Can a Foreigner’s Bank Account Be Blocked in Türkiye and How Can the Block Be Removed?

Yes.

A foreign national’s bank account in Türkiye can be blocked, restricted, attached, frozen or made temporarily unavailable under several different legal mechanisms.

However, the expression “my bank account is blocked” is not itself a legal diagnosis.

Two foreign customers may both see the same practical result on mobile banking:

“You cannot transfer this money.”

Yet the legal reasons may be completely different.

One account may be subject to an ordinary enforcement attachment for an unpaid debt.

Another may be affected by a tax authority electronic attachment.

A third may be subject to a criminal seizure order issued during a fraud or money-laundering investigation.

A fourth customer may simply be facing additional bank compliance checks concerning identity, residence information or the source and purpose of an international transfer.

A fifth transaction may have been temporarily suspended under Turkish anti-money-laundering legislation.

The legal procedure for removing the restriction depends entirely on which type of block exists.

This distinction is particularly important for foreign nationals because international transfers, different tax residencies, foreign companies, large property payments and cross-border source-of-funds documentation can cause Turkish banks to request more information before processing certain transactions.

However:

being a foreigner is not, by itself, a legal ground for confiscating or indefinitely freezing a bank account.

Turkish banks operate under banking, anti-money-laundering, criminal procedure, enforcement and tax legislation. Any restriction must therefore be analysed under the legal framework that created it.

Why Can a Foreign Bank Account Be Blocked in Türkiye?

The most common legal and practical reasons include:

1. The bank’s own security or compliance controls
2. MASAK-related suspicious transaction procedures
3. A temporary transaction suspension under Law No. 5549
4. A criminal seizure order under Article 128 of the Criminal Procedure Code
5. An enforcement attachment for a private debt
6. A tax or public-debt electronic attachment, known as e-haciz
7. A statutory asset-freezing decision concerning terrorism financing or international sanctions
8. Identity, passport, residence or customer-information deficiencies
9. Suspicion of account takeover, fraud or unauthorised banking activity
10. Contractual set-off or other bank claims in specific circumstances

Each requires a different response.

The first step should therefore never be:

“File a lawsuit against the bank immediately.”

The first step should be:

“Identify the exact legal basis of the restriction.”

Are Foreigners Treated Differently by Turkish Banks?

Foreign nationality does not automatically justify seizure of funds.

However, anti-money-laundering legislation operates through a risk-based approach.

Banks are among the institutions required to operate compliance programmes under Turkish anti-money-laundering legislation.

MASAK’s current compliance framework expressly recognises:

• customer risk;
• service risk;
• and country risk.

Country risk can include relationships involving countries considered higher risk in relation to money laundering or terrorism financing. Banks are also required to conduct continuing monitoring and risk-control activities.

This means that a foreign customer may sometimes face additional questions because of:

• the country from which funds originate;
• unusual international transfers;
• transaction size;
• business activity;
• relationship between sender and beneficiary;
• frequency of transfers;
• use of high-risk services;
• or inconsistency between the customer profile and account activity.

This is not the same as saying:

“Foreigners are presumed suspicious.”

They are not.

The issue is transaction and customer risk, not nationality alone.

Can a Turkish Bank Ask a Foreigner Where the Money Came From?

Yes.

This is very common in large international transfers.

A bank may ask the customer to document the source of funds and the economic purpose of a transaction.

For example, a foreign customer receiving USD 600,000 into a Turkish account may be asked to provide documents such as:

• property sale agreement;
• company dividend records;
• employment income records;
• inheritance documents;
• foreign bank statements;
• share sale agreement;
• loan agreement;
• tax documentation;
• investment records;
• or documents establishing the relationship between sender and recipient.

Banks operate under customer-identification, ongoing monitoring and suspicious-transaction obligations.

MASAK legislation defines suspicious transactions broadly as transactions where there is information, suspicion or grounds for suspicion that the property involved was obtained unlawfully or is being used for unlawful purposes.

Accordingly, a customer should not interpret every source-of-funds request as an accusation of criminal conduct.

In many cases, supplying coherent documentation resolves the problem.

Can the Bank Restrict the Account Because the Passport or Residence Information Is Out of Date?

Potentially, banking services can be restricted while customer information is being updated or verified.

MASAK guidance emphasises that obliged institutions must keep customer information, documents and records current. Its official FAQ specifically refers to the obligation to maintain updated customer information and verify address information used for customer identification.

A foreign customer should therefore keep the bank informed of changes involving:

• passport;
• foreign identity number;
• residence permit;
• registered address;
• tax number;
• telephone number;
• tax residence;
• beneficial ownership information for companies;
• and other material customer information.

