The “Declaration Requirement in Property Sales” Debate Has Been Clarified

The recently debated topic of a “declaration requirement in property sales” has now become clearer. As Space İstanbul—backed by more than 20 years of industry experience and nearly 40 professional consultants—we reviewed the details of the matter on your behalf.

What Was Included in the MASAK Draft Communiqué?

In 2025, a draft communiqué prepared by the Financial Crimes Investigation Board (MASAK) aimed to increase transparency in financial processes and transactions. The draft planned to introduce a requirement to provide an explanation regarding the source and purpose of:

• money transfers of TRY 200,000 and above, and

• bank transfers carried out via wire transfer/EFT mechanisms.

Although the draft was not designed exclusively for real estate, it was expected to affect the sector due to the high-value payments typically involved in property transactions.

The Provision on “Declaration Requirement” Was Suspended

The communiqué was expected to enter into force on 1 January 2026. However, it was suspended after it did not receive the anticipated approval for publication in the Official Gazette. The proposed regulation—closely relevant to millions—therefore did not proceed as planned.

As a result, the possibility of additional documentation requirements during payment stages of title deed (land registry) procedures has, for the time being, been taken off the agenda.

New Oversight Measures for Financial Transactions

Under the measures that are currently being implemented, banks no longer cancel transactions solely on the grounds that “no description/explanation was entered.” However, transactions with descriptions deemed meaningless, contradictory, or high-risk may be reviewed under MASAK-related compliance and monitoring processes. Depending on the risk assessment, such transactions may be:

• placed on hold,

• subject to requests for supporting documentation, and/or

• reported under a Suspicious Transaction Report (STR) mechanism.

Increased Importance of “Customer Profile Consistency”

In addition, the concept of profile consistency has gained significant importance. If a person’s income level, profession, transaction volume, and transaction frequency do not align—or if inconsistencies are detected—the system may automatically categorize the transaction as higher risk. These practices aim to create a more transparent and reliable environment within the financial system.

What Happens Next?

At this stage, it can be said that the draft communiqué has been removed from the agenda for now. At the same time, efforts to strengthen financial transparency and combat money laundering have accelerated in recent years. Within this framework, similar regulations may be revised and reintroduced in the future.

Space İstanbul: Luxury Real Estate Advisory Built on the Right Buyer, the Right Portfolio, and Transparency

As legislation and financial compliance become increasingly central in the real estate sector, access to accurate information and proper guidance is more valuable than ever. At Space İstanbul, luxury real estate advisory goes beyond simply listing portfolios; we build every sales and leasing process on the principles of transparency, precise matching, and trust.

Operating in Istanbul’s most distinguished locations, Space Luxury Real Estate continues to stand out through data-driven decision-making, accurate pricing strategies, and a client-focused approach that matches qualified living spaces with the right profiles.

For the latest developments in real estate, regulatory analysis, and selected portfolios, you can follow us at spaceistanbul.com.

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