAK) on June 13, 2025, it is stipulated—pursuant to Article 4, titled “Suspicious Transaction Reporting,” of Law No. 5549 on the Prevention of Laundering Proceeds of Crime—that if any information, suspicion, or circumstance that may give rise to suspicion exists indicating that the assets subject to a transaction carried out or attempted through or on behalf of obligated parties are derived from illegal means or are being used for unlawful purposes, such transactions must be reported by the obligated parties to the Financial Crimes Investigation Board (MASAK).
- The Guide includes a standardized form outlining how Electronic Commerce Intermediary Service Providers are to submit a Suspicious Transaction Report in the event they encounter a suspicious transaction. In such cases, it is mandatory to complete this form and submit the report electronically using information and communication technologies. Within this framework, Electronic Commerce Intermediary Service Providers are obligated to submit suspicious transaction reports in accordance with the procedures and principles set forth in the Guide.
- Obligated parties are required to submit suspicious transaction reports electronically, except in cases of force majeure. In exceptional circumstances, reports may be prepared in hard copy and submitted to the Financial Crimes Investigation Board (MASAK) accordingly.
- Procedures related to electronic submission, suspicious transaction reports with deferral requests, the completion of the suspicious transaction reporting form, general principles regarding the preparation of the form, and other procedural matters such as the structure of the form itself are explained in detail in the Guide.
The full text of the Suspicious Transaction Reporting (STR) Guide can be accessed at https://masak.hmb.gov.tr/duyuru/supheli-islem-bildirim-rehberleri-ve-masak-online-2-0-sistemi-hakkinda-duyuru.
Best Regards,
Balay, Eryiğit & Erten