However, an internal customer-information issue is different from a judicial seizure.

Once the required information has been supplied and verified, an internal compliance restriction may often be resolved through the bank itself.

What Is a Bank’s Internal Compliance Block?

Banks operate fraud-detection, transaction-monitoring and anti-money-laundering systems.

An unusual transaction may therefore be stopped internally while the bank asks questions or checks documents.

Examples include:

• a new account suddenly receiving very large transfers;
• repeated transfers from unrelated third parties;
• money immediately leaving the account after arrival;
• unexplained cryptocurrency-related transactions;
• inconsistent transaction patterns;
• possible identity fraud;
• sanctions screening;
• possible account takeover;
• or missing customer documentation.

An internal banking restriction should not automatically be confused with:

• a court seizure;
• an enforcement attachment;
• or a MASAK transaction suspension.

The practical distinction matters because an ordinary bank compliance issue may be resolved by:

• providing documents;
• confirming identity;
• explaining the commercial transaction;
• proving source of funds;
• or completing additional verification.

A court-ordered seizure cannot normally be removed simply because the customer gives the branch manager an invoice.

What Is MASAK?

MASAK is the Financial Crimes Investigation Board, operating within the Turkish Ministry of Treasury and Finance.

Its responsibilities include combating:

• money laundering;
• terrorism financing;
• and related financial crimes.

Banks are among the entities subject to obligations under Law No. 5549 and the regulations issued under that law.

MASAK-related issues are among the most misunderstood reasons for banking restrictions involving foreigners.

Does MASAK Automatically Freeze an Account Whenever the Bank Reports a Suspicious Transaction?

No.

A suspicious transaction report and a legal freeze are not the same thing.

Banks are required to report qualifying suspicious transactions to MASAK.

Importantly, the bank cannot normally tell the customer:

“We submitted a suspicious transaction report about you.”

Law No. 5549 expressly prohibits obliged institutions from disclosing to the parties or other persons that a suspicious transaction report has been submitted, except to the authorised auditors and courts during proceedings.

This explains why customers sometimes receive limited explanations from bank personnel.

A branch employee may not legally be able to disclose all internal compliance information.

What Is a MASAK Transaction Suspension Under Article 19/A?

Article 19/A of Law No. 5549 creates a specific mechanism called postponement of transactions.

Where a transaction involves property suspected of being connected with money laundering or terrorism financing, the competent authority may suspend the transaction or prevent it from being completed while the suspicion is examined.

Under the statute, this temporary measure can be imposed for seven business days.

MASAK’s official regulation describes postponement as either:

• suspending the transaction;
• or refusing to allow it to be completed temporarily.

The system applies where documents or serious indications support suspicion concerning money laundering or terrorism financing.

This rule must be understood correctly.

A Seven-Business-Day Transaction Suspension Is Not the Same as an Indefinite Account Freeze

The Article 19/A mechanism is temporary.

MASAK’s official FAQ confirms that the seven-business-day period is calculated from the relevant notification and that if the required decision is not notified within the statutory period, the transaction can proceed under the applicable framework.

However, this does not mean the account must always become fully unrestricted after seven business days.

During the review, authorities may obtain information leading to a separate criminal seizure order or another legally authorised measure.

That subsequent measure would have a different legal basis and duration.

Can the Bank Tell Me That MASAK Reported Me?

Usually not.

This is another frequent misunderstanding.

Banks themselves submit suspicious transaction reports to MASAK.

The reporting process is confidential.

Under Law No. 5549, the bank cannot tell the customer that a suspicious transaction report has been submitted.

Therefore, statements from bank staff such as:

“Your transaction is being reviewed by the compliance department”

may not reveal the full process.

This lack of detail can be frustrating, but it may arise from a legal confidentiality obligation rather than simple unwillingness to cooperate.

What Should a Foreigner Do During a MASAK-Related Compliance Review?

The customer should first avoid taking steps that make the situation more suspicious.

For example, the customer should not:

• create multiple new accounts solely to bypass the restriction;
• ask unrelated people to receive the funds;
• split transactions artificially;
• give inconsistent explanations;
• create retrospective contracts that do not reflect the truth;
• or attempt to move funds through third parties.

Instead, prepare a coherent documentation package.

Depending on the transaction, this may include:

• foreign bank account statements;
• purchase or sale agreement;
• company documents;
• shareholder resolutions;
• invoices;
• tax declarations;
• inheritance certificate;
• salary records;
• proof of investment;
• loan agreement;
• proof of beneficial ownership;
• and a clear written explanation of the transaction.

A legitimate foreign investor should be able to explain:

Who sent the money?

Why was it sent?

Where did the sender obtain it?

What is the commercial or personal purpose?

What will happen to the funds next?

