Traditional enforcement investigations usually begin with familiar assets:

• bank accounts;
• real estate;
• vehicles;
• company shares;
• salary;
• commercial receivables; and
• valuable movable property.

But an increasingly common enforcement problem looks very different.

The debtor has:

• no money in Turkish bank accounts;
• no valuable vehicle;
• no real estate;
• no declared investment portfolio;

yet regularly trades cryptocurrency.

The creditor suspects that the debtor holds substantial amounts of:

Bitcoin, Ethereum, USDT or other crypto assets.

This raises two separate questions:

Can cryptocurrency legally be seized in Türkiye?

and

Even if it can be seized, how can an enforcement office actually find and control it?

Since the 2024 amendments to the Turkish Capital Markets Law, the answer to the first question has become substantially clearer.

Yes. A debtor’s crypto assets can, in principle, be seized.

Article 99/B(7) of Capital Markets Law No. 6362 now expressly regulates judicial and administrative seizure requests concerning customers’ crypto assets and provides that such assets may be queried through information systems and electronically attached in accordance with Article 78 of the Enforcement and Bankruptcy Law.

However, the practical difficulty varies dramatically depending on where the debtor keeps the assets.

There is an enormous difference between:

crypto held through a regulated Turkish crypto platform

and

crypto held in a private self-custody wallet controlled only by the debtor.

For creditors, this distinction can determine whether the crypto portfolio can be frozen within hours—or remain technically inaccessible even after its existence is proven.

1. Crypto Assets Are Not Outside Enforcement Law

A debtor cannot ordinarily protect wealth from creditors merely by converting Turkish lira into cryptocurrency.

The economic principle underlying enforcement law is straightforward: assets having economic value and belonging to the debtor are generally capable of being subject to enforcement unless a specific statutory exemption applies.

Even before the 2024 crypto legislation, Turkish legal scholarship generally accepted that the uncertain private-law classification of cryptocurrency did not by itself prevent seizure of economically valuable crypto assets.

The legislative framework is now much clearer.

Law No. 7518, published on 2 July 2024, brought crypto asset service providers within the Capital Markets Law framework and introduced specific rules on custody, customer assets, judicial measures and attachment.

For enforcement practitioners, the critical provision is Article 99/B(7).

2. Article 99/B(7) Expressly Recognises Crypto Attachment

Article 99/B(7) of the Capital Markets Law provides that judicial and administrative requests concerning measures, attachment and similar actions relating to customers’ cash and crypto assets are to be implemented exclusively by crypto asset service providers.

Even more importantly, the provision expressly states that:

cash and crypto assets may be queried through information systems and electronically attached pursuant to Article 78 of the Enforcement and Bankruptcy Law.

The same mechanism is also recognised for public receivables pursued under Law No. 6183.

This eliminates one of the most important historical arguments against crypto attachment.

The legislation itself now expressly contemplates:

searching for crypto assets + imposing electronic attachment.

Accordingly, an enforcement office should not reject a properly formulated request merely on the abstract ground that:

“Cryptocurrency is not money.”

The law specifically recognises attachment of crypto assets.

3. Do Not Misread the Rule Protecting Customer Assets

Another provision can initially appear confusing.

Article 35/C(7) of the Capital Markets Law states that customer crypto assets and customer cash must be kept separate from the assets of the crypto asset service provider.

It further provides that:

• customer assets cannot be attached for the service provider’s debts; and
• the service provider’s own assets cannot be attached for customers’ debts.

This rule protects asset segregation.

It does not mean that a debtor’s own cryptocurrency is immune from the debtor’s own creditors.

The distinction is:

Platform owes money to Creditor

The platform’s creditor cannot seize Bitcoin belonging to Platform Customer A.

Customer A owes money to Creditor

Customer A’s own crypto assets can, in principle, be attached for Customer A’s debt.

The statutory separation prevents creditors from confusing the platform’s property with its customers’ property.

It does not create a general “crypto exemption from attachment.”

