Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
Bybit is not registered with MASAK (Financial Crimes Investigation Board) + CMB (Capital Markets Board) — but your funds are not lost. Swiss lawyers submit directly to Bybit's compliance team, bypassing standard support. 90%+ success rate.
Bybit is not licensed with CMB in Turkey; operates without local entity
CMB began licensing crypto exchanges in 2024; MASAK enforces AML compliance; Binance Turkey (Binfinity) was fined 8.2M TL (2022)
This matters because it determines which regulatory body has authority over your case — and whether you have a direct complaint path or need cross-jurisdictional legal action.
What this means for you: Bybit is not registered with MASAK (Financial Crimes Investigation Board) + CMB (Capital Markets Board), so direct regulatory complaints are limited. However, Bybit still operates under its home jurisdiction's AML laws (VARA Dubai ( provisional / operational license)). We submit legal documents directly to Bybit's compliance team — not through standard support channels.
Your funds are not illegal. Using an unregistered exchange in Turkey does not make your crypto holdings illegal under Turkish AML Law No. 5549 + CMB crypto regulation. You may face tax reporting obligations, but the funds themselves are yours.
under Law No. 5549, you can file a complaint with MASAK; also BDDK (banking regulator) if bank account frozen
Under Turkish AML Law No. 5549 + CMB crypto regulation (2024), Bybit must conduct customer due diligence and can freeze accounts during AML investigations. However, they must also:
If Bybit doesn't meet these obligations, we escalate to MASAK (Financial Crimes Investigation Board) + CMB (Capital Markets Board) and file a formal legal submission. For a broader comparison of how Turkey's rules stack up against other jurisdictions, see our AML laws by country reference.
no specific crypto tax (2024); treated as asset; potential income tax under Income Tax Law
If your Bybit account is frozen, you may still need to declare your crypto holdings on your Turkey tax return — even if you can't access them. Under Turkey law, the tax obligation may apply regardless of whether the funds are accessible. We recommend consulting a Turkish tax advisor.
If the freeze causes you to miss a tax deadline, we can provide documentation for the MASAK (Financial Crimes Investigation Board) + CMB (Capital Markets Board) and tax authority explaining the situation.
A Turkish user with a common Middle Eastern name had their Bybit account frozen after a sanctions screening match. Bybit's compliance tool (Chainalysis) flagged the name against OFAC lists. We prepared a non-association declaration and cross-referenced with MASAK (Financial Crimes Investigation Board) + CMB (Capital Markets Board)'s sanctions guidance. The account was restored after we provided a legal submission citing MASAK (Financial Crimes Investigation Board) + CMB (Capital Markets Board)'s guidelines and the client's transaction history.
Details anonymized to protect client confidentiality. Swiss professional secrecy applies.
We analyze your Bybit account, transaction history, and Turkey regulatory context to identify the exact trigger. Was it a Chainalysis risk flag? A sanctions screening match? A source-of-funds demand? Each requires a different strategy.
We prepare documentation compliant with Turkish AML Law No. 5549 + CMB crypto regulation — not just Bybit's standard templates. This includes source-of-funds proof, transaction tracing, and any required MASAK-specific forms.
We submit through Bybit's compliance channels — not standard support. Our submission is in Turkish and references MASAK guidelines. We coordinate with MASAK even though Bybit is not registered.
We verify everything works and advise on preventing recurrence on Bybit. If Bybit doesn't respond within no statutory maximum; MASAK investigations can take 3-6 months, we escalate to MASAK and pursue cross-jurisdictional action in Dubai, UAE (formerly British Virgin Islands) if needed.
Tell us what happened. A senior crypto compliance lawyer — not a chatbot, not a junior — will read your case and respond within 6 hours. Swiss professional secrecy applies from your first message.