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A foreign entrepreneur may legally establish a company in Türkiye with 100% foreign ownership.

The company may be:

• properly registered with the Turkish Trade Registry;
• registered with the tax authorities;
• fully capitalized;
• operating from a legitimate Turkish address; and
• legally entitled to conduct its business.

Yet the founder may still hear the following from a Turkish bank:

“We cannot open an account for your company.”

This can be frustrating.

Foreign founders often assume that because Turkish law permits them to own the company, Turkish banks must also open an account for it.

That assumption is incorrect.

Company formation and bank account approval are separate processes.

A Turkish Trade Registry determines whether a company has been validly incorporated.

A bank must separately determine whether it is willing and legally able to establish a banking relationship with that company under:

• customer identification rules;
• anti-money laundering legislation;
• counter-terrorist financing requirements;
• sanctions controls;
• beneficial ownership requirements;
• internal risk policies; and
• correspondent banking restrictions.

Under Turkish AML legislation, banks are required to understand both the customer and the economic purpose of the banking relationship.

MASAK regulations specifically require financial institutions, particularly in risk-based onboarding, to obtain information concerning matters such as:

• the purpose and nature of the business relationship;
• source of the assets;
• source of customer funds;
• expected transaction volume; and
• expected number of transactions.

Therefore, when a Turkish bank refuses a foreign-owned company, the reason is often not:

“Foreigners cannot own Turkish companies.”

The real reason may instead be:

“The bank cannot sufficiently understand or accept the compliance risk associated with this customer.”

This article explains the most common reasons for rejection and how foreign founders can reduce the risk of banking problems.

1. Can a Turkish Bank Refuse a Foreign-Owned Company?

In practice, yes.

Being a valid Turkish company does not automatically guarantee acceptance by every bank.

Banks establish their own customer acceptance policies within the limits of banking, AML, sanctions and other applicable legislation.

A bank may therefore decide that:

• the customer cannot be sufficiently identified;
• the beneficial ownership structure is unclear;
• source of funds cannot be verified;
• sanctions risk is too high;
• the business model is difficult to understand;
• expected transactions do not match the business;
• the company operates in a high-risk industry; or
• the relationship exceeds the bank’s internal risk appetite.

This is why one Turkish bank may reject a company while another institution may agree to onboard it after obtaining additional documentation.

2. Foreign Ownership Alone Is Usually Not the Real Problem

Foreign founders should first understand an important point:

Foreign ownership itself does not generally make the company illegal or ineligible for banking.

Official Turkish investment guidance expressly anticipates foreign shareholders and foreign directors and requires potential Turkish tax identification numbers for non-Turkish shareholders and board members.

That potential tax identification number is specifically used in connection with opening a bank account for company capital during incorporation.

Therefore, the Turkish investment system clearly contemplates foreign-owned companies using Turkish banks.

The issue is usually the risk profile associated with the individual company, not the simple fact that the shareholder holds a foreign passport.

3. Reason No. 1: The Bank Cannot Identify the Ultimate Beneficial Owner

One of the most common problems is an unclear ownership structure.

The shareholder appearing in the Turkish Trade Registry may not be the person who ultimately owns the company.

For example:

Turkish Startup A.Ş.

owned by:

Netherlands Holding B.V.

which is owned by:

Luxembourg Holding S.A.

which is owned by:

Cayman Investment Fund

The bank will normally want to understand who ultimately controls the group.

MASAK’s customer due diligence framework requires beneficial ownership identification when establishing continuing business relationships with commercial registry entities.

The bank may therefore request:

• corporate registry records from each jurisdiction;
• shareholder registers;
• organizational charts;
• certificates of incumbency;
• board information;
• trust information;
• fund information; and
• identification documents for controlling individuals.

If the ownership chain cannot be clearly documented, the bank may decline the relationship.

4. What Is an Ultimate Beneficial Owner?

The Ultimate Beneficial Owner, often called the UBO, is generally the natural person or persons who ultimately own or control a legal entity.

For example:

Turkish Company

100% owned by:

UK Holding Ltd.

UK Holding Ltd. is owned:

Founder A – 70%

Founder B – 30%

The bank may treat Founder A and Founder B as the individuals relevant to ultimate beneficial ownership analysis.

Simply providing the UK company’s certificate of incorporation may therefore not be sufficient.

5. Why Complex Holding Structures Create Banking Problems

Foreign entrepreneurs often structure businesses through:

• UK companies;
• Delaware corporations;
• Dutch holdings;
• Luxembourg entities;
• UAE companies;
• BVI companies;
• Cayman structures; or
• investment funds.

These structures may be completely lawful.

But they create additional KYC work.