4. The Easiest Case: Crypto Held on a Turkish Platform

The most straightforward enforcement scenario occurs where the debtor holds cryptocurrency through a Turkish crypto asset service provider.

For example, assume the debtor has:

• 1.5 BTC;
• 20 ETH; and
• 400,000 USDT

recorded in an account maintained through a regulated Turkish crypto platform.

In this situation, the creditor can request that the enforcement office investigate and attach the debtor’s crypto holdings through the mechanisms recognised by Article 99/B(7).

The service provider becomes the institution through which the attachment is implemented.

This is conceptually similar to the enforcement system’s interaction with:

• banks;
• investment institutions; or
• other third parties holding assets or receivables belonging to the debtor.

But the Capital Markets Law now contains a crypto-specific legal foundation.

5. The Crypto Platform—not the Creditor—Implements the Attachment

Article 99/B(7) is particularly important because it states that relevant judicial and administrative requests are implemented exclusively through the crypto asset service provider.

This makes sense technically.

An enforcement officer does not personally manipulate blockchain private keys held within a platform’s custody infrastructure.

Instead, the legally recognised service provider:

• identifies the relevant customer;
• determines the assets attributable to that customer;
• applies the required restriction;
• prevents prohibited transfers;
• and implements the competent authority’s direction through its own systems.

For creditor-side practice, the request should therefore identify the debtor correctly using available identification information and seek information and attachment through the appropriate service provider infrastructure.

6. Turkey Now Has a Central Crypto Registration Infrastructure

Another major development is the Crypto Asset Central Registry System — Kripto Varlık Merkezi Kayıt Sistemi (“KVMKS”), operated by Merkezi Kayıt Kuruluşu (“MKK”).

The system was created under the post-2024 regulatory framework to record customer transactions and balances reported by crypto asset service providers and to reconcile platform and custody records.

MKK’s 2025 Integrated Annual Report confirms that crypto asset service providers were integrated into KVMKS and describes the infrastructure as enabling monitoring of crypto assets, platforms, custodians and investors within the regulated system.

This development is significant for enforcement.

Historically, a creditor might have been required to guess:

“Does the debtor use Exchange A, Exchange B or Exchange C?”

A centralised regulatory recording architecture makes regulated Turkish crypto holdings substantially more traceable.

However, KVMKS should not be described as if it were automatically a universal blockchain registry.

It records information within the regulated crypto service provider ecosystem.

A wallet privately controlled by a debtor outside regulated custody presents a different problem.

7. A Practical Enforcement Request Should Go Beyond “Does the Debtor Have Bitcoin?”

The creditor’s request should be drafted broadly enough to capture the debtor’s real crypto position.

It may be useful, depending on the facts and available enforcement infrastructure, to request investigation of:

• whether the debtor has or had a customer relationship;
• current crypto balances;
• current cash balances connected to the platform;
• crypto asset type;
• amount of each asset;
• assets subject to open orders;
• custody information;
• external wallet withdrawals;
• transaction history where legally obtainable;
• and assets transferred after attachment notice.

The creditor should avoid focusing exclusively on “Bitcoin.”

A debtor may hold wealth in:

• BTC;
• ETH;
• stablecoins;
• tokenised assets;
• or other crypto assets supported by the platform.

A request limited to one coin can unnecessarily narrow the investigation.

8. Stablecoins Are Particularly Important in Asset-Concealment Cases

Creditors sometimes search for Bitcoin but overlook stablecoins.

A debtor seeking to preserve value while avoiding the volatility of Bitcoin may hold assets in:

• USDT;
• USDC;
• or similar crypto instruments.

From an enforcement perspective, a large stablecoin position can be economically comparable to a foreign-currency balance.

Suppose the creditor searches traditional bank accounts and finds:

TRY 12,000

but the debtor holds:

500,000 USDT

on a regulated crypto platform.

The lack of bank liquidity does not accurately reflect the debtor’s financial capacity.

Modern asset investigations therefore need to include crypto holdings alongside traditional financial accounts.

