Exploring Digital Financial Inclusion for Sanctioned Populations: A Compliance-Aware Framework Based on DevPay Türkiye

This exploratory working paper investigates the intersection of digital financial inclusion and regulatory compliance within the context of sanctions-impacted populations. While sanctions aim to constrain state actors, millions of ordinary citizens—especially in jurisdictions indirectly affected by over-compliance—remain excluded from global financial systems. Using the DevPay Türkiye platform as a case-based lens, this paper presents a compliance-aware digital framework that enables lawful financial access for users affiliated with sanctioned geographies, without violating international standards, local laws, or global platform rules. The study contributes to emerging scholarship on “compliance-first fintech,” where legal design, entity separation, KYC/AML firewalls, and risk-governed onboarding mechanisms enable responsible service delivery. Türkiye is examined not as a sanctioned state, but as a strategic host country capable of accommodating lawful financial innovation for sanctioned-affiliated users under FATF-aligned procedures. By applying qualitative regulatory analysis and typological modeling, this paper outlines a framework that adheres to OFAC, FATF, EU, and Turkish legal standards, while proposing guardrails against exploitation and circumvention. No primary human data was collected; the paper is based on publicly available regulatory guidelines, case comparisons, and first-hand operational documentation. This work is positioned as early-stage conceptual research aimed at fintech scholars, regulators, compliance professionals, and policymakers. It highlights the tension between humanitarian access and systemic risk, and proposes a middle path grounded in digital legality, regulatory clarity, and cross-border ethics. It does not advocate any particular product but instead presents a policy-relevant structure for lawful innovation in constrained financial environments.