A compliance team may have to determine:

1. whether each foreign entity genuinely exists;
2. who controls it;
3. whether the corporate documents are authentic;
4. whether any shareholders are sanctioned;
5. whether nominee arrangements exist;
6. whether trusts are involved; and
7. whether the economic owner can actually be identified.

A simple structure:

Foreign Founder → Turkish Company

is naturally easier for a bank to understand than:

Foreign Founder → Trust → Offshore HoldCo → European HoldCo → Turkish Company.

Complexity does not mean illegality.

It does mean additional compliance risk.

6. Reason No. 2: Source of Funds Cannot Be Explained

Another major problem arises when the foreign investor cannot clearly demonstrate where the money entering the company originates.

Suppose a founder tells the bank:

“Once you open the account, I will transfer USD 2 million.”

The bank may ask:

Where did you obtain the USD 2 million?

Possible legitimate explanations may include:

• proceeds from another company;
• salary savings;
• sale of real estate;
• sale of securities;
• inheritance;
• venture capital investment;
• company dividends;
• shareholder loan; or
• sale of a previous startup.

The important issue is documentation.

MASAK’s risk-based customer identification rules expressly require information about the source of the assets involved and the source of the customer’s funds in relevant onboarding processes.

7. Which Documents Can Prove Source of Funds?

Depending on the circumstances, useful documents may include:

• foreign bank statements;
• audited company financial statements;
• tax returns;
• salary records;
• share sale agreements;
• real estate sale agreements;
• inheritance documents;
• dividend resolutions;
• investment agreements;
• share subscription agreements;
• loan agreements; and
• documentary evidence of the underlying transaction.

The larger the transaction, the more likely the bank is to request substantial evidence.

A EUR 20,000 founder investment and a EUR 20 million incoming investment will not generally receive the same level of review.

8. Source of Funds and Source of Wealth Are Different

Foreign founders should also understand the difference between:

Source of Funds

and

Source of Wealth.

Source of funds asks:

Where did this particular payment come from?

For example:

“EUR 500,000 was transferred from the founder’s account at Bank X.”

Source of wealth asks:

How did the founder obtain their overall wealth?

For example:

“The founder sold a software business for EUR 8 million in 2024.”

Higher-value relationships may cause banks to investigate both questions.

9. Reason No. 3: The Company Has No Clear Business Model

A bank must understand what the customer actually does.

An application stating:

“Technology, investment, consulting, import-export, online services, software, marketing and international trade”

does not necessarily provide a meaningful explanation.

The bank may wonder:

• What product does the company sell?
• Who pays the company?
• Why will money enter Türkiye?
• Where will money be sent?
• What currencies will be used?
• How many payments are expected?

A clearer description would be:

“The company develops B2B logistics software. Customers are German and Dutch logistics companies paying monthly SaaS subscription fees in EUR. The company employs developers in Türkiye and pays AWS and other technology suppliers abroad.”

The second explanation allows a bank to understand the expected payment flow.

10. Reason No. 4: Expected Banking Activity Does Not Match the Business

Banks compare the customer’s declared activity with expected transactions.

Suppose a newly established software company expects:

• thousands of daily payments from individuals;
• transfers from twenty countries;
• crypto exchange payments;
• large cash transactions; and
• USD 10 million monthly volume.

That profile may not look like an ordinary software development business.

MASAK’s suspicious transaction guidance identifies situations where transactions lack an apparent economic or commercial purpose or do not correspond with the customer’s known activity as relevant risk indicators.

The bank may therefore request additional information or reject the relationship.

11. Reason No. 5: Payments Will Come From High-Risk Countries

Country exposure is a major component of banking compliance.

MASAK’s guidance specifically requires enhanced attention to transactions involving jurisdictions regarded as presenting increased terrorism financing or AML risks.

Its suspicious transaction indicators also identify financial transfers involving risky jurisdictions without a reasonable commercial basis.

Therefore, the bank may ask:

• Which countries will send money?
• Which countries will receive money?
• Why are those countries commercially relevant?
• Who are the counterparties?
• What goods or services are involved?

A business with clear commercial links to Germany, France and the UK may produce one risk assessment.

A business receiving unexplained payments from unrelated individuals across several high-risk jurisdictions may produce another.

12. Reason No. 6: Sanctions Exposure

Sanctions screening is particularly important in international banking.

A company may face enhanced review if:

• a shareholder appears on a sanctions list;
• a beneficial owner is sanctioned;
• the company trades with sanctioned entities;
• payments involve sanctioned jurisdictions;
• goods are potentially subject to export restrictions; or
• a correspondent bank could reject transactions.

Even where Turkish law permits the company to exist, international banking can involve:

• UN sanctions;
• Turkish sanctions;
• correspondent bank restrictions;
• US sanctions exposure;
• EU sanctions exposure; and
• internal international bank policies.

