Compliance officer is now a licensed profession

What changed

To become a compliance officer, an examination, a licence and registration are now required.

The Regulation amendment of 25 December 2024 introduced, for compliance officers and exclusive compliance officers, the requirement of "being registered in the compliance officer register". The procedures and principles were then set by General Communiqué (tebliğ) No. 30 of the Financial Crimes Investigation Board (Mali Suçları Araştırma Kurulu, MASAK) of 9 September 2025.

This is how it works:

• The examination is multiple choice, in one or more modules. The pass mark is 65; in a modular examination it is the average, provided that at least 50 is scored in each module.
• Eligibility: Turkish citizenship, not being deprived of public rights, not having been convicted of the listed offences, and at least four years of higher education.
• Successful candidates obtain the Compliance Officer Licence by online application and are entered in the register.
• Licence holders must attend renewal training every three years; attendance of at least 90% of the training is required.
• The licence of anyone who does not renew is suspended, and that person may not work as a compliance officer.
• If the requirements are lost, or in the event of conduct "contrary to the honesty and reputation required by the profession", the licence is revoked and the person is removed from the register.

A licence without examination is granted only to a narrow group: those who have actually worked for four years as administrators at MASAK, or for twelve years as Treasury and Finance Experts or as audit staff.

The licence is not the only requirement for being a compliance officer; the qualifications in Article 17 of the Compliance Regulation are also required.

Basis

Compliance Regulation, Articles 17 and 32/B (Official Gazette of 16 September 2008, No. 26999; Article 32/B added and Article 17 amended: Official Gazette of 25 December 2024, No. 32763) · MASAK General Communiqué No. 30 (Official Gazette of 9 September 2025, No. 33012)

Entry into force

The registration requirement applies from 25 December 2024, and the examination and licensing procedure from 9 September 2025. The three-year renewal period runs from the end date of the examination or of the last renewal training.

Who is affected

Precious metals intermediary institutions (kıymetli madenler aracı kuruluşu) · authorised institutions (yetkili müessese) · all financial institutions obliged to establish a compliance programme · those working as compliance officers and deputy compliance officers

What to do

Check the status of the licence and register entry of the compliance officer working for you. A person whose licence has been suspended may not work in this role; this is notified to the obliged party (yükümlü) in writing or by electronic notification.

If the compliance officer leaves, a new appointment must be made within thirty days. An acting appointment is possible but may not exceed sixty days in a calendar year.

A brief assessment. This rule turns the compliance officer role from an internal company function into a status licensed by the state. The result is this: the obliged party can no longer choose its compliance officer solely by its own criteria; the person's licence and registration are required, and if they are lost, the appointment lapses automatically. For the sector, the practical meaning is a narrowing supply of qualified compliance officers. For intermediary institutions and authorised institutions, this is as much a human resources issue as a compliance (uyum) issue.

Related page: Regulation, Compliance and Special Projects