For payment, e-money and crypto-asset institutions, an effective AML/CFT (anti-money-laundering and counter-terrorist-financing) compliance program is not merely a legal obligation — it is the foundation for protecting both the operating licence and the institution's reputation. In Turkey this area is shaped by Law No. 5549 and the regulations of the Financial Crimes Investigation Board (MASAK), while the international framework is set by the FATF recommendations.
1. Enterprise Risk Assessment
The foundation of the program is an institution-specific risk assessment. Risks are identified and rated across customer types, products and services, delivery channels, geographies and transaction types. A risk-based approach ensures resources are directed to the highest-risk areas.
2. Policies and Procedures
Written policies and procedures are built from the risk assessment: customer acceptance policy, identification and verification, suspicious-transaction detection, record keeping and reporting processes. These documents must not remain at a template level; they must reflect the institution's real workflow.
3. Compliance Officer and Governance
A compliance officer with sufficient authority and independence is appointed. Direct reporting of the compliance function to senior management, board oversight and appropriate resource allocation are critical.
4. Know Your Customer (KYC/CDD)
Customer due diligence covers identity verification, determining the beneficial owner, understanding the purpose of the business relationship and applying simplified or enhanced due diligence according to the risk rating. High-risk customers and politically exposed persons (PEPs) require additional controls.
5. Monitoring and Suspicious-Transaction Reporting
Continuous transaction monitoring, detection of unusual patterns and timely filing of suspicious-transaction reports (STRs) with MASAK where necessary form the heart of the program. Automated monitoring scenarios must be calibrated to the institution's risk profile.
6. Training and Awareness
Regular training of all relevant staff is essential to spread a culture of compliance across the organisation. Training should be role-specific and include current typologies.
7. Internal Audit and Independent Review
The effectiveness of the program is tested through regular internal audit and independent review. Findings are reported to senior management and the improvement loop is closed.
A Practical Note for Fintechs
In fast-growing fintechs, compliance often lags behind product development. Yet integrating compliance into product design from the outset (compliance-by-design) both reduces supervisory risk and eases scaling. A well-structured program is not an obstacle to growth but the infrastructure for safe growth.
How FinWise Consulting Helps
We provide end-to-end support in designing AML/CFT compliance programs aligned with MASAK and FATF standards — drafting policies and procedures, risk assessment, building monitoring scenarios, and establishing training and internal-audit mechanisms.