A bank may therefore decide that the commercial benefit of the relationship does not justify the sanctions risk.

13. Why Correspondent Banks Matter

Foreign entrepreneurs sometimes ask:

“If Türkiye does not prohibit the transaction, why won’t the Turkish bank process it?”

Because international transfers may involve other banks.

For example:

A USD payment from Türkiye may pass through a US correspondent bank.

A EUR payment may involve a European correspondent bank.

Those institutions can apply their own sanctions and compliance policies.

The Turkish bank may therefore consider not only Turkish law but also whether its international payment infrastructure could be affected.

This is particularly important for businesses trading with higher-risk jurisdictions.

14. Reason No. 7: The Shareholder Is a Politically Exposed Person

Foreign shareholders or beneficial owners who are politically exposed may face enhanced compliance review.

A politically exposed person relationship does not necessarily mean the account must be rejected.

However, banks may require:

• additional source-of-wealth information;
• senior management approval;
• enhanced transaction monitoring; and
• more extensive documentation.

The same may apply to close family members or individuals closely connected with politically exposed persons depending on the applicable framework.

15. Reason No. 8: The Company Operates in Crypto

Crypto-related businesses frequently face more extensive banking scrutiny.

In September 2025, MASAK updated both its Crypto Asset Service Providers Guide and its Enhanced Measures Guide.

The updated framework emphasizes matters including:

• customer identification;
• remote identification;
• enhanced measures;
• crypto transfer rules;
• suspicious transaction reporting; and
• risk-based AML controls.

Therefore, a company that:

• operates a crypto exchange;
• provides custody;
• transfers crypto assets;
• acts as a crypto broker;
• receives regular exchange payments; or
• operates crypto-related financial infrastructure

may be treated as higher risk by a bank.

16. Describing a Crypto Company as “Software” Can Make Things Worse

A founder may believe the easiest strategy is to tell the bank:

“We are simply a software company.”

But if the bank later sees transfers from:

• crypto exchanges;
• wallet service providers;
• crypto brokers; or
• blockchain platforms,

the inconsistency itself may become a compliance concern.

Transparency is usually preferable.

The bank should understand the actual business model before the account becomes operational.

17. Reason No. 9: The Company May Be Conducting a Regulated Financial Activity

Fintech companies face similar problems.

A company may describe itself as:

“technology startup”

while its actual activities involve:

• payment services;
• electronic money;
• money transfers;
• payment initiation;
• financial intermediation;
• lending;
• investment services; or
• crypto asset services.

The bank may ask:

Does this company require TCMB, BDDK, SPK or another regulatory licence?

If the regulatory position is unclear, the bank may decline onboarding until the company proves that:

• no licence is required; or
• the required licence has been obtained.

18. Reason No. 10: The Foreign Corporate Documents Are Incomplete

Foreign legal entity shareholders require more documentation than individual founders.

Official investment guidance states that foreign corporate shareholders may need documentation showing:

• company existence;
• current corporate status;
• authorized signatories;
• corporate approval for establishing the Turkish entity; and
• related representation information.

Documents issued abroad generally need the appropriate:

• notarization;
• apostille or consular authentication; and
• official Turkish translation.

A bank may similarly require correctly authenticated foreign documents during onboarding.

Missing apostilles or outdated registry documents can delay or prevent account opening.

19. Reason No. 11: Representation Authority Is Unclear

The bank must understand who has authority to act for the Turkish company.

For example:

Who can:

• open the bank account?
• sign the banking agreement?
• initiate transfers?
• use internet banking?
• obtain company credit cards?
• borrow money?
• create payment instructions?

If the Trade Registry records indicate:

Director A and Director B jointly

but only Director A applies to open the account, the bank may refuse to complete onboarding.

The corporate representation structure must therefore be consistent with the application.

20. Reason No. 12: The Bank Cannot Verify the Foreign Representative

Historically, foreign representatives sometimes faced practical difficulty because Turkish banking systems were designed primarily around Turkish identity documents and local verification infrastructure.

A significant regulatory change occurred on June 27, 2026.

MASAK announced that General Communiqué No. 32 amended the remote identification rules to permit remote identification of:

• foreign-national natural persons; and
• foreign-national representatives of legal entities registered in the Turkish Trade Registry.

This may reduce some operational barriers.

However, remote identification does not mean that banks are required to accept every foreign applicant.

21. Remote Identification Does Not Eliminate KYC

The opposite may sometimes be true.

Remote identification requires a risk-based assessment.

MASAK’s rules state that institutions conducting remote identification must obtain information including:

• account purpose;
• products requested;
• source of assets;
• source of customer funds;
• average income;
• expected monthly transaction volume; and
• expected number of transactions.

