Financial Crime World

Customer Identification and Verification Requirements for Financial Institutions

In accordance with regulations aimed at preventing money laundering and terrorist financing, financial institutions in Turkey must implement strict customer identification and verification procedures.

Identification of Authorized Representatives


Financial institutions are required to identify and verify the authorized representatives of legal persons or unincorporated organizations. This is done by obtaining documents such as power of attorney or circular of signature, which contain information specified in identity documents and are notarized.

  • Examples of acceptable documents:
    • Power of attorney
    • Circular of signature
    • Notarized copies of identity documents

Verification of Authorization


The authorization of persons given authority by authorized representatives must be verified through notarized proxy or written instruction from the authorized representative. The signatures on the written instruction must be verified through their signatures on the notarized circular of signature.

  • Steps to verify authorization:
    1. Obtain a notarized proxy or written instruction from the authorized representative.
    2. Verify the signatures on the written instruction through the notarized circular of signature.

Identification of Natural Persons


In cases where transactions are made by another person on behalf of a natural person, customer identification is carried out in accordance with measures related to natural persons. Authorization of the acting person must also be verified through a notarized power of attorney.

  • Examples of acceptable documents:
    • Notarized power of attorney
    • Identity documents (e.g., passport, ID card)

When transactions are carried out on behalf of minors or persons under legal disability by their legal representatives, such as guardians appointed by court decision, curators, or trustees, the authority of those representatives must be verified through an original or notarized copy of the relevant court decision.

  • Examples of acceptable documents:
    • Original or notarized copy of court decision appointing a guardian
    • Identity documents (e.g., passport, ID card)

Recording Customer Information


Financial institutions must record customer information in a legible format and make it available upon request from authorities.

  • Requirements for recording customer information:
    1. Legible format
    2. Availability upon request from authorities

Customer Identification for Wire Transfers


For wire transfers exceeding 2,000 Turkish Lira (TL) or equivalent to $1,092 USD, financial institutions must collect the following originator information:

  • Name and surname
  • Title of the legal person registered to trade registry
  • Full name of other legal persons and unincorporated organizations
  • Account number or reference number of the transaction
  • Address or place and date of birth
  • At least one of the numbers such as customer number, TR-ID number, passport number, or tax ID number

Transactions Exceeding 20,000 TL Threshold


Financial institutions must conduct Customer Due Diligence (CDD) and collect and verify information appropriate to the profile of the customer when the amount of a single transaction or total amount of multiple linked transactions exceeds 20,000 TL.

  • Requirements for CDD:
    1. Conducting due diligence on the customer
    2. Collecting and verifying information relevant to the customer’s profile

Obligation of Controlling Document Authenticity


Financial institutions are required to verify the authenticity of documents as much as possible by applying to the person or institution arranging the document or to other competent authorities in cases where they suspect the authenticity of documents used for verification purposes.

  • Steps to verify document authenticity:
    1. Apply to the person or institution arranging the document
    2. Apply to other competent authorities

Reliance on Third Parties


Financial institutions can establish business relationships or carry out transactions by relying on measures taken by another financial institution related to customer identification, record keeping, and CDD. However, ultimate responsibility remains with the financial institution carrying out the transaction. Reliance on third parties is subject to conditions that ensure they are compliant with international standards for combating money laundering and terrorist financing.

  • Conditions for reliance on third parties:
    1. Compliance with international standards
    2. Ultimate responsibility with the financial institution