Turkish Central Bank Bans Using Crypto-assets in Payments

Osman Gazi Güçlütürk
9 min readApr 16, 2021
Source: FinTech Istanbul

Turkish Central Bank’s (“TCB”) regulation on “not using crypto-assets” in payments (“Regulation”) was promulgated in today’s official gazette and shall enter into force on 30th April 2021.

Regulation is comprised of 6 Articles. Articles 1, 2, 5, 6 regulate typical issues of purpose and scope, grounds, effective date on which the Regulation shall enter into force, and the authority responsible for enforcing the Regulation, respectively. With 4 of its 6 Articles being typical boiler-plate provisions, the Regulation might seem insignificant at first glance, but this could not be further from the truth as the remaining 2 articles implement a practical ban on using crypto-assets for payments in Turkey.

Core Provisions

Article 3 and 4 of the Regulation read as follows:

“Article 3: Not Using Crypto-assets in Payments[1]

(1) For the purposes of this Regulation, crypto-assets (“kripto varlık” in Turkish) means intangible assets that are created virtually using the distributed ledger technology or a similar technology, distributed through digital networks, and not classified as fiat money, bank money[2], electronic money, payment instrument, security or capital market instrument.

(2) Crypto-assets cannot be used in payments either directly or indirectly.

(3) No service can be provided for direct or indirect use of crypto-assets in payments.

Article 4: Not Using Crypto-assets in the Provision of Payment Services and the Issuance of Electronic Money

(1) Payment service providers cannot develop business models involving direct or indirect use of crypto-assets for the provision of payment services and the issuance of electronic money, and cannot provide any services related to such business models.

(2) Payment institutions and electronic money institutions cannot act as an intermediary either for the platforms providing services of crypto-asset trading, storage, transfer, issuance or for the fund transfers made from these platforms.”

Definition of Crypto-assets

A) Distributed Ledger Technology



Osman Gazi Güçlütürk

Lawyer | IP&IT&Blockchain Law| PhD Candidate in Law & Computer Science| Self-taught Coder | LL.B. (Galatasaray) - LL.M. (LSE) - M.A. (Ankara) - MJur (Oxon)