9. What If the Debtor Withdraws the Crypto Immediately After Learning About Enforcement?

This is one of the major practical risks.

Crypto assets can move within minutes.

Suppose an attachment request is about to reach the platform.

The debtor transfers the entire portfolio to:

Wallet X.

The platform account then shows:

0 BTC

But that does not mean the investigation should stop.

The creditor should seek, where procedurally available:

• the withdrawal date;
• amount;
• destination wallet address;
• transaction hash;
• and other transaction records.

Blockchain transfers are generally recorded publicly on the relevant blockchain.

The debtor may therefore have removed the asset from the platform’s custody but simultaneously created a blockchain trail.

The legal problem then shifts from:

platform attachment

to

wallet identification and control.

10. The Hard Case: Self-Custody Wallets

A self-custody wallet changes the practical enforcement problem completely.

Examples include:

• a mobile wallet;
• desktop wallet;
• hardware wallet;
• paper wallet;
• cold wallet;
• or another structure in which the debtor controls the private keys.

The defining characteristic is that no Turkish crypto platform may have custody or technical authority to freeze the asset.

This matters because blockchain assets do not operate like a bank account.

A conventional bank can receive a judicial instruction saying:

“Block this account.”

A decentralised Bitcoin network has no central office to which an enforcement writ can be delivered.

No enforcement authority can simply send an electronic attachment order to “Bitcoin.”

11. Legal Seizability and Technical Control Are Different Questions

This distinction must be kept clear.

A self-custody Bitcoin balance may legally belong to the debtor and therefore form part of the debtor’s attachable economic assets.

But enforcing against it requires practical control.

Suppose a blockchain expert establishes that Wallet X contains:

8 BTC.

The creditor also proves that Wallet X belongs to the debtor.

That is valuable evidence.

But if only the debtor possesses the private key or seed phrase, transferring the BTC to a controlled wallet may remain technically difficult.

In crypto enforcement:

proving ownership

and

obtaining control

are separate stages.

12. A Hardware Wallet Does Not Literally Contain the Bitcoin

This technological point matters legally.

A hardware wallet does not normally contain cryptocurrency in the same physical sense that a safe contains banknotes.

The crypto asset exists through the blockchain record.

The hardware device generally stores or protects the cryptographic keys required to authorise transactions.

Accordingly, physically seizing a hardware device may be important, but it does not necessarily provide immediate access to the crypto assets.

The device may be protected by:

• PIN;
• passphrase;
• seed phrase;
• multisignature arrangements; or
• other security mechanisms.

The enforcement strategy therefore cannot be reduced to:

“Find the USB device and sell it.”

The economically valuable asset is the blockchain-controlled position, not merely the physical hardware.

13. Turkey’s Proposed New Enforcement Code Recognises This Problem—but It Is Still a Draft

The Ministry of Justice’s draft new Cebrî İcra Kanunu contains specific proposed provisions addressing crypto assets held through wallet devices and their custody and sale.

The draft recognises that crypto assets stored through a debtor-controlled wallet device create distinct enforcement problems and proposes specific rules for taking the device into custody.

This is an important indication of legislative direction.

However, practitioners must distinguish carefully between:

current law

and

draft legislation.

The draft itself should not be treated as if it had already replaced the Enforcement and Bankruptcy Law.

For current regulated-platform assets, Article 99/B(7) of the Capital Markets Law already provides the clearest positive-law basis.

14. How Can a Creditor Prove That a Private Wallet Belongs to the Debtor?

Wallet ownership is frequently the central evidentiary dispute.

A blockchain address usually does not display:

• name;
• Turkish identification number;
• address; or
• passport number.

Ownership must therefore be established indirectly.

Useful evidence may include:

Exchange Withdrawal Records

Suppose a verified account belonging to the debtor withdraws 3 BTC directly to Wallet X.

This creates a strong connection.

Return Transfers

If Wallet X later sends funds back to the debtor’s verified exchange account, attribution becomes stronger.

