AML / KYC / KYT Policy

1. Scope and purpose

This policy covers every service offered by Money Transfer Turkey: cash currency exchange, crypto assets (USDT, BTC, ETH and others), bank transfers and digital wallet services. Its purpose is to verify customer identity, establish the legitimate origin of funds, and prevent money laundering and terrorist financing risks.

2. KYC (Know Your Customer) procedures

Identification documents and supporting evidence are requested for any transaction that reaches one of the following thresholds:

• Cash currency exchange: Single transaction above TRY 75,000
• Crypto transaction: Single transaction above the equivalent of USD 1,000
• Bank transfer / EFT: Single transaction above TRY 50,000
• Cumulative: Above TRY 150,000 in total within the same day

Documents requested: national ID card or passport, proof of address (utility bill, residence certificate) and, where required, proof of income together with a declaration of the purpose of the transaction.

3. KYT (transaction monitoring) and crypto compliance

All crypto transactions are screened under the FATF Travel Rule through source and beneficiary wallet analysis. The following addresses and transaction types are not accepted:

• Addresses on the OFAC / SDN lists, or addresses connected to them
• Funds received from mixer or tumbler services (Tornado Cash, Wasabi CoinJoin and similar)
• Funds originating from darknet marketplaces or other illicit platforms
• Transactions linked to sanctioned jurisdictions
• Addresses rated Severe or High risk in Chainalysis / TRM Labs screening

4. Restricted countries and customer categories

We do not transact with the following customers:

• Individuals and entities on OFAC sanctions lists
• Individuals resident in sanctioned jurisdictions (North Korea, Iran, Syria, Cuba, and the Crimea / Donetsk / Luhansk regions)
• Politically exposed persons (PEPs) — enhanced due diligence applies and the request may be declined
• Individuals under the age of 18
• Customers who cannot verify their identity or explain the source of their funds

5. Record keeping

A complete record of every customer transaction is retained for at least 5 years. Records include the transaction ID, date and time stamps, transaction direction, amounts, the payment details of both parties, IP address, browser information and KYC documents. This data is shared with third parties only upon a lawful request from a competent government authority.

6. Suspicious transaction reporting

Transactions assessed as suspicious are reported to MASAK (the Turkish Financial Crimes Investigation Board) under the applicable Turkish legislation. The customer is not informed that such a report has been filed (prohibition on tipping-off).

7. Customer responsibilities

By starting a transaction, the customer is deemed to have accepted this policy and undertakes to:

• Provide accurate identity and contact information
• Be able to explain the legitimate source of the funds
• Not act on behalf of a third party, unless expressly declared
• Not object to a transaction being halted where it is assessed as suspicious