The institution may also apply enhanced measures including:

• requesting additional information;
• requiring senior management approval;
• increasing transaction monitoring;
• imposing transaction limits; and
• requiring initial payment from another regulated financial institution.

Remote onboarding therefore makes identification easier but does not remove compliance requirements.

22. Reason No. 13: The Company Appears to Exist Only on Paper

Banks may be cautious about newly incorporated companies with no obvious economic activity.

Potential red flags may include:

• no website;
• no employees;
• no office activity;
• no business plan;
• no customer contracts;
• no invoices;
• no explanation of intended activity;
• large incoming transfers immediately after incorporation.

None of these factors alone necessarily means wrongdoing.

But together they may create a risk profile that the bank does not wish to accept.

23. Can a Newly Established Company Still Open an Account?

Yes.

Every genuine startup begins with limited operational history.

The solution is not to manufacture artificial turnover.

The solution is to provide a credible explanation.

A startup can provide:

• pitch deck;
• founders’ CVs;
• signed investment agreements;
• company website;
• business plan;
• customer pipeline;
• supplier contracts;
• development agreements;
• funding documentation; and
• forecast transaction flows.

This helps the bank understand why the company exists.

24. Reason No. 14: Capital Comes From an Unrelated Third Person

Imagine a Turkish startup owned by a German founder.

But the initial EUR 500,000 payment arrives from:

an unrelated individual in another country.

The bank may ask:

• Who is this person?
• Why are they sending money?
• Is this a loan?
• Is this an investment?
• Are they the real beneficial owner?
• Why are they not a registered shareholder?

Third-party payments frequently generate more questions than direct transfers from the shareholder’s own bank account.

25. Use Correct Payment Descriptions

A founder should not randomly write:

“transfer”

on significant payments.

The payment description should reflect the legal transaction.

Examples may include:

• capital contribution;
• share subscription payment;
• shareholder loan;
• investment payment;
• invoice number;
• service agreement payment; or
• intercompany loan repayment.

The accounting documentation should tell the same story.

Mismatch between banking records and company accounting can create future problems.

26. Reason No. 15: The Founder Mixes Personal and Corporate Funds

A common startup mistake is using the founder’s personal account for company transactions.

For example:

Customer → Founder’s Personal Account

Founder → Company Account

This creates unnecessary questions.

The bank may want to know:

• why customers are paying the shareholder personally;
• whether the income belongs to the founder or company;
• whether tax obligations are being avoided;
• whether the company is being used merely as a pass-through vehicle.

Corporate income should generally flow directly through the company’s banking infrastructure.

27. Reason No. 16: Excessive Cash Activity

A foreign-owned company claiming to operate an online software business but regularly depositing large amounts of physical cash may appear inconsistent.

Cash-intensive business models naturally create higher AML concerns because tracing the original source of cash can be more difficult.

The bank may therefore ask for:

• invoices;
• sales records;
• customer information;
• tax records; and
• explanations for the cash activity.

28. Reason No. 17: The Company Is a Pass-Through Vehicle

Banks can become suspicious where a company appears simply to receive money and immediately send it elsewhere.

For example:

EUR 1 million enters Monday.

EUR 990,000 leaves Tuesday.

No clear commercial activity exists.

No employees.

No inventory.

No service records.

No business explanation.

This may look less like an operating company and more like a payment conduit.

Such transaction profiles are likely to attract compliance attention.

29. Reason No. 18: Payments From Large Numbers of Unrelated Individuals

Suppose a company claims to provide:

B2B consulting services

but receives thousands of payments from unrelated individuals.

The payment structure does not match the stated business model.

This can cause banks to ask whether the company is actually conducting:

• payment collection;
• marketplace activity;
• financial services;
• gaming;
• crypto activity;
• crowdfunding; or
• another undisclosed business.

Foreign founders should ensure that corporate activities and bank transactions tell the same story.

30. Reason No. 19: Online Gambling or Similar High-Risk Exposure

Businesses linked directly or indirectly with:

• gambling;
• betting;
• unlicensed gaming;
• payment collection for gambling operators; or
• high-risk online entertainment

may face serious compliance concerns.

Even where the founder describes the company as:

marketing or software,

the bank may examine the underlying customers.

Providing services to high-risk industries can affect the company’s banking risk profile.

31. Reason No. 20: High-Risk Merchant Categories

Some banks may treat industries such as:

• adult entertainment;
• certain gaming businesses;
• money services;
• crypto;
• financial intermediaries;
• certain high-risk e-commerce;
• defence-related businesses; or
• complex commodity trading

with enhanced caution.

The decision may depend significantly on the specific bank’s risk appetite.

A business that one bank accepts may be outside another bank’s customer strategy.

