Introduction: Financial Exclusion as Infrastructure Failure
In sanctioned economies, financial exclusion is not merely a political or regulatory phenomenon; it is fundamentally an infrastructural one. As global finance becomes increasingly digitized, the infrastructure supporting cross-border financial services —
payments, settlements, identification, compliance — has been largely constructed with the explicit aim of exclusion, rather than inclusion. This exclusion is often justified through compliance with international sanctions regimes, notably those issued by OFAC
or FATF, but the by-product is the creation of significant grey zones where entire populations lack lawful access to even the most basic financial tools.
The consequences are profound. Without access to compliant financial services, sanctioned economies struggle to integrate into legitimate trade systems, their citizens face obstacles to educational opportunities, and youth populations are increasingly driven
towards informal or illicit financial networks. It is no surprise that the policy discourse on financial exclusion is shifting towards questions of infrastructure design — not just legality.
Türkiye: A Unique Regulatory and Geographic Laboratory
Türkiye occupies a uniquely strategic position between sanctioned markets and the financial ecosystems of Europe. This positioning has produced a fertile testing ground for innovative financial technologies aimed at navigating the complex intersection of
compliance, inclusion, and infrastructure design. Turkish fintech models are demonstrating that lawful financial access, even for populations within sanctioned jurisdictions, is not merely theoretical. It can be practically engineered.
Within this ecosystem, certain fintech platforms have begun deploying highly structured compliance frameworks that allow for lawful access to cross-border financial services — wallets, remittances, and in some cases, limited card issuance — by leveraging
Türkiye’s alignment with FATF protocols, EU data standards, and its privileged access to global payment networks. These approaches utilize jurisdictional segmentation, rigorous KYC processes, and cross-border data governance to ensure absolute alignment with
sanctions while enabling limited, lawful access to financial infrastructure.
One such case study is a Türkiye-based platform designed specifically to provide cross-border wallets and financial services under strict compliance methodologies. This platform demonstrates how architecture, rather than circumvention, can enable lawful
access within the bounds of existing regulations. Users are onboarded through non-Iranian addresses, non-sanctioned mobile numbers, and full FATF-aligned verification processes, with all services flowing through infrastructure wholly separated from the sanctioned
economy’s domestic financial networks. This ensures alignment with Mastercard, Visa, OFAC, and local regulatory standards without breaching legal or financial boundaries.
Theoretical Implications: Compliance as Infrastructure, Not Barrier
These developments challenge prevailing assumptions about sanctions compliance and financial innovation. Traditionally, compliance has been viewed as a restrictive force, a barrier to innovation. However, emerging models in Türkiye suggest the opposite:
when compliance is treated as an infrastructural design challenge, rather than a static restriction, it becomes a catalyst for lawful innovation.
What we observe in Türkiye is not regulatory arbitrage but regulatory alignment through design. Legal frameworks are not bypassed; they are internalized into the architecture itself. Multi-jurisdictional data segregation, identity management protocols, transaction
monitoring, and capital controls are designed not as afterthoughts, but as core elements of the financial product. In effect, compliance is no longer an obstacle to financial inclusion; it is the enabler of it.
This reframing has significant implications for the broader fintech ecosystem, especially as discussions around RegTech, digital sovereignty, and geopolitical finance continue to evolve. Türkiye’s models offer a roadmap for how sanctioned populations can
be brought into lawful financial ecosystems without undermining the legitimacy of international sanctions regimes.
Conclusion: Towards a New Paradigm of Inclusion Under Compliance
The future of cross-border finance will depend not on the binary logic of access or exclusion but on sophisticated, compliance-driven infrastructure capable of navigating complex geopolitical realities. Türkiye’s fintech ecosystem offers a valuable case
study in this evolving paradigm, demonstrating how lawful, technically robust, and ethically sound infrastructure can serve as a bridge between exclusion and inclusion.
Financial inclusion under sanctions is not merely a legal question. It is, increasingly, a question of who is willing to build the infrastructure that makes lawful access possible. As fintech leaders, policymakers, and regulators look to the future, Türkiye’s
example suggests that innovation and compliance need not be adversaries. When designed together, they can deliver meaningful access to those who need it most, without breaching the legal and ethical frameworks upon which global finance depends.
