14.08.2026 17:00
Crypto.com added Turkey to the list of eligible countries for Dual Invest, which it showcased among 'crypto options products' in its own research report. The product, which involves a target price, maturity, asset locking, and conditional automatic conversion, has raised serious questions in light of the CMB's ban on derivative transactions.
Crypto.com, whose company in Turkey is in the process of liquidation, displays its product called Dual Invest as available in Turkey. On the page in the platform's Turkish help center, Turkey is explicitly listed among the countries where the product is available.
With Dual Invest, a user invests a crypto asset and selects a target price and a maturity date. At maturity, if the specified condition is met, the invested asset is converted into an alternative crypto asset without requiring a new instruction.
CRYPTO.COM CALLED IT AN "OPTION" IN ITS OWN REPORT
Crypto.com promotes Dual Invest as a "reward-earning feature" on its Turkish help page. However, in the company's research report dated June 5, 2025, titled "Crypto Options," the product is classified under a different heading.
In the report, Dual Invest is shown among Crypto.com's "crypto options products," together with UpDown Options and Strike Options. The same report explains that options are a type of derivative, that they carry more complex structures than spot transactions, and that they may involve higher investment risks.
Thus, the company classifies the product it presents as a "reward feature" in its Turkish help center directly among crypto options in another corporate publication.
TURKEY IS AMONG ELIGIBLE COUNTRIES
The Dual Invest page lists the countries where the product can be used one by one. Turkey is also included in this list.
This record makes it difficult to argue that the product is not intended for Turkey. The platform does not merely publish Turkish content; it directly shows Turkey among the eligible countries.
However, it has not been independently tested whether an order can actually be completed through a verified account resident in Turkey. The finding that has been definitively confirmed is that Crypto.com keeps Turkey on the product's eligibility list.
ASSETS ARE LOCKED, ORDERS CANNOT BE CANCELLED
Dual Invest does not operate like an ordinary spot trading transaction. Once the user confirms the order, the invested asset is locked until maturity.
Crypto.com explicitly states that a placed order cannot be changed or cancelled afterwards.
The outcome is determined based on the average index price of the target asset in the last 60 minutes before the payment date. If the condition is met, the invested amount and the reward are converted into the alternative crypto asset at the selected target price.
EXAMPLE OF AN ANNUAL RATE OF 132.42% ON THE TURKISH PAGE
Crypto.com's Turkish page includes an example using 0.5 Bitcoin, a target price of 97,000 USDC, a one-day maturity, and an annual rate of 132.42%.
However, 132.42% is not the profit a user will earn in one day. This is an annualized example rate. According to the formula disclosed by the company, the one-day reward portion in the example corresponds to approximately 0.363% of the invested asset.
It cannot be said that the rate is fixed, guaranteed, or a current return offered to all users.
ARTICLE 14 OF THE CMB IS CLEAR
According to Article 14 of the Communiqué No. III-35/B.2, which entered into force on March 13, 2025, crypto assets listed on platforms cannot be traded with leverage.
The same article also prohibits these assets from being subject to derivative instrument contracts, margin purchases, short sales, and lending transactions.
The structure of Dual Invest, which involves a target price, maturity, asset locking, and conditional automatic conversion, draws attention. The fact that Crypto.com shows the product among its "crypto options products" in its own report further strengthens the question of whether the product should be evaluated within the scope of Article 14.
Whether Dual Invest qualifies as a derivative instrument contract under Turkish law can only be definitively assessed by the CMB and competent authorities. However, the company's own classification constitutes a clear corporate record that may carry weight in any investigation.
THE NAME OF THE PRODUCT DOES NOT CHANGE ITS LEGAL NATURE
Experts point out that presenting a financial product under the name "reward," "earnings," or "feature" does not alone determine the product's legal nature.
In the assessment, the economic outcome of the transaction matters more than the name used. The target price, maturity, obligations undertaken by the parties, the locking of assets, and automatic conversion when a specific condition occurs are all examined together.
According to experts, Crypto.com's expression "crypto options product" in its own report does not alone constitute a definitive judgment. However, this expression is one of the important elements that could be taken into account in the CMB's examination of the product's true nature.
WHICH COMPANY STANDS BEFORE TURKISH USERS?
Crypto.com's Turkey user agreement states that application services are provided by Foris DAX TR, unless otherwise specified. The contract also states that some services may be provided by affiliates of Foris DAX TR and may be subject to separate conditions.
However, the contract does not explicitly name Dual Invest or the legal entity offering this product.
Foris DAX TR appears on the CMB's current list under the title "Foris DAX TR Crypto Asset Trading Platform Inc. in Liquidation." Neither Crypto.com nor Foris DAX TR appears on the CMB's list of operating institutions.
The CMB also emphasizes that being on the "List of Operating Entities" does not even constitute authorization.
Despite this, which Crypto.com company offers Dual Invest, which is explicitly shown as available in Turkey, on what license this company relies, and which legal entity a Turkish user can apply to in case of a dispute have not been clarified.
PUBLICATIONS WITH TARGET PRICES ARE ALSO UNDER REVIEW
Article 30 of Communiqué No. III-35/B.1 prohibits crypto asset service providers from including a specific price target in their advertisements, announcements, publications, and notices.
The regulation also restricts promotional campaigns that offer specific return promises or direct users to invest in one or more crypto assets.
Whether the example on Crypto.com's help page with a target price of 97,000 USDC and an annual rate of 132.42% is merely a technical product description or a promotional publication requires assessment by the competent authorities.
The contradiction in the middle is clear: the CMB prohibits derivative contracts being written on crypto assets listed on platforms. Crypto.com, on the other hand, keeps Turkey among the eligible countries for Dual Invest, which it shows as a "crypto options product" in its own report. If the authorities deem the product a banned activity or an unauthorized crypto asset service, the suspension of the activity and blocking of access to the relevant internet addresses may come to the fore. Individuals determined to be responsible for unauthorized activity may also face imprisonment from three to five years and judicial fines from five thousand to ten thousand days.