32. Why Oil, Gas and Commodity Trading Companies May Face Questions

International commodity trading often involves:

• substantial transaction amounts;
• multiple jurisdictions;
• intermediaries;
• shipping companies;
• trade finance;
• sanctions exposure;
• letters of credit; and
• changing counterparties.

A newly established company claiming it expects USD 50 million of oil trades without:

• contracts;
• industry experience;
• financing;
• supplier relationships; or
• documentary evidence

will naturally receive significant compliance scrutiny.

33. Reason No. 21: The Company Cannot Explain Its Tax Residence or Group Structure

International companies may operate through several jurisdictions.

The bank may ask:

• Where is the parent company resident?
• Where are the founders resident?
• Where is the IP held?
• Which entity invoices customers?
• Why does the Turkish company receive the funds?
• Are related-party payments involved?

Unclear tax and group structures can appear commercially unusual.

They may also create transfer pricing, tax and AML concerns.

34. Reason No. 22: Nominee Shareholders

Banks may examine whether registered shareholders genuinely own the company.

A Turkish nominee shareholder may not make banking easier.

It may instead create another question:

Who is the real owner?

Because MASAK requires beneficial ownership analysis for continuous relationships with companies, the bank may look behind formal ownership.

Foreign founders should therefore avoid unnecessary nominee structures.

35. Reason No. 23: The Bank Does Not Understand the Startup’s Funding Structure

Startups may receive money through:

• equity investment;
• convertible financing;
• shareholder loans;
• SAFE-style arrangements;
• grants;
• venture capital;
• accelerator funding; or
• intercompany financing.

Turkish banks may ask how the funding is legally characterized.

A founder should be able to provide the relevant:

• investment agreement;
• shareholder resolution;
• capital increase documentation;
• loan agreement; or
• other legal instrument.

36. Why Venture Capital Investment Should Be Pre-Notified

Suppose the startup normally has monthly turnover of:

EUR 30,000

and suddenly receives:

EUR 5 million.

Even if the transaction is entirely legitimate, the amount is inconsistent with the existing transaction profile.

Before closing a large investment round, the company should consider providing the bank with:

• signed investment agreement;
• investor identification;
• cap table;
• capital increase documentation;
• board/general assembly resolutions;
• source-of-funds documentation; and
• explanation of the transaction.

This can reduce the risk of the payment being delayed by compliance review.

37. Can the Bank Restrict the Account After Opening?

Yes, account opening is not the end of compliance monitoring.

Banks are required to continue monitoring customer relationships.

MASAK’s framework is based on ongoing customer due diligence and risk-based monitoring.

Remote onboarding rules also expressly permit enhanced monitoring and additional controls where risk requires them.

A bank may therefore later request explanations concerning:

• unusual incoming payments;
• international transfers;
• sudden changes in turnover;
• new counterparties;
• crypto transactions;
• high-risk countries; or
• changes in beneficial ownership.

38. Why Can a Previously Working Account Suddenly Become Restricted?

Possible triggers include:

• major increase in transaction volume;
• new high-risk countries;
• new shareholders;
• change in business model;
• transfers inconsistent with declared activity;
• new sanctions information;
• expired corporate documents;
• updated bank compliance policies;
• suspicious transaction indicators; or
• insufficient response to bank information requests.

Startups should therefore update the bank when major structural changes occur.

39. Can a Bank Ask for New Documents Every Year?

Potentially, yes.

Customer information is not necessarily collected only once.

Banks may periodically update:

• shareholder records;
• beneficial ownership;
• passport information;
• address;
• Trade Registry documents;
• financial statements;
• tax records; and
• business activity information.

Higher-risk customers may be reviewed more frequently.

40. Can the Founder Force the Bank to Explain the Exact AML Reason?

Not necessarily in every case.

Banks are subject to confidentiality obligations concerning suspicious transaction reporting and internal compliance assessments.

Therefore, a bank may provide only a general explanation such as:

• internal policy;
• compliance requirements;
• customer acceptance criteria; or
• inability to establish the relationship.

A lack of a detailed explanation does not necessarily mean no compliance reason exists.

41. What Should a Foreign Founder Do After a Bank Rejection?

The founder should first determine whether the rejection may have resulted from a correctable problem.

Questions to review include:

• Were all foreign corporate documents apostilled?
• Was the UBO structure clear?
• Was source of funds documented?
• Was the company’s business model properly explained?
• Were expected transaction countries disclosed?
• Was crypto exposure disclosed?
• Does the company require a licence?
• Were authorized signatories properly registered?
• Did the bank understand the investment structure?

Correcting the file before approaching another institution can materially improve the next application.

42. Should the Founder Apply to Ten Banks at the Same Time?

Not necessarily.