Can a Criminal Court Freeze a Foreigner’s Bank Account?

Yes.

This is a much more serious legal measure.

Article 128 of the Turkish Criminal Procedure Code No. 5271 permits seizure of various assets where there is a strong suspicion based on concrete evidence that:

1. the relevant offence was committed; and
2. the property was obtained from that offence.

The assets that may be seized expressly include:

“any kind of account at banks or other financial institutions.”

Therefore, a foreign national who becomes a suspect in a qualifying criminal investigation may find that:

• Turkish-lira accounts;
• foreign-currency accounts;
• investment accounts;
• and other qualifying financial assets

have become unavailable.

The measure is not limited to Turkish citizens.

Is Every Criminal Investigation Enough to Freeze a Bank Account?

No.

Article 128 is an exceptional protective measure.

The statute requires a strong suspicion based on concrete evidence concerning both:

• commission of the offence;
• and the connection of the assets with the proceeds of the offence.

Article 128 also applies within the statutory framework concerning qualifying offences.

The Constitutional Court has likewise described Article 128 as permitting seizure of bank accounts on the basis of a judicial decision where the statutory conditions are satisfied.

A bank itself does not decide whether the criminal requirements of Article 128 are satisfied.

The bank executes the competent authority’s measure.

How Is a Criminal Bank Account Seizure Implemented?

Article 128 provides that a seizure order concerning accounts at banks or other financial institutions is immediately communicated to the relevant institution through technical communication channels and separately served on the institution.

Transactions intended to defeat the seizure after the decision has been made are invalid.

This explains why a customer can suddenly find that previously available money has become inaccessible.

How Can a Criminal Account Seizure Be Challenged?

The precise legal remedy depends on:

• which authority issued the order;
• procedural stage;
• type of investigation;
• and statutory basis.

Under the general objection provisions of the Criminal Procedure Code, objection is available against judicial decisions in cases where the law allows it.

Following amendments effective in 2024, the general objection period under Article 268 is two weeks from learning of the decision, unless a different rule applies.

A lawyer challenging a criminal bank seizure may argue issues such as:

• absence of concrete evidence;
• failure to establish a connection between the money and the alleged offence;
• disproportionate seizure;
• funds belonging to a third party;
• lawful source of funds;
• excessive scope of the measure;
• or changed circumstances making continued seizure unnecessary.

The account holder should also provide documentary evidence showing the legitimate origin of the funds.

What If the Money Belongs to Someone Other Than the Suspect?

Article 128 expressly contemplates seizure even where specified assets are held by another person if the legal conditions concerning the suspect’s property are established.

Therefore, simply saying:

“The money is in my spouse’s account”

does not necessarily defeat a seizure where authorities allege that the beneficial owner is actually the suspect.

Conversely, a genuine third party whose legitimate money has been captured by a measure may have grounds to seek removal or limitation of the seizure.

Evidence of actual ownership becomes essential.

Can an Account Remain Frozen Forever During a Criminal Investigation?

Protective measures must remain legally justified and proportionate.

The Turkish Constitutional Court has emphasised in bank-account cases that even a measure initially serving a legitimate public purpose can become disproportionate if it continues for an excessive period without adequate justification.

In Ayşe Sabahat Gencer (B. No. 2018/34950), the Constitutional Court found a violation of the constitutional right to property where a bank-account-related block continued for more than five years without sufficient assessment demonstrating why the measure still needed to remain in force.

That case arose under a different specific statutory framework, but the broader constitutional principle is important:

a financial restriction should not continue indefinitely without continuing legal justification and proportionality.

Can a Foreigner’s Turkish Bank Account Be Attached for an Ordinary Private Debt?

Yes.

A bank account can be attached through enforcement proceedings for an ordinary civil or commercial debt.

Examples include:

• unpaid loan;
• court judgment debt;
• unpaid promissory note;
• rental debt;
• contractual debt;
• compensation debt;
• or another enforceable receivable.

Banks hold money belonging to the account holder and are therefore third parties in enforcement proceedings.

Article 89 of the Enforcement and Bankruptcy Law No. 2004 regulates attachment of claims and assets held by third parties.

The official Enforcement and Bankruptcy Law text provides for service of an attachment notice on the third party where the enforcement debtor has a claim or property in that person’s possession.

A bank can therefore be required to block attachable amounts belonging to the debtor.

Foreign nationality does not prevent attachment.

Does a Bank Attachment Mean the Entire Account Belongs to the Creditor?

Not necessarily.

The extent of the attachment depends on:

• debt amount;
• enforcement costs;
• interest;
• nature of the funds;
• and any statutory exemption from attachment.