Repeated Transactions

A consistent transaction pattern between the debtor’s accounts and the wallet can support ownership.

Device Evidence

A lawfully obtained wallet device linked to the relevant address may be significant.

Electronic Records

Lawfully acquired emails, wallet notifications or transaction records may support attribution.

Admissions

The debtor may have previously stated:

“This is my wallet.”

Blockchain Expert Analysis

A specialist may reconstruct transaction chains and wallet clusters.

No single factor will always be decisive.

The strongest attribution cases combine several independent forms of evidence.

15. Bank Records Are Often the Starting Point for Crypto Enforcement

A creditor should not begin every crypto investigation with blockchain analysis.

Frequently, the traditional banking system provides the first clue.

Look for:

• transfers to crypto asset service providers;
• repeated transfers to payment institutions connected to crypto;
• significant foreign transfers;
• regular cash movements preceding crypto purchases;
• deposits from known exchanges;
• and unusual financial activity inconsistent with the debtor’s declared assets.

A typical evidentiary chain may look like:

Debtor’s bank account

↓

TRY 2,000,000 transfer

↓

Turkish crypto platform

↓

purchase of BTC

↓

withdrawal

↓

private blockchain wallet

That chain can transform a speculative allegation—

“He probably has crypto”

into a structured asset-tracing case.

16. Foreign Crypto Exchanges Create a Cross-Border Enforcement Problem

The next category is more complicated.

Suppose a Turkish debtor holds assets through a platform established abroad.

A Turkish enforcement office’s decision does not automatically have the same direct operational effect against every foreign platform.

Questions may arise concerning:

• where the service provider is legally established;
• whether it has a Turkish entity;
• whether that Turkish entity legally holds the assets;
• recognition or enforcement mechanisms;
• international judicial assistance;
• the foreign jurisdiction’s disclosure laws;
• and the platform’s response to foreign judicial orders.

Therefore, the creditor should not simply send identical domestic attachment requests to every international brand and assume the same result.

The legal entity actually maintaining custody must be identified.

17. The SPK List Is Important When Identifying Turkish Providers

The Capital Markets Board maintains public information concerning crypto asset service providers operating within the Turkish regulatory transition framework.

For enforcement lawyers, the legal identity of the platform matters.

A consumer may refer casually to a trading brand.

The enforcement request should identify the actual corporate entity against which the attachment obligation is directed.

This avoids one of the most common mistakes in digital-asset enforcement:

confusing the international brand with the Turkish legal entity.

18. Can the Creditor Use an İİK Article 89 Attachment Notice?

Crypto assets maintained by a third-party service provider also raise the general enforcement-law principles applicable to assets and receivables held by third parties.

In current Turkish legal practice, Article 99/B(7)’s special crypto framework is read together with the Enforcement and Bankruptcy Law’s mechanisms concerning electronic attachment and, where appropriate, third-party attachment procedures.

Current practitioner commentary accordingly treats crypto balances held through Turkish platforms as capable of attachment through the service provider within the enforcement framework.

The precise procedural route should nevertheless be adapted to the nature of the asset and the technical integration available to the enforcement office.

The strongest application should rely primarily on the express crypto-specific rule in Article 99/B(7) rather than treating cryptocurrency as if it were merely an ordinary bank receivable.

19. Crypto Can Also Be Subject to Precautionary Attachment

The issue is not limited to final enforcement.

Suppose a creditor has a qualifying monetary claim and satisfies the statutory requirements for precautionary attachment (ihtiyati haciz) under Articles 257 et seq. EBL.

The court’s order may cover the debtor’s attachable movable and immovable property and third-party rights and receivables within the limits of the claim.

Crypto assets should therefore not be excluded merely because of their digital form.

Once an appropriate precautionary attachment order exists, the creditor should seek its implementation against identified regulated crypto holdings.

This can be particularly valuable where the debtor is actively moving assets.

20. Speed Matters More With Crypto Than With Real Estate

Real estate cannot usually disappear to another continent in thirty seconds.