Submitting ten poorly prepared applications may produce ten rejections.

A better strategy may be:

1. prepare a complete compliance package;
2. identify banks familiar with international companies;
3. approach an appropriate corporate banking branch;
4. explain the business clearly;
5. provide UBO and source-of-funds documentation;
6. answer compliance questions promptly.

Quality of the application is often more important than quantity.

43. What Is a Banking Compliance File?

A foreign-owned company should prepare a centralized file containing:

Corporate Documents

• Trade Registry Gazette;
• articles of association;
• activity certificate;
• tax certificate;
• signature circular;
• representation resolutions.

Foreign Shareholder Documents

• certificates of incorporation;
• foreign commercial registry records;
• certificates of incumbency;
• shareholder registers;
• apostilles;
• translations.

UBO Documents

• ownership chart;
• founder passports;
• shareholder declarations;
• group structure.

Financial Documents

• founder bank statements;
• investor documents;
• source-of-funds evidence;
• financial statements.

Business Documents

• website;
• pitch deck;
• customer agreements;
• supplier agreements;
• invoices;
• business plan.

This file can be used during both onboarding and later compliance reviews.

44. How Should the Business Model Be Explained?

Use a short, factual explanation.

For example:

“The Turkish company develops cybersecurity software for corporate customers. Its shareholders are two Swedish citizens. Initial funding of EUR 400,000 originates from their Swedish personal bank accounts and is documented through shareholder financing agreements. Customers are expected primarily from Sweden, Germany and Türkiye. The company’s monthly transaction volume is expected to remain below EUR 150,000 during the first year. Payments will primarily consist of B2B subscription revenue and operating expenses.”

This tells the bank:

• what the company does;
• who owns it;
• where the money comes from;
• which countries are involved;
• expected transaction size; and
• the commercial reason for the account.

45. Banking Documents Checklist

Before applying, foreign founders should ideally prepare:

• Turkish Trade Registry Gazette
• Articles of association
• Company tax certificate
• Current activity certificate
• Chamber registration
• Signature circular
• Manager or board resolutions
• Representation authority records
• Passports of foreign shareholders
• Turkish tax identification numbers
• Foreign company registry documents
• Apostilles
• Official Turkish translations
• Complete ownership chart
• Ultimate beneficial owner identification
• Source-of-funds explanation
• Source-of-wealth evidence where relevant
• Foreign bank statements
• Investment agreements
• Shareholder loan agreements
• Business plan
• Pitch deck
• Website
• Customer contracts
• Supplier contracts
• Regulatory licences
• Expected monthly turnover
• Expected transaction number
• Currencies to be used
• Countries of incoming payments
• Countries of outgoing payments
• Explanation of any crypto exposure
• Explanation of any fintech activity
• Sanctions review of major counterparties
• Banking power of attorney where relevant

46. Can a Lawyer Help With Bank Account Opening?

Legal counsel can help prepare the company and compliance documentation and identify structural problems before the application.

Assistance may include:

• corporate document review;
• UBO analysis;
• preparation of powers of attorney;
• apostille coordination;
• document translation;
• corporate resolutions;
• source-of-funds documentation;
• banking compliance explanations; and
• regulatory analysis.

However, the final customer acceptance decision remains with the relevant bank.

A lawyer generally cannot guarantee that a bank will approve an account.

47. Does a Turkish Partner Make Banking Easier?

Not automatically.

A foreign founder should not give shares to a Turkish citizen merely because someone says:

“The bank will open the account if you have a Turkish partner.”

The bank is required to understand beneficial ownership.

An artificial Turkish nominee may therefore create rather than solve compliance problems.

The correct solution is usually to improve transparency rather than disguise ownership.

48. Does a Turkish Director Solve the Problem?

Again, not necessarily.

A Turkish manager may help with:

• communication;
• local representation;
• branch visits; and
• operational matters.

But the bank will still identify:

• shareholders;
• ultimate beneficial owners;
• source of funds; and
• actual business activities.

Management nationality does not replace KYC.

49. Does Higher Company Capital Guarantee Banking Approval?

No.

A TRY 10 million capital company can still be rejected if:

• source of funds is unclear;
• beneficial ownership is hidden;
• sanctions risk exists; or
• the business is outside the bank’s risk appetite.

Likewise, a much smaller startup may successfully open an account if its:

• ownership;
• funding;
• activities; and
• transaction model

are transparent.

Capital amount alone is not the decisive factor.

50. Does Having a Work Permit Guarantee Banking Approval?

No.

A founder’s:

• residence permit;
• work permit; or
• Turkish foreign identity number

may simplify identification.

But these documents do not eliminate AML obligations.

The bank must still assess the Turkish company itself.

