Crypto Law- Suspicious Transaction Reporting Guide (Crypto Asset Service Providers) – Fin Tech

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The Financial Crimes Investigation Board of The Ministry of
Treasury and Finance (“MASAK“) published
The Suspicious Transaction Reporting Guide (“Guide”)
 on its official website on 18.04.2022. The Guide was
published after crypto asset service providers (“CASP”)
1were accepted as liable with
the relevant legal regulation2and aims to explain the
rules to which the obligor is subject in reporting a suspicious
transaction 3 within the body. Apart from the suspicious
transaction reporting obligation, crypto-asset service providers
are also subject to other commitments by the relevant legal

Still, the Guidelines do not include explanations regarding
these obligations:4

  1. Obligation to Know the Customer

  2. Obligation to Provide Information and Documentation

  3. Retention and Presentation Obligation

  4. Obligation to Provide Continuous Information

  5. Suspicious Transaction Reporting Obligation (the subject of
    this Guide)

The Guide explains the notification and shows the form, matter
and content. The Guide also describes suspicious transactions and
customers who make the suspicious transactions by examples. The
Obliged Parties shall report suspicious transactions to MASAK
within ten working days from suspicion regarding the transaction.
In cases where a delay is considered harmful, The Parties shall
oblige to report to MASAK immediately. Suppose new information and
findings are obtained later on regarding the notified transaction.
In that case, CASPs shall file the Suspicious Transaction Report
form (“STR“) again, and it is told
without delay, stating that it is in addition to the previous
notification.Suspicious transaction reporting to MASAK in CASPs is
carried out by the natural person obligor
herself/himself and by the legal
of the legal person obligee.



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