Can blockchain based products create trust when the market in Türkiye needs it?
Following decisions issued on 17 September, 131 funds belonging to seven portfolio management companies were placed into liquidation. According to the Capital Markets Board of Türkiye, those funds had 455,758 unique investors. The specified liquidation period was later extended from three months to six months so that portfolio assets could be sold under appropriate market conditions. [Source: CMB - investor count] · [Source: CMB - liquidation period]
As confidence in the markets is questioned after this decision, which was prompted by a series of scandals, we believe this is precisely the time to discuss how innovative technologies can be used to restore confidence in Turkish capital markets. In particular, rebuilding the market with blockchain based digital asset technologies, while preserving the existing capital markets framework in full and moving all Turkish capital market activity onto blockchain infrastructure, could be one of the most important elements in restoring trust.
Imagine a Turkish Capital Markets blockchain in which a permissioned distributed ledger converts fund unit issuance and redemption requests, custody, cash and settlement movements, and the data and valuation version used to calculate net asset value into a time stamped audit trail. It might not make every market problem visible, but investors, auditors and regulators could follow when an order was made, at which stage it was pending and which record it was reconciled against, without having to reconstruct files after the fact. Zero knowledge proofs could make this architecture more commercially viable. Without disclosing all of its positions or counterparties, a fund could prove that it complies with stated investment restrictions, has passed specified collateral or concentration tests, or has not breached a predefined limit. The purpose of a ZK approach is to establish correctness without revealing unnecessary data.
However, blockchains do not, under any circumstances, independently establish that data entered into them is correct in the real world. Incorrect valuation, incomplete custody records, undisclosed related party risk, low liquidity or weak governance would remain problems on chain. Without reliable data sources, custody discipline, independent audit and legal accountability, an immutable record is, of course, only an immutable claim.
CLARITY is pushed to next spring uncertainty in the US
On 15 September, the US Senate failed to reach the required majority in the 49 to 50 procedural vote that would have allowed it to proceed to consideration of the CLARITY Act. The result delayed more than the bill becoming law: the federal framework that would permanently define issuance, trading platforms, custody and regulatory jurisdiction in the digital asset market was once again left in limbo. [Source: US Senate]
This does not mean that the US tokenisation agenda has stopped. A few days later, the SEC issued its Innovation Exemption, allowing onchain trading in tokenised NMS stocks under certain conditions. But the decision does not take the place of the legislature. [Source: SEC]
September Flow
SEC opens a controlled route for tokenised equity trading: The Innovation Exemption allows certain Tokenized Securities Venues to facilitate permissioned onchain trading in tokenised NMS stocks on a conditional and limited basis. Transparent transaction data, recordkeeping, technology safeguards and volume limits are positioned as parts of the framework. [SEC]
The United Kingdom is entering its authorisation period: The FCA has published guidance on the scope of its cryptoasset regime. The application window opens on 30 September 2026, and the full regime will take effect on 25 October 2027. [FCA]
Lending and tokenised deposits are on the MiCA review agenda: The EBA presented to the Commission its priorities on scope and definitions, stablecoin issuers, multi function groups, interaction with payments rules, crypto lending and tokenised deposits. [EBA]
Singapore is moving its stablecoin regime into legislation: MAS is seeking feedback on legislative changes covering value stability, capital, par redemption, stress testing, wind down plans and limited recognition of foreign stablecoins. [MAS]
Remote customer onboarding is becoming more constrained in Türkiye: The 3 September rule requires remote identification of foreign natural persons through NFC enabled passports compliant with ICAO 9303, alongside higher risk monitoring and defined SWIFT flows. [Official Gazette]
This publication is for information only and does not provide investment, legal or compliance advice.
The recurring theme in regulation is that “clearer” is not the same as “lighter.” A workable framework should make the failure path legible too—who can pause a system, who is liable, and how users recover when the rule changes.