Series045SectionCaratDate15 October 2026Reading time2 minutes
MASAK's Suspicious Transaction Guide for Hawala
MASAK has published a guide containing sector-specific risk indicators for hawala and similar value transfer systems that constitute unauthorised payment services.
What changed
On 11 September 2026, the Financial Crimes Investigation Board (Mali Suçları Araştırma Kurulu, MASAK) published the "Guide to Suspicious Transaction Reporting for Hawala and Similar Alternative Value Transfer Systems".
The Guide treats hawala as a payment activity carried out without a licence under Law No. 6493. Using examples, it explains how hawala is used in laundering, the financing of terrorism, the circumvention of sanctions and asset-freezing measures, the movement of illegal betting proceeds and unregistered activity.
There are separate risk indicators and suspicious transaction typologies for each group of obliged parties (yükümlü). Authorised institutions (yetkili müessese), carriers of money and valuables, and the precious metals, stones and jewellery sector are among these groups.
The Guide's main message: look at the chain, not at the single transaction. The customer, the company, the beneficial owner, bank accounts, crypto-asset wallets, foreign currency and precious metal movements, and links abroad should be assessed together.
Basis
MASAK announcement, 11 September 2026 · Law No. 5549 (suspicious transaction report, şüpheli işlem bildirimi) · Law No. 6493 · Turkish Criminal Code, Article 282 · Laws No. 6415, 7262 and 7258
Nature
The Guide is not a regulation or a communiqué (tebliğ); it does not introduce a new obligation. It shows how the existing reporting obligation is to be fulfilled. The presence of one of the indicators on its own does not mean that hawala activity is taking place.
Who is affected
Authorised institutions · jewellers and precious metal, stone and jewellery businesses · carriers of valuables · banks, payment institutions and electronic money institutions · crypto-asset service providers · lawyers, certified public accountants and sworn-in certified public accountants (SMMM/YMM) and notaries
What to do
Incorporate the indicators in the Guide for your sector into your customer acceptance and transaction monitoring procedure. Base the reporting decision not on a single indicator but on the whole picture of which the transaction forms part.
Legislation changes; so does this article. This article was prepared on the basis of the legislation in force on the date of its publication. Amounts, rates, thresholds and time limits marked with are subject to change. Do not carry out any transaction on the basis of this article.
This is an English translation provided for information. In case of any discrepancy, the Turkish text prevails.
Last updated: 5 November 2026
Data controller
The data controller with respect to the personal data processed on this website is Muhammed Abdullah Türkkan, Attorney at Law.
Address: Kuştepe Mah. Mecidiyeköy Yolu Cad. No: 12 Kat: 28 Daire: 05, Şişli / İstanbul 34387 · Email: selam@turkkanlawfirm.com
This notice has been prepared pursuant to Article 10 of Law No. 6698 on the Protection of Personal Data (6698 sayılı Kişisel Verilerin Korunması Kanunu) and covers only the operations carried out through this website.
What data we process and why
Communication by email. When you write to us, the information contained in the message you send — your name, your email address and what you write. It is used to assess and respond to your request. Its legal basis is the establishment and exercise of a right, and our legitimate interest.
Technical records. The IP address, browser and visit information generated on our server when you access the site. They are kept to ensure the security and proper functioning of the site. Visit measurement (only with your consent). If you consent to Google Analytics cookies, the pages you visit, where you came to the site from, the length of your visit, your approximate location (country, city), device and browser information, the terms you type in the site search, clicks on contact links and online identifiers are processed. The purpose is to measure how the site is used and to improve it. The legal basis is your explicit consent (Article 5(1) of the Law); you can withdraw your consent at any time. Details are in the Cookie Policy.
There are no forms on this site — neither a contact form nor a newsletter subscription. No data is collected through forms.
Who we share your data with
Your personal data is not sold and is not transferred to third parties for marketing purposes.
We use three service providers for the operation of the site, our corporate email and visit measurement. They access your data only to the extent that the service requires:
Service
Provider
Data accessed
Website hosting
Hostinger
Technical records: IP address, browser and visit information
Corporate email
Google (Google Workspace)
The content of the message you write to us, your name and your email address
Visit measurement (only with your consent)
Google (Google Analytics)
Pages visited, source of visit, device and browser information, online identifiers
In addition, data may be shared, to the extent provided for by the legislation, upon a duly made request by public authorities authorised by law.
Cross-border transfer
The servers of all three providers above are outside Türkiye (the server hosting the site is in France). As a result, the site's technical records, email correspondence and, if you have consented, visit measurement data are processed abroad:
Provider
Data transferred abroad
Hostinger — website hosting
IP address, browser and visit information
Google Workspace — corporate email
The content of email correspondence
Google Analytics — visit measurement (only with your consent)
Visit and device information, online identifiers
The data transferred is limited to the minimum necessary for the service to be provided; the site and email cannot operate otherwise. These providers do not use the data for their own purposes.
