Recent Development 

The Central Bank of Turkey amended the Capital Movements Circular (the “Amendment“).

What's New?

  • As explained in our Client Alert dated July 12, 2019, in case of an unidentified FX transfer from abroad worth USD 50,000 or more, Turkish account bank is required to obtain the account holder's written declaration, in addition to substantiating information and documents, to determine whether the unidentified FX transfer is in respect of the loans utilized by the account holder.
  • The Amendment emphasizes that the account bank is obliged to verify the nature of the transfer even if the account holder's statement is obtained.
  • The Amendment states that the term "credit" also includes the loans borrowed from the shareholders residing abroad.

Conclusion

The Amendment clarifies the scope of the due diligence of account banks for FX transfers.