51. Does Having a Turkish Address Guarantee an Account?

No.

A Turkish office or residential address may assist with identification and demonstrate a genuine connection to Türkiye.

But it does not solve problems involving:

• sanctions;
• source of funds;
• UBO identification;
• regulatory licensing; or
• unexplained transactions.

52. Can the Company Open Accounts With Several Banks?

Generally, yes.

Using multiple banks can be commercially sensible.

For example:

Bank 1: TRY payroll and domestic payments

Bank 2: EUR customer collections

Bank 3: USD investor transactions

This can provide:

• operational redundancy;
• better FX options;
• access to different products;
• alternative international payment channels.

However, every bank will conduct its own KYC review.

53. Is Opening Multiple Accounts Suspicious?

Not by itself.

Businesses commonly use several banks.

But maintaining many accounts with no clear commercial purpose and moving funds rapidly between them may attract questions.

The company should be able to explain why each banking relationship exists.

54. Can Remote Identification Solve Foreign Founder Banking Problems?

The 2026 reforms are important.

As of June 27, 2026, MASAK’s framework permits remote identification for foreign individuals and foreign representatives of Turkish Trade Registry entities under applicable conditions.

This can reduce problems caused solely by physical presence.

But it does not solve:

• unclear beneficial ownership;
• unexplained wealth;
• sanctions exposure;
• high-risk businesses;
• licensing concerns; or
• suspicious transaction profiles.

Remote onboarding solves an identification logistics problem.

It does not eliminate the bank’s risk assessment.

55. A Practical Example: Foreign SaaS Company

Assume two German founders establish:

CloudSoft Türkiye A.Ş.

Ownership:

Founder A – 60%
Founder B – 40%

Initial funding:

EUR 300,000

Business:

B2B SaaS

Customers:

Germany, Netherlands and Türkiye

Expenses:

Turkish payroll, AWS, software licences

This is relatively straightforward.

A strong onboarding package would include:

• passports;
• tax numbers;
• company records;
• UBO chart;
• founders’ German bank statements;
• shareholder funding documentation;
• website;
• SaaS contracts;
• projected turnover.

A bank can quickly understand the commercial logic.

56. A Practical Example: Difficult Banking Profile

Now consider:

Global Trade Technologies Ltd.

Shareholder:

BVI Company

BVI Company shareholder:

unknown nominee

Expected monthly turnover:

USD 15 million

Business description:

“Consultancy and technology”

Incoming payments:

five unrelated countries

Outgoing payments:

immediately transferred to other offshore jurisdictions

No employees.

No website.

No contracts.

No explanation of source of funds.

Even if the Turkish company itself is validly incorporated, a bank may reasonably view the relationship as high risk.

57. A Practical Example: Foreign Crypto Startup

Assume a foreign founder establishes a blockchain company.

The founder tells the bank:

“We develop blockchain software.”

But the company’s expected banking activity includes:

• customer deposits;
• crypto exchange withdrawals;
• transfers to wallet providers; and
• high-volume payments to retail users.

The bank may conclude that the activity potentially resembles a regulated crypto asset service rather than ordinary software development.

It may request:

• SPK-related regulatory information;
• MASAK compliance documentation;
• business model explanation;
• customer flow diagrams; and
• AML procedures.

Given MASAK’s current enhanced measures concerning crypto-related financial relationships, additional scrutiny should be expected.

Conclusion: Why Do Turkish Banks Reject Foreign-Owned Companies?

The most important point is this:

A Turkish bank usually does not reject a company merely because its shareholders are foreign.

Foreign ownership is legally recognized within Türkiye’s investment framework, and official incorporation guidance expressly addresses bank accounts for companies with foreign shareholders.

The real issue is generally risk and transparency.

Banks need to understand:

Who owns the company?

Who ultimately controls it?

Where is the money coming from?

What does the company actually do?

Which countries will it transact with?

How much money will move through the account?

Does the transaction profile match the business model?

Is the business regulated?

Are sanctions or high-risk jurisdictions involved?

MASAK’s risk-based framework expressly requires banks and other financial institutions to obtain information concerning the purpose of the relationship, source of assets and funds, and expected transaction activity in relevant onboarding processes.

Banks must also pay particular attention to high-risk customer relationships, countries and transactions.

Therefore, the worst approach for a foreign founder is:

“First incorporate the company, then walk into a random branch with a passport and ask for an account.”

A better strategy is to prepare a banking compliance package before incorporation or immediately afterward.

That package should clearly establish:

• shareholders;
• UBOs;
• company activity;
• source of funds;
• investment structure;
• expected transaction countries;
• expected transaction volume;
• regulatory status; and
• authorized representatives.