Bitcoin can.

This makes timing unusually important.

Suppose:

09:00 — Creditor discovers the debtor uses a Turkish crypto platform.

10:30 — Attachment request is prepared.

11:15 — Debtor receives information about the enforcement proceeding.

11:20 — Debtor withdraws 10 BTC to a self-custody wallet.

The difference between attachment before and after 11:20 is enormous.

Before withdrawal, a regulated service provider may be able to restrict the customer’s holdings.

After withdrawal, the creditor may need:

• blockchain tracing;
• wallet attribution;
• additional litigation;
• and ultimately technical access to the private wallet.

A crypto enforcement strategy should therefore prioritise immediate preservation.

21. What If the Debtor Transfers Crypto to a Spouse or Relative?

Another common asset-protection strategy is:

Debtor wallet → spouse’s wallet

or

Debtor exchange account → sibling’s crypto account.

The creditor should not assume that the transfer permanently removes the asset from reach.

Depending on the facts and procedural requirements, transactions designed to prejudice creditors may potentially be examined under:

Articles 277 et seq. of the Enforcement and Bankruptcy Law concerning avoidance of prejudicial dispositions.

For example, a gratuitous transfer of substantial crypto assets to a close relative shortly before enforcement may raise obvious avoidance issues.

The challenge, again, is evidence.

The creditor must establish:

• ownership before transfer;
• transfer date;
• destination;
• recipient relationship;
• consideration, if any;
• and the relevant statutory conditions.

Blockchain evidence can be extremely useful because transaction timing and amounts may remain publicly traceable.

22. Blockchain Transparency Can Sometimes Help Creditors

Cryptocurrency is frequently described as anonymous.

That is an oversimplification.

Many blockchain systems are better described as pseudonymous.

The wallet address may not reveal the owner’s name, but the blockchain may permanently display:

• transaction date;
• amount;
• sending address;
• receiving address;
• transaction hash;
• and subsequent transfers.

Once one wallet can be linked to the debtor, historical activity can sometimes be reconstructed much more comprehensively than with cash.

This means that moving crypto does not necessarily erase evidence.

A debtor attempting to conceal assets may instead create a permanent transaction chain.

23. Mixers, DeFi and Cross-Chain Transfers Make Tracing Harder

Asset tracing becomes more technically demanding where the debtor uses:

• decentralised exchanges;
• cross-chain bridges;
• multiple wallets;
• privacy-enhancing protocols;
• mixers;
• decentralised finance platforms;
• or repeated token conversions.

The legal right to pursue the asset does not necessarily disappear.

But evidentiary and technical costs increase.

Complex cases may require specialised blockchain forensic analysis capable of following:

BTC → exchange → stablecoin → bridge → another chain → new wallet.

A general accounting expert may not be sufficient for this task.

24. The Creditor Should Search for Exchange Off-Ramps

Even where assets disappear into self-custody, the debtor may eventually need to convert them into:

• Turkish lira;
• euros;
• dollars;
• real estate;
• vehicles;
• goods; or
• other conventional assets.

This usually requires an off-ramp.

Suppose the debtor transfers cryptocurrency through several private wallets and finally deposits it into a regulated platform to convert it into Turkish lira.

That reconnection to an identifiable regulated institution may create another enforcement opportunity.

For this reason, crypto asset tracing should not stop simply because a coin left its original platform.

25. How Is the Value of Attached Crypto Determined?

Cryptocurrency introduces another problem:

volatility.

Suppose 1 BTC is worth:

TRY 3 million

when attached.

Two months later it is worth:

TRY 4 million.

Or:

TRY 2 million.

The enforcement process therefore needs to distinguish:

• quantity of crypto attached;
• valuation date;
• market used for valuation;
• and eventual conversion proceeds.

A creditor should usually seek attachment of sufficient assets to cover:

• principal;
• interest;
• costs; and
• enforcement expenses,

without creating an obviously disproportionate over-attachment.

The underlying principle of proportionality remains relevant even when the asset is digital.

