On 23 September two documents from Türkiye's financial intelligence body took effect, changing how banks and payment services handle client transactions day to day. Both apply from the date of publication — there is no transition period. For an account holder the first one matters most: it determines what happens to a payment when a sanctions screening returns a match.

A match now means a hold, not a refusal

The lists in question are those of the UN Security Council. Previously a hit in a bank's system meant something simple for the client: the transaction does not go through. The order is now different. Where the person initiating a transaction matches a listed person or entity, the obliged party must notify the financial intelligence body immediately and take steps to postpone the transaction.

The difference is fundamental. A refusal is an answer you can work with: another route, another bank, an explanation. A postponed transaction is a state without an answer — the money has neither left nor returned, and the decision no longer rests with the bank.

The range of those covered is broad: banks, payment and electronic money institutions, capital market intermediaries, financing and factoring companies. A transfer will stop the same way at a bank and at a non-bank service.

A list match and sanctions against you are not the same thing

Screening compares data mechanically, so it also triggers on a matching name, on incomplete information about a counterparty, or on a similar company name. Sorting that out happens after the payment has stopped, not before.

Hence a practical conclusion worth drawing in advance: the documents evidencing the source of funds and the substance of the deal must exist before the transaction, not be assembled afterwards. By the time an explanation is required, there is no time left to collect them.

The second document: thresholds rose, the duty to check did not

The same issue raised the monetary thresholds up to which simplified customer due diligence may be applied. For prepaid cards and electronic money — from 2,750 to 5,500 lira. For mobile payments — from 1,000 to 2,500 lira per transaction and from 2,750 to 6,500 lira per month.

It is easy to draw the wrong conclusion here. The thresholds concern simplified measures, not exemption from checks: identification remains mandatory wherever there is any suspicion of money laundering or terrorist financing, whatever the amount. What has risen is the line below which the procedure is shorter — not the line below which there is none.

The non-bank route has become less reliable

The same issue carried the Central Bank's decision annulling the authorisation of the electronic money institution Papel, which had been licensed in October 2022. This is not an isolated case: restrictions hit Payco and Junomoney at the end of August, and the payment institution TRPOS in early September.

For a business that has built its settlements around non-bank providers the conclusion is simple: there should be more than one route. And it is better not to hold balances in such accounts — once authorisation is withdrawn, the matter moves from payments to debt recovery.

What is worth doing

• Check the counterparty and its bank before the transaction, not after — sanctions lists in Türkiye are updated almost weekly.
• Keep documents ready for every large transaction: contract, invoice, evidence of the source of funds. The payment reference must match the contract.
• Keep a backup payment route and avoid leaving significant balances with non-bank providers.
• If a transaction is stopped, obtain the grounds in writing. An oral explanation from a staff member is no use either for an appeal or in talks with a counterparty.

This material is for general information, describes the content of published documents and is not a legal assessment of any specific situation.