The primary goal of this policy is to prevent the laundering of proceeds of crime and the financing of terrorism. Through this Policy, FINNOVA also aims to:
FINNOVA operates in accordance with and fully complies with the following regulations:
a) Money Laundering
Money laundering, as prohibited under the laws of the Republic of Türkiye, refers to the actions and processes whereby assets obtained from criminal activities are disguised as income originating from legitimate sources in order to conceal their illicit origin.
b) Terrorism Financing
Terrorism financing refers to the act of knowingly and willingly providing or collecting funds for a terrorist or terrorist organization with the intention that they be used to plan or carry out acts considered as terrorist activities under the law.
FINNOVA subjects every registered user to the highest level of control and screening. The platform implements best practice procedures for KYC compliance and fraud prevention to ensure that all user transactions are free from suspicious activity.
If a person applying for an account with FINNOVA raises suspicion, the relevant staff member may request additional information to address potential risks or concerns. FINNOVA reserves the right to reject any account application deemed risky or suspicious without providing any explanation to the applicant.
FINNOVA applies the standard KYC procedures as specified by MASAK and performs the following actions:
Users wishing to perform transactions as defined by the legislation under MASAK will be subjected to enhanced identification and verification procedures.
FINNOVA conducts a comprehensive risk-based assessment of individuals applying to become users, evaluating them in terms of potential money laundering and terrorism financing threats. Based on this evaluation, a risk profile is assigned to each user.
The following circumstances are also specifically considered by FINNOVA:
The Compliance Officer may elevate a user’s risk level if they believe that the risk rating assigned by the company’s scoring system does not reflect the actual risk posed by the user.
The FINNOVA Compliance Department periodically reviews the risk scoring system and classification model.
FINNOVA relies on the types of suspicious transactions defined by MASAK when identifying suspicious activity. Additionally, FINNOVA acknowledges that suspicious transactions beyond those specified by MASAK may also occur.
All FINNOVA employees are required to report any suspicious activity they detect on the platform — whether executed or attempted — by users to the Compliance Department without delay.
FINNOVA is obliged to provide any information, documents, data, and related environment records that may be requested within the scope of MASAK's anti-money laundering and counter-terrorism financing obligations, and to ensure access to such records and facilitate their delivery.
FINNOVA retains transaction-related documents from the date they are issued; ledgers and environment records from the last entry date; and identity verification documents and records from the date of the last transaction for a legally mandated period and provides them to the authorities upon request.
When a suspicious transaction and its corresponding user are identified, the information is shared solely with designated personnel in the Compliance Department and not disclosed to any other FINNOVA employee.
In the event that a suspicious transaction is referred to the judiciary, FINNOVA does not share any information with third parties other than courts and authorized public institutions.
The Compliance Officer is a designated FINNOVA employee responsible for ensuring compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. The Compliance Officer's duties at FINNOVA include the following:
FINNOVA is responsible for training its employees on the risks and obligations related to money laundering and terrorism financing, and for keeping their knowledge up to date.
The Compliance Officer or another AML/CTF expert must conduct these training sessions. Each relevant employee must confirm their participation in writing. It is recommended that training sessions be held at least once a year, or more frequently if necessary.
The training sessions are conducted under a comprehensive curriculum that includes the minimum topics required by law as well as cryptocurrency-specific practices.
FINNOVA employees’ knowledge levels are regularly assessed through periodic testing. Employees scoring below the defined threshold will be required to undergo additional training.
FINNOVA conducts regular audits using a risk-based approach. An independent audit firm prepares a report based on its findings.
The FINNOVA Compliance Department reviews these audit reports to assess any non-conformities related to regulatory requirements and implements corrective or preventive actions when necessary.