Under Article 4/3 of the Communiqué, platforms must execute the crypto asset withdrawals they intermediate, including transfers to other platforms, no earlier than 48 hours after the purchase, exchange or deposit of the crypto asset to be transferred; for a customer's first crypto asset withdrawal, that period is at least 72 hours.

Read in isolation, the provision gives the impression of a general waiting period on crypto assets leaving a Turkish platform. That is not the case. The paragraph is expressly limited to withdrawals falling "within the scope of the sixth and seventh paragraphs of Article 24/A of the Measures Regulation". Everything noteworthy about the provision follows from that limitation.

Article 24/A of the Regulation on Measures Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism No. 2007/13012 (the "Measures Regulation") is the Turkish counterpart, for crypto asset transfers, of the travel rule set out in FATF Recommendation 16 and extended to virtual assets through the Interpretive Note to Recommendation 15. The first paragraph of Article 24/A requires that transfers of 15,000 Turkish Lira and above intermediated by crypto asset service providers include specified originator information in the transfer message, and that the accuracy of that information be verified. The second paragraph provides a lighter regime for transfers below that amount, under which verification is not mandatory. The sixth and seventh paragraphs govern two situations in which that architecture does not operate.

The sixth paragraph concerns transfers sent to, or received from, a wallet address not registered with any crypto asset service provider. Since there is no institution on the other side to share data, the obligation is discharged through a declaration obtained from the customer.

The seventh paragraph covers transfers carried out with a crypto asset service provider, or a financial institution authorized to transfer crypto assets, that is established abroad and is under no obligation under its own legislation to share originator and beneficiary information. Here too, the gap is filled by customer declaration.

Article 4/3 of the Communiqué therefore does not impose a general withdrawal delay. What it imposes is a delay specific to transfers that leave the traceability perimeter: Transfers towards self-custody, or towards a foreign platform that cannot report back. A transfer from one licensed Turkish platform to another, with travel rule information complete, remains within the first or second paragraph of Article 24/A and is subject to no waiting period at all.

On that basis, the phrase "including transfers to other platforms" in the paragraph should be read not as extending the rule to all inter-platform transfers, but as confirming that the rule cannot be avoided by routing through a platform that itself falls within the sixth or seventh paragraph. MASAK's own Guide on Enhanced Measures of September 2025 reads the provision the same way: It ties the waiting period to withdrawals within the scope of transfers carried out with unregistered wallet addresses or with foreign service providers under no information-sharing obligation, restating the scope limitation by spelling out its content rather than by citing the paragraph numbers.

The absence of a monetary threshold is the feature of the regime most likely to be overlooked, and the one with more significant consequences than the length of the period itself.

The first and second paragraphs of Article 24/A are tied to a 15,000 Turkish Lira threshold. The sixth and seventh paragraphs contain no monetary threshold at all. Transfers to unregistered wallet addresses and to foreign service providers under no information-sharing obligation fall within those paragraphs regardless of amount.

The consequence follows necessarily: Article 4/3 of the Communiqué also applies irrespective of amount. A customer moving a small balance to a cold wallet and a customer withdrawing a position of substantial size are subject to the same wait. The rule is structured by reference to the transparency of the counterparty, not to the amount.

First, the provision works against the principle of self-custody in capital markets legislation. The sixth paragraph of Article 35/C of the Capital Markets Law No. 6362 and, repeating it, the first paragraph of Article 24 of Communiqué III-35/B.2 adopt as the default position that crypto assets belonging to platform customers are to be held in the customers' own wallets. Article 4/3 of the Communiqué sets a time restriction against that choice, and does so irrespective of amount. Capital markets legislation adopts self-custody as the default; anti-money laundering legislation makes reaching it slower than every other option.

Second, the Communiqué rests on Article 26/A of the Measures Regulation and on Article 13 of the Regulation on the Compliance Program Regarding Obligations of Anti-Money Laundering and Combating the Financing of Terrorism (the "Compliance Regulation"). The first paragraph of Article 26/A provides that enhanced measures are to be applied, in transactions within the scope of Articles 18, 20 and 25 and in high-risk situations identified under a risk-based approach, "in proportion to the risk identified". The measures listed in that paragraph are individualized by nature: Obtaining additional information, making the transaction subject to senior management approval, intensifying monitoring. Article 13 of the Compliance Regulation is two-layered: Its first paragraph ties additional measures to groups identified as high-risk following a risk rating, while its second paragraph, added on 25 December 2024, requires crypto asset service providers to apply specified measures as a minimum in their customer relationships and to set limits on amounts and transaction counts, without any risk rating being required. The measures that paragraph mandates categorically, however, consist of the enumerated items and of amount and transaction-count limits; a time restriction is not among them. The second paragraph of Article 26/A, in turn, authorizes the Ministry to determine the high-risk situations to be taken into account and to prescribe enhanced measures beyond those listed.

Against this, Article 4/3 of the Communiqué is a uniform and categorical restriction applied to an entire category of transactions, independently of amount, customer profile or any concrete risk assessment. Of the Communiqué's two legal bases, only Article 26/A is broad enough to serve as the source of such a measure, and that article carries the proportionality-to-risk criterion. Whether a measure of this nature can count as an "enhanced measure" within a risk-based delegation, or is by nature a regulatory instrument of a different kind, is not a question the text resolves.

Third, the allocation of price risk. The assets subject to the waiting period belong to the customer; the platform merely holds them. In a market that trades without interruption, for the mandatory 48 or 72 hours the customer bears the entire market risk of a transfer it has already instructed.

The first paragraph of Article 35/C of the Capital Markets Law No. 6362 renders void any contractual term that eliminates or limits a service provider's liability towards its customers; the sixth paragraph of Article 22 of Communiqué III-35/B.1 repeats the same prohibition for framework agreements. At the same time, the fourth paragraph of Article 99/B of the same Law excludes from the scope of liability losses arising from a temporary inability to execute transfers where the service provider is not at fault. As matters stand, this is not a regulatory gap but a silent allocation: The market risk arising during the mandatory waiting period remains with the customer.

Article 4/3 of the Communiqué is narrower than its public reception suggests. It is a time restriction, with no monetary threshold, applied to transfers that leave the travel rule's information perimeter, principally transfers towards self-custody.

That the provision is narrow does not mean it is uncontroversial. Because the measure is calibrated by reference to the transparency of the counterparty rather than to amount, it bears most heavily on precisely the transfers towards self-custody that capital markets legislation adopts as the default. Capital markets legislation and anti-money laundering legislation pulling the same conduct in opposite directions is not a problem that either framework's internal consistency can resolve.

Likewise, whether a categorical time restriction can count as an enhanced measure under a risk-based delegation, and how the liability regime for market risk arising during the mandatory waiting period is to be constructed, are questions the wording of the provision does not answer.