MASAK compliance: obligations, reporting, and suspicion categories
MASAK publishes separate suspicious transaction report guides for each obliged party group under Law No. 5549. These guides define not only which transactions are suspicious, but also the required reporting fields and suspicion categories. TruvaLI unifies rule building, case management, and report drafting in a single architecture. Deployment is available in the cloud, private cloud, or on-premise.
MASAK obligations represent the responsibility of institutions deemed obliged parties under Law No. 5549 on Prevention of Laundering Proceeds of Crime to apply KYC, monitor transactions, and file suspicious transaction reports. MASAK publishes a separate suspicious transaction report guide for each of these institutional groups, listing sector-specific indicators one by one.
Who is an obliged party and what is expected?
Law No. 5549 on Prevention of Laundering Proceeds of Crime designates a wide range of institutions as obliged parties. MASAK publishes a separate suspicious transaction report guide for each of these groups, defining not only what makes a transaction suspicious, but also how the reporting must be executed.
| Obliged party group | Guide version |
|---|---|
| Banks and PTT | 2.0 |
| Payment institutions and electronic money institutions | 2.0 |
| Crypto asset service providers | 2.0 |
| Operators in the field of games of chance and betting | 1.0 |
| Electronic commerce intermediary service providers | 1.0 |
| Dealers in precious metals, stones, or jewelry | 2.0 |
| Real estate traders for commercial purposes | 2.0 |
| Investment trusts | 1.0 |
| Insurance and reinsurance brokers | 1.0 |
Each guide considers the transaction structure of the respective sector, explaining sector-specific risk areas, typologies, and suspicious transaction indicators with concrete examples. The guide for banks lists 173 indicators, the crypto guide lists 160, and the payment and electronic money guide lists 142.
Are the guides a ceiling or a floor?
The common warning across all guides is this: obliged parties must not limit themselves to the listed typologies, and must file a report even if a suspicious transaction does not match any of the specified types.
This has a direct implication for the monitoring architecture: simply implementing the types in the guides as rules is not enough. The institution must be able to write its own scenarios based on its risk policy, and do so without requiring a software development project.
How are reports submitted?
Application procedures and all submissions for suspicious transaction reports are carried out electronically through the MASAK.Online system. The guides emphasize that this is crucial for standardization, reporting quality, and the efficiency of analysis processes.
Why is the form a system requirement?
The reporting form is divided into sections: obliged party details, report details, natural person details, legal entity details, suspicious transaction details, account details, suspicion category, and description. The fields to be included in each section are strictly defined.
Three rules demand concrete capabilities from the monitoring software:
Non-monetary events are also reported. Matters that do not involve monetary value, such as suspicious account openings and closures, safe deposit box visits, or power of attorney and guarantee transactions, are written in the description section of the form, leaving the suspicious transaction section blank. This means the case must be capable of carrying non-monetary events.
A single report can cover a date range. If the suspicion is based on multiple transactions over a specific date range rather than a single transaction, the total amount and the date range are reported together as a multi-transaction event.
Channel and type distinctions are preserved. If suspicious transactions are concentrated across different channels, branches, or types, the form section can be repeated separately for each cluster.
38 suspicion categories
When filing a report, the suspicion is mapped to one of the categories in MASAK's reference table, and each category is matched with its corresponding legal regulation. For instance, usury and POS usury are linked to Article 241 of Law No. 5237, while encouraging or facilitating prostitution is linked to Article 227.
The list ranges from usury to migrant smuggling, customs smuggling to cybercrimes, tax evasion to fraudulent bankruptcy, illegal betting to violating asset-freezing decisions, and financing the proliferation of weapons of mass destruction.
This means case management must operate with this taxonomy rather than arbitrary custom tags. Category selection is an integral part of the report itself, not a retrospective reporting preference.
What is the threshold for reports with suspension requests?