Legal status of the cross-border transfer. Work is under way to make the above transfers subject to appropriate safeguards under Article 9 of Law No. 6698. When standard contracts are concluded, this notice will be updated and the date of conclusion will be stated here.
The fonts used on the site are also served from our own server, and when you open a page your browser connects to no address other than turkkanlawfirm.com unless you have consented to Google Analytics.
How long we keep data
Email correspondence: the minimum period prescribed by the relevant legislation; where the legislation prescribes no period, three years from the end of the process.
Technical records: the minimum period prescribed by the relevant legislation; where the legislation prescribes no period, three years.
Visit measurement data:14 months in Google Analytics; the cookies remain in your browser for no more than 13 months.
Where the legislation prescribes a longer retention period, that period applies. When the period expires, the data is erased, destroyed or anonymised.
Your rights
Pursuant to Article 11 of Law No. 6698, by applying to us, you have the right to:
learn whether your personal data has been processed,
request information about it if it has been processed,
learn the purpose of the processing and whether the data is used in accordance with that purpose,
know the third parties in Türkiye or abroad to whom the data has been transferred,
request rectification if the data has been processed incompletely or inaccurately,
request its erasure or destruction,
request that the rectification, erasure and destruction be notified to the third parties to whom the data has been transferred,
object to a result to your detriment arising from the analysis of the data exclusively by automated systems,
request compensation for damage if you suffer damage as a result of unlawful processing.
How to apply
You may send your requests to selam@turkkanlawfirm.com or to the postal address above. In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller (Veri Sorumlusuna Başvuru Usul ve Esasları Hakkında Tebliğ), you may make your application in writing, or by registered electronic mail, secure electronic signature, mobile signature or the email address you have previously notified to us.
Your application will be concluded within thirty days at the latest. If you do not find our response satisfactory, you may lodge a complaint with the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).
This is an English translation provided for information. In case of any discrepancy, the Turkish text prevails.
Last updated: 5 November 2026
What this policy is about
This policy explains how your information is processed when you visit the turkkanlawfirm.com website.
The case-file information of persons who have granted a power of attorney to our office falls outside the scope of this policy. Client information is subject to the duty of confidentiality under Article 36 of the Attorneys' Act (Avukatlık Kanunu) and is not processed through the website.
What information we collect
Information you provide yourself. If you email us, the information contained in your message.
Information collected automatically. The IP address, browser and operating system information, date of visit and pages viewed that are generated in the server logs when you access the site. If you consent to Google Analytics cookies, the pages you visit, where you came to the site from, the length of your visit, your approximate location, device information, the terms you type in the site search and clicks on contact links are also measured.
There are no forms on this site — neither a contact form nor a newsletter subscription. No data is collected through forms.
Why we collect it
To assess and respond to your request, if you have written to us
To ensure the security of the site and to fix technical faults
Your data is not sold and is not transferred to third parties for marketing purposes.
Cookies
Google Analytics cookies are used on this site only with your explicit consent; the cookies and consent management are described in a separate document: Cookie Policy.
Which addresses your browser connects to
When you visit the site, your browser connects to turkkanlawfirm.com. Fonts, images and scripts are served from our own server. Only if you consent to Google Analytics does your browser also connect to Google's measurement addresses; if you do not consent, no such connection is made.
The social media and map links on the page work only if you click them.
Service providers we use
We use external services for the operation of the site. These do not come into play when you open a page; they play a role at the stage of storing and transmitting data, and they access your data only to the extent that the service requires.
Service
Provider
Server location
Website hosting
Hostinger
Abroad (France)
Corporate email
Google (Google Workspace)
Outside Türkiye
Visit measurement (only with your consent)
Google (Google Analytics)
Outside Türkiye
Because the servers are located abroad, personal data are transferred abroad: technical records on the hosting side, the content of correspondence on the email side and, if you have consented, visit and device information on the measurement side. The data transferred are limited to the minimum needed to provide the service.
Work is under way to make these transfers subject to appropriate safeguards under Article 9 of Law No. 6698 on the Protection of Personal Data (6698 sayılı Kanun). When standard contracts are concluded, this policy will be updated and the date of conclusion will be stated. Details are in the Privacy Notice (aydınlatma metni).
Retention periods and your rights
Your data is kept for the minimum period prescribed by the relevant legislation; where the legislation prescribes no period, it is kept for three years. When the period expires, it is erased, destroyed or anonymised.
Your rights under Article 11 of Law No. 6698 and the application procedure are set out in the Privacy Notice on the Protection of Personal Data.
External links
Our site may contain links to other websites. We are not responsible for the content or privacy practices of those sites.
Changes
This policy may be updated. The current version is always published on this page, and the "Last updated" date above is changed.