A debt of TRY 150,000 should not automatically justify treating every future asset of unlimited value as the creditor’s property.

The particular enforcement file must be examined.

How Can an Enforcement Attachment Be Removed?

Possible methods include:

• paying the enforcement debt;
• obtaining the creditor’s consent to release the attachment;
• challenging an unlawful enforcement proceeding;
• showing that the debt has already been paid;
• proving mistaken identity;
• challenging attachment of legally exempt funds;
• obtaining a court or enforcement-court decision;
• or resolving the underlying enforcement dispute.

The correct remedy depends on whether the problem is:

the debt itself

or

the attachment procedure.

A foreign customer should obtain the enforcement-file number and identify:

• enforcement office;
• creditor;
• debt amount;
• date of proceedings;
• and legal basis.

Without the file information, attempting to resolve the issue only with the bank is usually ineffective.

The bank normally cannot disregard a valid enforcement order simply because the account holder disputes the debt verbally.

Can a Tax Debt Cause a Bank Account to Be Blocked?

Yes.

This is commonly known as e-haciz, or electronic attachment.

Public receivables such as qualifying tax debts can be collected under Law No. 6183 on the Procedure for the Collection of Public Receivables.

Article 79 permits attachment of rights and receivables held by third parties, including banks.

The Revenue Administration confirms that electronic attachment notices are sent to participating banks under Article 79 and that assets and receivables identified through the process can be attached for collection of public debts.

Therefore, a foreign person with Turkish tax obligations can have Turkish bank funds affected by an e-haciz.

What Can Cause a Foreigner to Have a Turkish Public Debt?

Examples can include:

• income tax;
• property-related taxes;
• company-related liabilities in qualifying circumstances;
• administrative fines;
• tax penalties;
• vehicle-related liabilities;
• or other public receivables subject to Law No. 6183.

A foreign person should not assume that leaving Türkiye eliminates an existing Turkish public debt.

How Can an E-Haciz Be Removed?

The first step is to identify the public debt through the relevant tax or collection authority.

Potential solutions can include:

• payment;
• correction of an erroneous debt;
• cancellation following successful legal challenge;
• instalment or restructuring where legally available;
• proving that collection has already occurred;
• or obtaining an order requiring removal of the attachment.

Revenue Administration guidance itself notes that e-haciz should not be applied in certain circumstances, such as qualifying debts for which payment has been deferred or where execution has been judicially stayed.

Therefore, a mistaken or excessive e-haciz should not simply be accepted.

However, administrative and tax litigation has short procedural deadlines.

Immediate examination of:

• payment order;
• tax assessment;
• service date;
• and attachment date

is essential.

What Is the Difference Between E-Haciz and an Ordinary Enforcement Attachment?

The distinction is fundamental.

Ordinary enforcement attachment

Usually involves a private creditor and is governed primarily by the Enforcement and Bankruptcy Law.

E-haciz

Involves a public receivable and is governed by Law No. 6183.

The competent authorities, objection mechanisms and courts can differ.

A customer who simply says:

“My account has a haciz”

has not yet provided enough information to determine the remedy.

Can Accounts Be Frozen Because of Terrorism Financing or International Sanctions?

Yes, under separate statutory regimes.

Law No. 6415 on the Prevention of Financing of Terrorism provides mechanisms for freezing assets.

Law No. 7262 also provides for implementation in Türkiye of certain United Nations Security Council sanctions relating to proliferation financing.

For example, Law No. 7262 permits qualifying assets in Türkiye to be frozen through decisions published in the Official Gazette within the statutory sanctions framework.

This is very different from:

• an ordinary debt attachment;
• a bank’s internal compliance check;
• or a seven-business-day MASAK transaction postponement.

The legal challenge must therefore target the specific freezing decision.

Can a Foreign Customer’s Account Be Blocked Merely Because of Their Country of Origin?

Not automatically.

However, banks are required to use risk-based compliance systems, and MASAK regulations expressly recognise country risk as one relevant category in anti-money-laundering risk management.

A customer connected with a higher-risk jurisdiction may therefore face:

• enhanced documentation requests;
• closer transaction monitoring;
• sanctions screening;
• or stricter source-of-funds examination.

But these compliance controls should not be confused with a legal confiscation of property based merely on nationality.

What If the Bank Says Only “Compliance Review” and Gives No Legal Order?

Then the customer should ask the bank in writing to clarify, to the extent legally possible:

1. whether the account itself is restricted or only a specific transaction;
2. whether the restriction arises from a court or enforcement order;
3. whether an enforcement-office file exists;
4. whether a tax attachment exists;
5. whether additional customer documents are required;
6. and what actions the customer can take to restore ordinary banking access.

The bank may not be allowed to disclose whether a suspicious transaction report was made.