For higher-risk businesses such as:

• fintech;
• crypto;
• international payments;
• commodity trading;
• businesses involving high-risk jurisdictions; or
• complex foreign holding structures,

banking strategy should be included in the legal structuring process from the beginning.

The 2026 expansion of remote identification for foreign individuals and foreign representatives is a significant practical improvement.

But the fundamental rule remains unchanged:

Remote identification can make it easier for the bank to identify the founder. It does not require the bank to accept the risk.

For foreign entrepreneurs, successful banking in Türkiye is therefore largely about being able to prove three things:

Who you are.

Where the money comes from.

Why the transactions make commercial sense.

Frequently Asked Questions

Why did a Turkish bank reject my foreign-owned company?

Possible reasons include unclear beneficial ownership, insufficient source-of-funds documentation, sanctions exposure, high-risk countries, regulatory uncertainty, unusual transaction patterns or the bank’s internal customer acceptance policies.

Is foreign ownership itself a reason for rejection?

Not generally. Turkish investment rules expressly allow foreign shareholders, and official guidance contemplates Turkish banking procedures involving foreign shareholders.

Can a 100% foreign-owned company open a Turkish bank account?

Yes, subject to the bank’s KYC, AML and customer acceptance procedures.

Can a bank ask who ultimately owns my foreign holding company?

Yes. MASAK rules require beneficial ownership identification in continuing business relationships with commercial entities.

What is a UBO?

A UBO is the natural person who ultimately owns or controls a legal entity.

Why does the bank ask for my personal bank statements?

They may be required to help verify the source of funds or source of wealth.

Why does the bank ask what countries my customers are in?

Country exposure forms part of AML and sanctions risk assessment.

Can high-risk countries cause account rejection?

Potentially. MASAK guidance specifically requires increased attention to transactions involving higher-risk jurisdictions.

Can crypto activity cause a banking rejection?

Potentially. MASAK updated its enhanced measures and crypto-related guidance in 2025, emphasizing risk-based controls for crypto asset relationships.

Can a fintech company be rejected because it has no licence?

Yes, if the bank believes the activity may require regulatory authorization that has not been obtained or clearly addressed.

Can a newly established company open an account without revenue?

Yes. However, the bank may request a business plan, investment documents and expected transaction information.

Does a company website help?

It may help the bank understand the company’s actual business, although a website is not itself a universal statutory requirement for account opening.

Why does the bank ask for expected monthly turnover?

MASAK’s risk-based onboarding rules expressly refer to expected monthly transaction volume and number of transactions.

Why does the bank ask about source of funds?

Financial institutions are required to understand where customer funds and relevant assets originate as part of risk-based customer due diligence.

Can I use a Turkish nominee shareholder to make banking easier?

This is generally not a good solution. Banks are required to identify beneficial ownership, so nominee arrangements may create additional compliance questions.

Does appointing a Turkish director guarantee account opening?

No. The bank will still investigate shareholders, UBOs, source of funds and business activities.

Does having a Turkish work permit guarantee account approval?

No.

Can a foreign representative now complete identification remotely?

A June 27, 2026 amendment introduced remote identification possibilities for foreign nationals and foreign representatives of legal entities registered with the Turkish Trade Registry, subject to applicable requirements.

Does remote identification guarantee an online account?

No. Remote identification only changes the identification procedure. The bank still performs its KYC and risk assessment.

Can the bank impose additional restrictions after remote onboarding?

Yes. MASAK’s remote identification rules permit enhanced measures including additional information requests, senior approval, increased monitoring and transaction limits based on risk.

What should I do after one bank rejects my company?

Identify the reason where possible, correct missing corporate or compliance documentation and prepare a stronger onboarding file before approaching another institution.

Can another Turkish bank accept the company after one bank rejects it?

Potentially, yes. Banks have different internal risk appetites and customer acceptance policies.

Should I approach several banks before incorporating?

For businesses with unusual international payment requirements, regulated activities, crypto exposure or complex ownership, discussing banking feasibility before or during incorporation can be commercially sensible.

What is the best way to improve the chance of account approval?

Prepare clear documentation showing:

• ownership;
• UBOs;
• source of funds;
• business model;
• investment structure;
• expected payment countries;
• expected turnover;
• authorized signatories; and
• required regulatory licences.

Legal Disclaimer: This article provides general information regarding Turkish banking, corporate and anti-money laundering law and does not constitute legal, banking or compliance advice. Bank account applications are evaluated individually, and each financial institution may apply different customer acceptance and internal risk policies. Foreign shareholders, complex holding structures, source of funds, sanctions exposure, business sector, transaction countries and regulatory status can materially affect onboarding. Current Turkish banking, MASAK and sector-specific regulations should be reviewed for each individual case.

Related reading: Recovery of unpaid invoices.