Contact
selam@turkkanlawfirm.com · Kuştepe Mah. Mecidiyeköy Yolu Cad. No: 12 K: 28 D: 05 · Şişli / İstanbul 34387
This is an English translation provided for information. In case of any discrepancy, the Turkish text prevails.
Last updated: 5 November 2026
What is a cookie
A cookie is a small text file that the websites you visit place in your browser. It enables a site to remember you and retain your preferences.
Cookies used on this site
Only Google Analytics cookies are used on this site. These cookies are not essential and are not set without your explicit consent. They are used to measure which pages of the site are viewed, where visitors come from and for how long, which terms are searched for in the site search and whether contact links (telephone, email, WhatsApp) are clicked, and to improve the site on the basis of those measurements. They are not used for advertising, remarketing or cross-site tracking.
Cookie
Provider
Purpose
Time limit
_ga
Google
To distinguish a visitor from their previous visits
13 months
_ga_…
Google
To keep visit (session) information
13 months
In Google Analytics, Google signals, ad personalisation and data sharing are switched off. Measurement data are kept for 14 months.
Unless you give consent, your browser connects only to turkkanlawfirm.com; all elements of the page, including fonts, are served from our own server.
Consent and your preferences
When you open the site, a short notice appears at the bottom of the page: Accept or Reject.
If you accept, your choice is stored in your browser for 12 months, and the notice is not shown again during that period.
If you reject, no Google Analytics cookie is set; the notice is shown again on your next visit.
Your choice is kept not in a cookie but in the local storage your browser sets aside for this site, and it applies only to that device and browser.
Separately, as with every website, our server keeps technical access logs: IP address, browser information and time of visit. These are kept for the security and proper functioning of the site and are not used for analysis at the level of individuals. Details are in the Privacy Notice on the Protection of Personal Data.
Your browser settings
You can delete or block cookies in your browser settings at any time. Blocking Google Analytics cookies does not affect how the site works.
Cross-border transfer
Google Analytics data are processed on Google's servers outside Türkiye. Details are in the Privacy Notice on the Protection of Personal Data.
Contact
selam@turkkanlawfirm.com
This is an English translation provided for information. In case of any discrepancy, the Turkish text prevails.
Last updated: 5 November 2026
At Türkkan Law Firm, we believe that the reflection in the digital world of the principle of "justice for all", which lies at the foundation of law, is "access for all". With this belief, we are committed to making our website a resource that all users, whatever their abilities and needs, can navigate and understand with ease.
Our website aims to meet the Level AA success criteria of the internationally recognised Web Content Accessibility Guidelines (WCAG) 2.2. In the design and technical infrastructure, basic principles such as compatibility with screen readers, keyboard navigation and sufficient colour contrast have been observed.
For us, this is not a destination but an ongoing journey. If you encounter an accessibility problem or have a suggestion that would improve the experience, you can contact us at selam@turkkanlawfirm.com.
Testing and known gaps
Our site is checked automatically each time it is prepared for publication; the heading structure, the naming of links, in-page link targets and keyboard usability are within the scope of this check. The target size and focus visibility criteria introduced in WCAG 2.2 have been measured in the browser. Colour contrast is also assessed separately in the browser by measuring the actual backgrounds of the text.
As of today, these tests show no unresolved gaps.
Points that cannot be measured by script and continue to be assessed manually:
End-to-end testing with screen readers on real devices
The size of touch targets on real devices
Last reviewed: 5 November 2026
This is an English translation provided for information. In case of any discrepancy, the Turkish text prevails.
Last updated: 4 September 2026
1. General Information
This website (the "Site") has been prepared by Türkkan Law Firm (the "Firm") in accordance with the Professional Rules of the Union of Turkish Bar Associations and the relevant legislation, in particular the Regulation on the Advertising Ban (Reklam Yasağı Yönetmeliği). All information, images and other materials on the Site have been created solely for general information purposes.
2. Not Legal Advice
The information provided on the Site does not constitute legal advice, counsel, an opinion or guidance. Visitors are advised to obtain professional advice from a qualified lawyer before acting on this information. The Firm cannot be held liable for any damage that may arise from actions taken in reliance on the information on the Site.
3. No Attorney-Client Relationship
Visiting the Site, using the information on the Site or contacting the Firm through its communication channels does not establish an attorney-client relationship between the user and the Firm. Such a relationship can be established only after a legal services contract (avukatlık sözleşmesi) containing the express declarations of intent of the parties has been signed.
4. Currency and Accuracy of Information
Although the utmost care is taken to keep the information and references to legislation up to date, owing to the dynamic nature of the law the information may reflect the position at the date of publication and may subsequently cease to be valid. The Firm gives no warranty that the information on the Site is complete, accurate and up to date.
5. Intellectual Property Rights
All texts, logos, images and other intellectual works on the Site belong to Türkkan Law Firm. Copying, reproducing or using these materials without the Firm's written permission is prohibited.