But this does not prevent the customer from requesting practical information necessary to comply with document requirements or identify a judicial attachment.

Can the Bank Keep a Compliance Restriction in Place Indefinitely Without Explanation?

The answer depends on the legal basis.

If the restriction is based on a valid judicial, enforcement or administrative decision, the bank generally must follow that decision until it is lifted or modified.

If the issue is purely an internal banking restriction, the customer may challenge whether the bank has properly applied its contractual and regulatory powers.

A long-lasting unexplained restriction can raise contractual, banking-law and ultimately property-right concerns depending on the circumstances.

The Constitutional Court’s property-right jurisprudence demonstrates that prolonged financial restrictions must remain proportionate and legally justified.

Can a Foreigner Complain to BDDK About a Bank Account Block?

Potentially, yes—but BDDK is not the correct remedy for every type of block.

BDDK provides an electronic complaint mechanism concerning institutions under its supervision.

Its official guidance also directs individual customers toward the relevant individual customer arbitration committees for eligible disputes.

However:

BDDK cannot simply cancel a court seizure order.

Nor can it ordinarily override:

• an enforcement-office attachment;
• a tax authority attachment;
• or a valid statutory asset-freezing decision.

BDDK complaints are most useful where the dispute concerns the bank’s own conduct.

Can a Foreigner Apply to the Türkiye Bankalar Birliği Individual Customer Arbitration Committee?

For qualifying individual banking disputes, yes.

The Türkiye Bankalar Birliği Bireysel Müşteri Hakem Heyeti examines disputes between individual customers and member banks concerning banking services.

The customer must first apply to the bank.

TBB states that ordinary bank-response time is generally 30 days and that an application to the committee can follow according to the applicable procedure.

The service is available to natural persons for individual banking matters rather than commercial disputes.

For 2026, TBB states that banks are required to comply with committee decisions up to TRY 51,158, subject to the committee framework.

Participation-bank customers have a similar individual customer arbitration mechanism through the Türkiye Katılım Bankaları Birliği.

Again, these mechanisms are aimed at bank-customer disputes.

They do not replace criminal-procedure objections to a judicial seizure.

What Documents Should Be Prepared to Remove a Bank Account Block?

The answer depends on the type of restriction, but useful documents often include:

• passport;
• residence permit or residence documentation;
• foreign identity number;
• tax number;
• Turkish address document;
• foreign bank statements;
• SWIFT records;
• employment contract;
• payslips;
• company financial records;
• shareholder documentation;
• invoices;
• sales agreements;
• property documents;
• inheritance certificate;
• loan contracts;
• tax returns;
• proof of debt payment;
• enforcement-file documents;
• court decisions;
• prosecutor or criminal court decisions;
• and correspondence from the bank.

For large international transactions, the best documentation package usually explains both:

source of funds

and

purpose of funds.

Example 1: USD 500,000 Arrives from Abroad and the Transfer Is Stopped

A foreign customer receives USD 500,000 from a foreign company.

The customer normally maintains only small personal balances.

The bank asks:

“What is the purpose and source of this payment?”

This may simply be a compliance review.

The customer may resolve the issue by providing:

• share sale agreement;
• dividend resolution;
• tax records;
• foreign bank statements;
• and company documents.

This situation should not automatically be described as “MASAK confiscated my money.”

Example 2: A Seven-Business-Day MASAK Transaction Suspension

A foreign customer attempts a large outgoing transfer.

The bank identifies serious suspicious indicators and follows the statutory reporting process.

The transaction is temporarily suspended.

Article 19/A permits postponement for up to seven business days within the statutory framework.

If no further measure follows, the temporary mechanism itself does not authorise indefinite suspension.

If a judicial seizure is subsequently issued, however, the legal position changes.

Example 3: Account Frozen in a Fraud Investigation

A foreign businessperson becomes a suspect in a large fraud investigation.

The prosecutor’s file alleges that proceeds of the offence entered the person’s Turkish bank account.

A judicial seizure order is issued under Article 128.

The correct response is not merely a complaint to the bank.

The legal team must obtain the criminal file information and challenge the seizure through the appropriate criminal-procedure remedy, demonstrating issues such as:

• lawful source;
• lack of connection with the offence;
• excessive scope;
• or proportionality.

Example 4: Bank Account Attached for Unpaid Private Debt

A foreign homeowner loses a Turkish civil case and owes TRY 400,000.

The creditor initiates enforcement proceedings.

A bank attachment is served.

The bank restricts the amount in the account.

The foreign debtor must address the enforcement file.

The branch manager cannot simply “remove the block.”

Example 5: Tax E-Haciz

A foreign shareholder discovers that funds in a Turkish account are blocked.

