The activities of a firm outside Türkiye relating to a client or counterparty located in Türkiye might be subject to Turkish law. A service provider located abroad needs to consider whether it is triggering a Turkish licensing obligation and complying with Turkish marketing rules.

Foreign financial service providers must take no action that would create an impression that they are providing financial services in Türkiye. However, they can respond to reverse inquiries where the Turkish resident customer has initiated the relationship. Foreign financial service providers must avoid any promotion, distribution, marketing or other solicitation of their services and products in Türkiye that may be subject to licensing in Türkiye.

There is no exact definition of “marketing, promotion and solicitation of financial products and services” under Turkish financial services regulations. Marketing, promotion and solicitation cover all initiatives to market financial products and services, including passive marketing. For instance, a foreign bank calling or emailing a customer resident in Türkiye to provide information on its products and/or services without the customer asking first is considered to be marketing its services and products in Türkiye.