Post-Approval Compliance in Turkish citizenship requires investors and families to monitor legal, financial, and registry obligations after the citizenship decision is granted under Law No. 5901 and its Implementing Regulation.
LEGAL BASIS
Citizenship granted on investment or other grounds remains subject to ongoing conditions embedded in the route chosen (real estate, bank deposit, government bonds/lease certificates, fund shares, exceptional grounds). Authorities can review compliance during and after approval; material breaches may trigger administrative action, including annulment where the legal basis is lost through the holder’s own acts.
HOLDING PERIODS AND “NO DISPOSAL”
Most investment routes require maintaining the qualifying asset for three years. “No disposal” goes beyond mere sale: in practice, avoid partial transfers, pledges, liens, set-offs, or any encumbrance that drops the net qualifying value below the statutory threshold. Keep the investment intact and continuously traceable for the entire lock period.
REAL ESTATE: TITLE, ANNOTATION, AND USE
For real estate, ensure the no-sale annotation remains on the title (tapu) and that the property is neither sold nor encumbered below the qualifying threshold during the three-year horizon. Track condominium/land registry changes, co-owner actions, and any mortgage or pledge proposals from banks. Retain the valuation report, purchase receipts, and payment proofs that match deed data; if the property becomes uninhabitable or is consolidated/subdivided, seek legal advice before altering the asset profile.
BANK DEPOSIT AND SECURITIES: BLOCKS AND BALANCE
For the bank-deposit path, keep the account blocked and continuously at or above the qualifying threshold. Do not pledge the deposit or draw it down—even temporarily. For government bonds, lease certificates, or qualifying fund shares, maintain custody/ledger statements proving uninterrupted holding; avoid switching instruments unless the law permits equivalent replacements without breaking the lock.
REGISTRY AND CIVIL-STATUS UPDATES
Promptly update MERNİS (civil registry) for changes in marital status, birth/adoption of children, or court orders affecting custody—especially if family members were included in the file. Align passport/ID details with foreign records to prevent transliteration inconsistencies. If there are foreign divorces or custody orders, complete recognition (tanıma/tenfiz) in Türkiye so records remain enforceable and accurate.
ADDRESS, TAX, AND MILITARY TOUCHPOINTS
Register your address and keep it current; many notifications rely on registry data. Assess tax residency and reporting duties where dual citizenship is involved; coordinate with a tax adviser to avoid double-tax pitfalls. For eligible males, review military obligations early to plan lawful deferment or exemptions where available.
AML, SOURCE-OF-FUNDS, AND BANK RELATIONSHIPS
Banks continue KYC/EDD monitoring. Preserve the source-of-funds file (tax returns, SWIFT slips, sale agreements, inheritance papers) and be ready to re-evidence lawful origin upon request. Unusual transactions, third-party payments without clear rationale, or rapid fund movements can trigger queries—keep the economic story consistent.
EVIDENCE RETENTION AND AUDIT READINESS
Maintain a compliance binder: citizenship decision, conformity letters, title/ledger statements, bank blocking letters, CBRT/attestation records (if applicable), valuations, receipts, and certified translations/legalizations. Calendar the three-year end date and intermediate audits; request periodic confirmation letters from banks/custodians and updated extracts from the land registry.
BREACHES, REMEDIES, AND RISK CONTROL
If a breach occurs (e.g., inadvertent lien, mistaken withdrawal), act immediately: document the incident, restore the threshold, and obtain corrective letters. Depending on gravity and timing, legal strategies may include explanatory submissions, administrative re-verification, or judicial review against adverse decisions. Proactive disclosures, not silence, usually mitigate risk.
PRACTICAL CHECKLIST
- Track the three-year clock and keep the asset intact.
- Obtain periodic bank/registry confirmations.
- Keep civil-status and address records updated.
- Retain a complete evidence pack; refresh translations if required.
- Coordinate tax/military assessments early.
- Escalate promptly if any encumbrance or balance dip occurs.
CONCLUSION
Handled correctly, post-approval compliance is administrative hygiene: protect the asset, preserve documentary continuity, and keep registry, banking, and civil-status records aligned. This discipline safeguards the status you have acquired and reduces the risk of challenges down the line.
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