Investigation reveals a public debt pursued under Law No. 6183.

The correct response may require:

• checking the underlying payment order;
• identifying why personal liability was asserted;
• challenging an unlawful assessment or collection procedure;
• or paying/resolving the public debt.

This is a tax/public-debt dispute rather than a MASAK case.

Example 6: The Bank Requests an Updated Passport

A foreign customer’s passport has expired.

The bank restricts certain operations until updated customer information is supplied.

The customer produces:

• new passport;
• tax number;
• residence information;
• and requested forms.

The restriction is then reviewed internally.

This is fundamentally different from an enforcement attachment.

Example 7: Customer Says “The Bank Won’t Tell Me Why”

A foreign customer receives only a vague statement from the bank:

“Your transaction is under review.”

This may occur partly because suspicious transaction reporting is confidential under Law No. 5549.

The customer should nevertheless request in writing:

• what documents can be submitted;
• whether there is a court/enforcement attachment visible to the bank;
• whether the restriction is transaction-specific;
• and whether additional KYC information is required.

Frequently Asked Questions

Can a foreigner’s bank account be frozen in Türkiye?

Yes. Foreign bank accounts can be affected by banking compliance reviews, enforcement attachments, public-debt e-haciz, criminal seizure orders, statutory asset freezes and other lawful measures.

Can a bank freeze an account simply because the customer is foreign?

Foreign nationality alone is not an independent legal ground for confiscation. However, anti-money-laundering risk assessment can take country, customer, service and transaction risk into account.

Can the bank ask where my money came from?

Yes. Banks are subject to customer-identification, monitoring and suspicious-transaction obligations.

Do I have to prove the source of my foreign transfer?

Where the bank reasonably requests documentation within its compliance obligations, failing to explain a substantial or unusual transfer can prevent or delay completion of the transaction.

What is MASAK?

MASAK is Türkiye’s Financial Crimes Investigation Board.

Does a MASAK report mean I committed a crime?

No. A suspicious transaction report is not a conviction and does not itself prove criminal conduct.

Can the bank tell me whether it reported me to MASAK?

Generally no. The law prohibits disclosure of the fact that a suspicious transaction report has been made, except in the statutory circumstances.

How long can a MASAK transaction postponement last?

Article 19/A provides a temporary postponement mechanism of up to seven business days.

Does that mean every MASAK-related block automatically disappears after seven business days?

No. A separate judicial or statutory measure may subsequently be imposed.

Can a Turkish criminal court seize my bank accounts?

Yes. Article 128 expressly includes accounts at banks and other financial institutions where its statutory conditions are satisfied.

Can I challenge a criminal seizure?

Yes. The appropriate objection procedure must be determined from the decision. The general CMK objection period is currently two weeks unless a special rule applies.

Can a creditor freeze my Turkish bank account?

A bank account can be attached through Turkish enforcement proceedings.

Can the Turkish tax authority freeze my account?

Yes. Electronic attachment can be used for qualifying public debts under Law No. 6183 Article 79.

Is tax e-haciz the same as MASAK?

No. They are completely different legal mechanisms.

Can I remove a block by going to the bank branch?

Only if the restriction is within the bank’s own control. A branch normally cannot remove a judicial, enforcement or tax authority attachment without the competent authority’s release.

Can BDDK remove my court-ordered block?

No. BDDK is a banking regulator and complaint authority; it does not replace the criminal court, enforcement office or tax authority.

Can I complain about the bank itself?

Yes. First apply to the bank. Depending on the dispute, BDDK, TBB or TKBB complaint/arbitration mechanisms may then be considered.

Can I deal with the process after leaving Türkiye?

Potentially yes. A foreign customer may appoint a Turkish lawyer through an appropriate power of attorney to investigate the legal basis of the restriction and pursue the relevant remedy.

How Can a Foreigner Determine Why the Account Is Blocked?

A structured investigation is far more effective than repeatedly calling the bank.

Step 1: Ask the Bank in Writing

Request confirmation of whether:

• there is an enforcement attachment;
• there is a tax attachment;
• there is a court/prosecutorial restriction;
• additional documents are required;
• or the problem is an internal banking restriction.

The bank may be unable to disclose suspicious transaction reporting information.

Step 2: Obtain Any Enforcement File Details

If an icra attachment exists, determine:

• enforcement office;
• file number;
• creditor;
• amount;
• and date.

Step 3: Check Public Debts

Determine whether the restriction arises from a tax/public debt.

Step 4: Determine Whether a Criminal Investigation Exists

Where Article 128 or another criminal measure is involved, obtain the relevant investigation/court information through proper legal channels.

Step 5: Prepare Source-of-Funds Documentation

If the issue is compliance-related, prepare a complete transaction explanation.