26. Attachment Does Not Necessarily Mean Immediate Sale

The stages should be distinguished.

There is:

identification

then

attachment/blocking

then

custody

and ultimately

realisation/conversion.

Current Capital Markets Law expressly regulates the querying and electronic attachment of crypto assets held through service providers.

Detailed practical issues surrounding the realisation of certain forms of crypto—particularly self-custody holdings—remain more technically complicated, which is one reason the Ministry of Justice’s draft enforcement legislation proposes dedicated rules for custody and sale of crypto assets.

Practitioners should therefore avoid treating the words “attachment” and “sale” as interchangeable.

27. What Happens if the Crypto Platform Itself Owes Money?

This is another important distinction.

Suppose Customer A owns 5 BTC held through Platform X.

Platform X itself owes TRY 100 million to one of its own commercial creditors.

Can Platform X’s creditor attach Customer A’s 5 BTC?

No.

The Capital Markets Law specifically separates customer assets from the platform’s own estate.

Customer crypto assets cannot be used to satisfy the provider’s debts.

This protection is economically important.

The customer is not supposed to lose personal crypto merely because the service provider has unrelated creditors.

But again, if Customer A himself is the debtor, his own crypto remains potentially attachable.

28. What If the Debtor Is a Company Rather Than an Individual?

The same basic principles apply.

Suppose Debtor Ltd. owes:

TRY 50 million

to Supplier.

The company holds:

700,000 USDT

in a corporate crypto account.

There is no reason to treat the crypto position as economically irrelevant merely because it does not appear in an ordinary bank account.

The creditor should investigate:

• whether the account is opened in the company’s name;
• which platform holds it;
• who has transaction authority;
• where the crypto was acquired from;
• whether assets have recently been transferred to shareholder wallets;
• and whether company funds were diverted into crypto shortly before enforcement.

If corporate crypto is transferred to a shareholder or manager to defeat creditors, additional:

• director liability;
• avoidance;
• fraudulent transaction;
• and potentially criminal-law

questions may arise depending on the facts.

29. A Practical Crypto Enforcement Workflow

A creditor suspecting crypto holdings can structure the investigation as follows.

Step 1 — Establish the Enforceable Claim

Determine the procedural status of the underlying debt and the available attachment authority.

Step 2 — Search the Regulated Turkish Crypto Ecosystem

Use the available enforcement mechanisms directed toward crypto asset service providers.

Step 3 — Request More Than Current Cash

Seek crypto balances as well as relevant cash balances.

Step 4 — Identify Recent Withdrawals

If the account is empty, determine whether substantial crypto recently left the platform.

Step 5 — Obtain Wallet Information Where Legally Available

Destination addresses and transaction hashes may allow blockchain tracing.

Step 6 — Examine Bank Records

Identify fiat transfers to and from crypto platforms.

Step 7 — Build Wallet Attribution

Connect external wallets to the debtor using multiple pieces of evidence.

Step 8 — Act Quickly

Seek attachment or precautionary attachment before assets move further where the legal conditions are satisfied.

Step 9 — Investigate Third-Party Transfers

Spouses, relatives and related companies should be examined where transfers appear artificial or gratuitous.

Step 10 — Use Specialist Expertise When Necessary

Complex blockchain tracing should be handled by experts familiar with on-chain investigation.

30. What Should a Creditor’s Petition Emphasise?

A strong enforcement request should not merely say:

“We believe the debtor has cryptocurrency.”

It should explain the statutory basis clearly.

For example, the request may refer to:

Capital Markets Law No. 6362 Article 99/B(7)

and

Enforcement and Bankruptcy Law Article 78

and request electronic investigation and attachment of crypto assets held for the debtor by regulated crypto asset service providers.

Where evidence exists, the request should also identify:

• known platforms;
• known wallet addresses;
• bank transfers to crypto institutions;
• transaction hashes;
• and suspicious withdrawals.

Specificity makes technical implementation easier.

31. A Practical Example

Assume Creditor has a final TRY 12 million receivable from Debtor.

