Crypto Sponsorship, Fan Tokens, and MASAK (Financial Crimes Investigation Board)
Digital transformation in the sports industry has fundamentally changed sponsorship models. Cryptocurrency exchanges, blockchain-based investment tools, and fan token projects have become revenue sources for clubs. However, this new system is under the supervision of the Financial Crimes Investigation Board (MASAK ), the Capital Markets Board (SPK) , and the Advertising Board ( Real Estate Agency) in terms of financial crimes, money laundering, and investor protection .
This article will examine crypto sponsorship and fan token projects Turkish law , analyzing clubs' compliance obligations with MASAK (Financial Crimes Investigation Board) and potential criminal risks.
2. What is Crypto Sponsorship?
Crypto sponsorships are agreements between a club and a cryptocurrency platform where the club uses advertising, jerseys, or stadium spaces in exchange for brand promotion.
For example:
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Paris Saint-Germain – Crypto.com,
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Manchester City – OKX,
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The Galatasaray – Socios.com agreements are an example of this model.
In Turkish law, these contracts may contain elements of a service contract or a contract for work , as defined in Articles 470 et seq. of the Turkish Code of Obligations
3. MASAK Compliance Obligation
to Law No. 5549 on the Prevention of Money Laundering, crypto asset service providers are considered "obligated parties."
Therefore, clubs must fulfill the following obligations in their sponsorship agreements with crypto exchanges:
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Authentication of Personal Data (KYC) – Party verification must be completed before a business relationship is established.
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Suspicious Transaction Report (STR) – Unusual fund inflows must be reported to MASAK (Financial Crimes Investigation Board).
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A training and internal audit – compliance unit should be established, and employees should receive AML (Anti-Money Laundering) training.
MASAK General Circular No: 19:
“Advertising and sponsorship agreements with crypto asset providers should be monitored as part of a money laundering risk assessment.”
4. Legal Nature of Fan Tokens
Fan tokens are digital assets minted on the blockchain that offer fans voting rights, access to content, or exclusive benefits.
According to the Capital Markets Board (SPK), these tokens securities ; however, investment instruments .
Capital Markets Board Press Release (2021/63):
“Crypto assets are not considered investment services or capital market instruments; however, marketing activities for investment purposes are subject to oversight.”
Fan token contracts are mostly in the nature of "licensed digital product contracts" or "service usage contracts".
5. Clubs' Responsibility to MASAK (Financial Crimes Investigation Board)
While clubs are not directly considered "obligated," they fall under indirect compliance obligations due to their collaboration with crypto companies . In this context:
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The payment method (crypto or fiat) is specified in the contract
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The source of the fund transfer,
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The parties' identification information
must be provided.
Supreme Court 11th Criminal Chamber, Case No. 2022/3145, Decision No. 2022/7904:
"Organizations that accept cryptocurrency payments for advertising or sponsorship revenue are obligated to disclose the source of the funds."
6. Tax Assessment
Income from crypto sponsorships is taxed under the Corporate Tax Law and the Value Added Tax Law . Income from fan token sales must be declared as " business income "
If the token is sold on an international platform, double taxation agreements must be taken into consideration.
Opinion of the Revenue Administration (2023):
"Revenue from the sale of crypto assets is subject to VAT as a digital product sale."
7. Advertising Board and Consumer Law Aspects
Crypto sponsorship campaigns the Consumer Protection Law and of the Advertising Board .
Clubs using phrases such as "investment guarantee" or "promise of profit" misleading advertising .
Advertising Board Decision – September 28, 2022:
"An advertisement promoting investment through a cryptocurrency sponsor has been fined 250,000 TL."
8. International Regulations
The EU, Markets in Crypto Assets Regulation (MiCA), has brought fan tokens and sponsorship deals closer to the investment instrument category.
This regulation is also referenced in Turkey by MASAK and SPK.
According to MiCA Art. 4:
"The issuer of crypto assets is obligated to provide the investor with an information document."
Therefore, clubs are legally required to provide information and risk warnings during fan token launches.
9. Criminal Risks
In case of suspected misrepresentation, unauthorized token sales, or fund laundering:
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Turkish Penal Code Article 282 (Money Laundering of Assets Derived from Crime)
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MASAK Article 13 (Administrative sanctions)
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Article 109 of the Capital Markets Law (CSPKn) (Misleading the investor)
is applicable.
Secret agreements, particularly those involving offshore exchanges, can hold club executives liable for both administrative and criminal charges .
10. Conclusion and Evaluation
While crypto sponsorships and fan tokens offer significant financial opportunities to sports clubs, compliance with the Financial Crimes Investigation Board (MASAK), transparency, data security , and investor information are fundamental requirements.
Clubs should work with expert lawyers and financial advisors to oversee contracts; they must also document consent, taxation, and fund flows.
Cryptocurrency sponsorships, when conducted without regulation, can lead to risks of financial reputational damage and sanctions.
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