Step 6: Do Not Mix the Procedures

Do not file an administrative complaint against MASAK when the real issue is a private enforcement attachment.

Do not apply to an enforcement court when the restriction is simply a bank security verification.

Correct classification saves significant time.

How Can a Lawyer Help Remove a Foreign Customer’s Bank Account Block?

A banking-block file may require work across several legal areas.

A lawyer can first determine whether the issue arises from:

• the bank;
• MASAK;
• a criminal prosecutor or judge;
• an enforcement office;
• the Revenue Administration;
• or another public authority.

The lawyer may then:

• request written information;
• obtain enforcement-file records;
• challenge a criminal seizure;
• submit evidence concerning lawful source of funds;
• apply for release of an attachment;
• challenge an unlawful public-debt collection measure;
• prepare a complaint against the bank;
• or pursue damages where an unlawful restriction has caused proven financial loss.

The most important part of the process is identifying the correct defendant or authority.

Can Compensation Be Claimed for a Wrongful Bank Account Block?

Potentially, depending on the cause of the restriction.

For example, if a bank independently applies an unlawful restriction in breach of its contractual duties and the customer proves financial loss, contractual liability may be examined.

If a public authority imposes an unlawful measure, a different compensation regime may apply.

If a criminal protective measure was lawful when imposed but later becomes unjustifiably prolonged, constitutional property-right principles may become relevant.

The Constitutional Court has expressly recognised that prolonged restrictions on bank funds can violate the right to property where the individual is forced to bear a disproportionate burden.

However, compensation is not automatic simply because the customer was temporarily unable to use funds.

The unlawfulness, fault where required, causation and actual damage must be examined.

What Should a Foreign Customer Never Do After Discovering a Block?

The customer should avoid:

• asking another person to secretly receive the funds;
• transferring through multiple accounts to evade controls;
• submitting false invoices;
• creating fictitious loan agreements;
• giving inconsistent explanations;
• opening multiple accounts merely to bypass a legal measure;
• withdrawing through another person where a judicial seizure applies;
• or deleting transaction records.

These actions can turn an ordinary documentation problem into a much more serious legal issue.

Transparency and documentary consistency are usually the best strategy where the funds have a legitimate origin.

A Practical Checklist for Foreigners with a Blocked Turkish Bank Account

When a foreign customer discovers that funds cannot be used, the following checklist should be followed:

1. Do not assume the block is MASAK-related.
2. Obtain written information from the bank where legally possible.
3. Determine whether the entire account or only one transaction is restricted.
4. Identify any enforcement-office file.
5. Check for tax or other public debt.
6. Determine whether a criminal investigation or court order exists.
7. Update passport, tax and address information if requested.
8. Prepare source-of-funds documentation.
9. Preserve all SWIFT and bank records.
10. Do not attempt to circumvent the restriction using another person.
11. Challenge judicial measures within the applicable deadline.
12. Request removal once the debt or legal basis has ended.
13. If the problem is bank-originated, make a formal written complaint to the bank.
14. Consider TBB/TKBB or BDDK procedures where appropriate.
15. Seek immediate legal review where substantial amounts are blocked.

Conclusion: A Foreigner’s Bank Account Can Be Blocked in Türkiye, but the Legal Reason Determines How It Can Be Removed

A foreign national’s Turkish bank account is not immune from legal restrictions.

But neither can money simply be confiscated merely because the account holder is foreign.

A Turkish bank account can be restricted for many fundamentally different reasons.

The first category is bank compliance and security controls.

Banks are required to operate risk-based anti-money-laundering systems and continuously monitor customers and transactions.

The Turkish compliance framework recognises customer risk, country risk and service risk, meaning that substantial or unusual international transactions can legitimately lead to additional verification.

In this category, the solution is usually documentary.

The foreign customer may need to establish:

• identity;
• address;
• source of funds;
• commercial purpose;
• relationship with the sender;
• or reason for the transaction.

The second category is a MASAK-related suspicious transaction process.

A suspicious transaction report does not itself mean that the account holder is guilty of money laundering.

Nor is the bank normally permitted to tell the customer that a suspicious transaction report has been made.

Where Article 19/A of Law No. 5549 applies, a particular transaction can be temporarily postponed for up to seven business days while the matter is analysed.

This seven-business-day mechanism should not be described as an unlimited MASAK account freeze.

If a longer restriction exists, the lawyer should determine whether another legal measure has subsequently been imposed.

The third category is criminal seizure.

Article 128 of the Criminal Procedure Code expressly allows seizure of accounts at banks and other financial institutions where there is strong suspicion based on concrete evidence concerning the relevant offence and criminal proceeds.