The regulation prepared based on Article 19/A of Law No. 5549, titled "Suspension of transactions", governs the suspension of transactions based on a report. The guides set a clear threshold for this: there must be documents or serious indications supporting the suspicion, going beyond mere suspicion, that the assets subject to the transaction are related to money laundering or terrorist financing, and the report must be submitted along with its justifications.
This threshold is a direct system requirement: evidence must be attached to the case, the justification must be documented in writing, and the identity of the decision-maker must be recorded. A free-text note on an alert screen does not satisfy this threshold.
How TruvaLI meets these requirements
Rule building, so institutions can write their own scenarios
The rule engine supports nested logic, flexible aggregation windows, and callbacks from rules. While the types in the guides are converted into rules, the core capability is allowing the institution to write its own scenarios that are not in the guides. A rule can be described in plain language using a prompt to generate a draft for approval, requiring no coding.
Before deploying a new rule to production, you can test it on historical traffic using rule simulation to see the alert volume it would generate. You can also specify a past date and view the results on that day's traffic.
Non-monetary events as first-class citizens
The event model distinguishes between financial and non-financial events. Events without a monetary value, such as account openings, sessions, device changes, and document uploads, are also processed by rules and linked to the case. This ensures that details to be written in the description section of the form are properly recorded.
Cases, evidence, and categories
An alert is transformed into a case with an owner, a SLA, and evidence. Decisions and evidence are attached to the case, and the suspicion category is selected from MASAK's taxonomy. Information on who made the decision, with what authority, using which data, and when, is written to an immutable audit trail.
The approval workflow is not limited to a simple second signature: approval policies, multi-signature decisions, and delegation of authority can be defined, with the delegation itself recorded alongside its supporting documentation.
Report drafting
The report draft is prepared from the same case data: the date range, total amount, channel, and type distinctions are pulled directly from the case. The signing authority remains with the institution.
Sector-specific solutions are on separate pages: banking, payment institutions, e-money institutions, gaming and betting, crypto and VASPs, insurance, securities. The reporting workflow is on the regulatory reporting page, and the rule side is on the rule and scenario engine page.
Source
MASAK sectoral suspicious transaction report guides and Law No. 5549 on Prevention of Laundering Proceeds of Crime.
This page does not constitute legal interpretation; it conveys the procedures contained in the guides. Rules, thresholds, and actions are configured according to the institution's own risk policy and obligations.
Common questions
- Are we required to write all the types in the guide as rules?
- The guides state the opposite: obliged parties must not limit themselves to the listed types, and must file a report even if a suspicious transaction does not match any of them. The types represent a minimum common ground, not a ceiling.
- Can an event without a monetary value be subject to a report?
- Yes. Matters such as suspicious account openings and closures, safe deposit box visits, or power of attorney and guarantee transactions are written in the description section of the form. The case must be capable of carrying these types of events.
- Why is the suspicion category important?
- When filing a report, the suspicion is mapped to one of the 38 categories in MASAK's reference table, and each category is matched with a legal regulation. Case management must operate with this taxonomy rather than arbitrary custom tags.
- What is required for a report with a suspension request?
- The guides set a clear threshold: there must be documents or serious indications supporting the suspicion, going beyond mere suspicion, and the report must be submitted with its justifications. This requires evidence to be attached to the case and the identity of the decision-maker to be recorded.
- Who is a MASAK obliged party?
- Law No. 5549 designates a wide range of institutions as obliged parties: banks, payment and electronic money institutions, capital markets institutions, insurance companies, crypto asset service providers, and operators in the field of games of chance are among them.
- Are sectoral guides binding?
- The guides list sector-specific indicators and establish a floor. If a pattern not listed in the guide raises suspicion, the obligation to report still applies.
- How are reports submitted?
- Application procedures and all submissions for suspicious transaction reports are carried out electronically through the MASAK.Online system.
- Can we write rules specific to our own sector?
- Yes, you can. A rule can be described in your own words to generate a draft, tested on historical traffic before going live, and put into effect upon approval.