The enforcement investigation finds:

Bank accounts:

TRY 40,000

Real estate:

None

Vehicles:

None

But bank records show that during the previous year Debtor transferred:

TRY 9 million

to a Turkish crypto platform.

The creditor should not conclude that the debtor is insolvent.

Instead:

Stage One

Request investigation of crypto assets through the regulated provider framework.

Stage Two

Suppose the platform identifies:

2 BTC
50 ETH
150,000 USDT.

These assets may be electronically attached within the statutory framework.

Alternative Scenario

Suppose the platform replies that the debtor withdrew all assets one month earlier to Wallet X.

The case now becomes an asset-tracing investigation.

The creditor should seek to establish:

• Wallet X belongs to Debtor;
• current balance;
• subsequent transfers;
• and whether the assets later entered another identifiable service provider.

The first platform’s zero balance is therefore not necessarily the end of the investigation.

It may simply identify where the investigation should go next.

32. The Biggest Mistake Is Searching Only Traditional Assets

A debtor with sophisticated financial knowledge may intentionally maintain very little in ordinary accounts.

A traditional asset search may produce:

Bank: zero.

Vehicle: zero.

Land Registry: zero.

The creditor may conclude:

“There is nothing to collect.”

But the debtor may have significant wealth stored as:

• stablecoins;
• Bitcoin;
• tokenised investments;
• or other digital assets.

As crypto becomes integrated into regulated financial infrastructure, enforcement practice must evolve accordingly.

The traditional asset checklist should therefore become:

bank + land registry + vehicles + securities + company shares + receivables + crypto.

33. What the 2024 Reform Changed

Before the 2024 amendments, much of the legal discussion focused on questions such as:

“What is Bitcoin legally?”

“Is it property, money, a commodity or an intangible right?”

Those theoretical classification questions remain relevant in some contexts.

But for enforcement through Turkish crypto asset service providers, the practical debate has changed.

Parliament has now expressly legislated for:

• attachment;
• judicial measures;
• administrative measures;
• information-system queries; and
• electronic attachment of customer crypto assets.

This is a major shift.

For regulated custodial holdings, the question is no longer primarily:

“Can crypto theoretically be attached?”

It is:

“Where is the debtor’s crypto held, and can the enforcement system obtain control before the debtor moves it?”

Conclusion: Bitcoin Is Not an Enforcement Safe Haven

Under current Turkish law, a debtor cannot assume that crypto assets are automatically outside the reach of creditors.

Following the 2024 amendments to the Capital Markets Law, Article 99/B(7) expressly provides a statutory framework for judicial and administrative attachment of customer crypto assets and recognises electronic querying and attachment pursuant to Article 78 of the Enforcement and Bankruptcy Law.

The practical result depends primarily on custody.

If the crypto is held through a regulated Turkish service provider:

The enforcement position is comparatively strong. The provider can implement attachment measures and the regulated system now has significantly greater centralised record infrastructure through MKK’s KVMKS.

If the crypto has been withdrawn into a self-custody wallet:

The asset remains economically valuable and potentially attachable, but identification, attribution and technical control become substantially harder.

If the crypto is held through a foreign platform:

Cross-border enforcement and the precise legal identity of the custodian must be analysed separately.

If the debtor transfers crypto to relatives or related persons to defeat enforcement:

Blockchain records may assist in tracing the transfer, and fraudulent-disposition remedies may need to be considered where the statutory conditions exist.

For creditor-side practitioners, the correct strategy is therefore not simply:

“Send a haciz notice to a crypto exchange.”

It is:

identify the exchange, freeze what remains, obtain the transaction trail, follow withdrawals to external wallets, connect those wallets to the debtor, and investigate every route through which the crypto returns to the regulated financial system.

Cryptocurrency can move quickly.

But movement does not necessarily mean disappearance.

In many cases, the blockchain leaves a trail.

The creditor who follows that trail may discover the asset that an ordinary bank-account search never revealed.