Introduction: Financial exclusion as infrastructure failure

In approved economies, financial exclusion is not only a political or regulatory phenomenon. Fundamentally, this is an infrastructure. With the increasing digitization of global finance, infrastructure that supports cross-border financial services – payments, settlements, ID cards, compliance – has been largely built on clear exclusion purposes rather than inclusion. This exclusion is often proven by compliance with international sanctions regimes, especially those issued by OFAC or FATFs, but the by-product is to create important gray areas where the entire population does not have legal access to even the most basic financial tools.

The consequences are profound. Without access to compliant financial services, approved economies strive to integrate them into a legal trading system, their citizens face barriers to educational opportunities, and the youth population is increasingly driven towards informal or illegitimate financial networks. Not surprisingly, policy discourse on financial exclusion is turning to infrastructure design issues, not just legitimacy.

Türkiye: Unique regulatory and geographic laboratory

Türkiye occupies a unique strategic position between the approved market and the European financial ecosystem. This positioning provides fertile tests for innovative financial technologies designed to navigate the complex intersection of compliance, inclusion, and infrastructure design. Türkiye’s fintech model shows that even among the population within approved jurisdictions, legal financial access is not only theoretical. It can actually be designed.

In this ecosystem, certain fintech platforms have begun to deploy highly structured compliance frameworks that can legally access cross-border financial services (wallets, remittances and limited card issuance) by leveraging Türkiye’s consistency with the FATF protocol, EU data standards and its privileged global payment network. These approaches utilize jurisdictional segmentation, strict KYC processes and cross-border data governance to ensure absolute consistency with sanctions while allowing limited and legal access to the financial infrastructure.

One such case study is a Türkiye-based platform designed specifically to provide cross-border wallets and financial services under a strict compliance approach. The platform demonstrates how architecture (rather than circumvent) can achieve legitimate access within the scope of existing regulations. Users boarded through non-Iranian addresses, unapproved mobile phone numbers and a complete FATF consistent verification process, all services are completely separated from the approved economy’s domestic financial network through infrastructure. This ensures consistency with Mastercard, visa, OFAC and local regulatory standards without violating legal or financial boundaries.

Theoretical meaning: compliance as infrastructure, not obstacles

These developments challenge the main assumptions regarding sanctions compliance and financial innovation. Traditionally, compliance has been seen as a limiting force and a barrier to innovation. However, emerging models in Türkiye make the opposite recommendation: It becomes a catalyst for legitimate innovation when compliance is seen as an infrastructure design challenge rather than a static limit.

What we observe in türkiye is not regulatory arbitrage, but design through design. The legal frameworks are not bypassed; they are internalized into the building itself. The design of multi-Italian data isolation, identity management protocols, transaction monitoring and capital control is not an afterthought, but a core element of financial products. In fact, compliance is no longer a barrier to financial inclusion. It is its enabler.

This remarks have a significant impact on the wider fintech ecosystem, especially as discussions around Regtech, digital sovereignty and geopolitical finance continue to develop. Türkiye’s model provides you with a roadmap for how to bring the approved population into a legitimate financial ecosystem without undermining the legitimacy of the international sanctions regime.

Conclusion: Establish a new inclusive paradigm under compliance conditions

The future of cross-border finance will not depend on the binary logic of access or exclusion, but on the complex, compliance-driven infrastructure that can navigate complex geopolitical realities. Türkiye’s Fintech ecosystem provides a valuable case study in this ever-evolving paradigm, demonstrating how legitimate, technologically robust and rational infrastructure can be a bridge between exclusion and inclusion.

Financial inclusion under sanctions is not only a legal issue. The growing question is who is willing to build the infrastructure that makes legal access possible. Just like the future that fintech leaders, policy makers and regulators are looking forward to, Türkiye’s example shows that innovation and compliance don’t have to be rivals. When designed together, they can provide meaningful access to those who need it most without violating the legal and ethical frameworks that global finance relies on.