This type of restriction must be challenged within the criminal-procedure framework.

Going repeatedly to the branch or complaining to a call centre cannot substitute for a legal objection against a judicial seizure.

The fourth category is an ordinary enforcement attachment.

A private creditor can attach a debtor’s bank receivable through Turkish enforcement proceedings under the Enforcement and Bankruptcy Law.

The customer must identify the enforcement file and deal with:

• the underlying debt;
• the validity of the proceedings;
• or the attachment itself.

The fifth category is e-haciz for public debts.

Law No. 6183 permits electronic attachment of bank receivables for qualifying public debts, and the Revenue Administration actively uses electronic attachment systems with banks.

The foreign account holder must then address the relevant tax or public-debt file rather than MASAK.

A sixth, exceptional category includes statutory asset-freezing regimes relating to terrorism financing or international sanctions.

These measures have their own legal bases and challenge procedures.

Foreign bank customers should therefore avoid using the word “bloke” as though it identifies the legal problem.

Instead, the critical questions are:

Who imposed the restriction?

Which authority sent the bank the instruction?

Is the restriction on the account or only a single transaction?

Is there a criminal investigation?

Is there an icra file?

Is there a tax debt?

Has the bank requested additional customer information?

Is Article 19/A being applied?

Is there a separate judicial seizure order?

How long has the restriction continued?

What evidence proves the lawful source of the funds?

Only after these questions are answered can the appropriate legal procedure for removing the bank account block be selected.

The proportionality of a financial restriction should also not be overlooked.

The Turkish Constitutional Court has recognised that prolonged restrictions on bank funds can interfere with the constitutional right to property and that even measures serving legitimate public purposes can become disproportionate when they continue excessively without adequate justification.

Therefore, neither a customer nor a bank should approach a blocked account with the assumption that:

“Once the account is blocked, nothing can be done.”

There is usually a legal route.

The decisive issue is identifying the correct one.

Legal Basis

The principal Turkish legislation relevant to blocked bank accounts of foreign nationals includes:

Law No. 5549 on Prevention of Laundering Proceeds of Crime

Article 4 – Suspicious Transaction Reporting

Banks and other obliged institutions must report qualifying suspicious transactions. The fact that a report has been made cannot generally be disclosed to the transaction parties or others outside the statutory exceptions.

Article 19/A – Postponement of Transactions

Permits qualifying transactions suspected of connection with money laundering or terrorism financing to be postponed for up to seven business days for analysis and verification.

Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism

Regulates:

• customer identification;
• suspicious transaction obligations;
• customer information;
• and other anti-money-laundering measures applicable to banks and other obliged institutions.

Regulation on Compliance Programmes Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism

Requires banks to operate risk-based compliance programmes including:

• customer risk;
• country risk;
• service risk;
• monitoring;
• control;
• internal audit;
• and compliance systems.

Criminal Procedure Code No. 5271

Article 128 – Seizure of Immovable Property, Rights and Receivables

Expressly permits seizure of bank and financial institution accounts where the statutory conditions relating to specified offences and criminal proceeds are satisfied.

Articles 267–268 – Objection

Regulate objections against judicial decisions. The general objection period is currently two weeks from learning of the decision, unless a different statutory period applies.

Enforcement and Bankruptcy Law No. 2004

Article 89 – Attachment of Claims and Property Held by Third Parties

Provides the framework under which a debtor’s claims and qualifying assets held by a third party—including banks—can become subject to enforcement attachment.

Law No. 6183 on Collection Procedure of Public Receivables

Article 79 – Attachment of Third-Party Rights and Receivables

Forms the legal basis for electronic attachment of qualifying assets and receivables held by banks for collection of public debts.

Law No. 6415 on Prevention of Financing of Terrorism and Law No. 7262

Provide statutory mechanisms for freezing assets in terrorism-financing and specified international-sanctions contexts.

Constitutional Property Protection

Money held in a bank account constitutes an economic asset protected within the scope of property rights.

In Ayşe Sabahat Gencer, B. No. 2018/34950, the Turkish Constitutional Court held that a bank-account-related block continuing for more than five years without sufficient justification imposed an excessive individual burden and violated the constitutional right to property.

The judgment demonstrates an important principle:

A legally imposed financial restriction must remain lawful, necessary and proportionate throughout the period in which it continues.

Disclaimer: This article provides general information concerning Turkish banking, anti-money-laundering, criminal procedure, enforcement and tax law. It does not constitute individual legal advice. A bank account described as “blocked” may actually be subject to several completely different legal measures. The bank correspondence, account records, enforcement files, public debts, court or prosecutor decisions and source-of-funds documentation should be examined before determining the appropriate legal remedy.