Turkey’s citizenship by investment programme allows foreigners to acquire Turkish nationality through qualifying real estate purchases, bank deposits or other forms of investment. When the investment is genuine and properly documented, this route can be stable and long term. However, if the investment is built on fake or inflated valuations, sham payment flows or “cash-back” schemes, the risk is not only administrative but also criminal: investors may face investigations, asset freezes and ultimately the loss of Turkish citizenship itself.
- How Citizenship by Investment Should Work
In the classic real estate route, the process is designed around four basic pillars:
– The property must actually meet the minimum legal investment threshold in real market terms.
– An independent valuation company prepares a valuation report reflecting the true market value.
– The purchase price is registered in the land registry and supported by bank transfer receipts from the investor’s own account.
– A no-sale restriction is annotated on the title deed for the required holding period.
In this ideal model, the investor really bears financial risk, and the state grants citizenship in reliance on accurate documents and transparent banking records.
- Fake or Inflated Valuation Reports
Problems begin when valuation reports are manipulated to fabricate eligibility. Risk indicators include:
– Valuation reports that significantly exceed market prices for comparable properties in the same area.
– Collusion between developer, broker and appraisal company to “hit” the citizenship threshold on paper.
– Use of a single inflated report to cover several units or packages that are sold to different investors.
Submitting such a valuation together with a citizenship application means the authorities are misled about a key requirement: the amount of the investment. If the investor was aware of the manipulation, this can be treated as obtaining citizenship through misrepresentation or concealment of material facts. Under the Turkish citizenship framework, naturalisation granted on that basis may be cancelled later, as if it should never have been given at all.
- Payments Not Actually Made or Immediately Refunded
Another frequent pattern is that the investor does not truly pay or bear the economic burden of the investment:
– The full “purchase price” is transferred from the investor’s account but secretly refunded by the seller, sometimes in cash or via offshore accounts, once citizenship is approved.
– The developer or an affiliated company loans back the entire amount with no real repayment expectation, so the investor appears to have paid but in reality has no net exposure.
– “Double contracts” are used: one contract with a higher price for the file, and another private agreement with a much lower true price.
In these scenarios bank receipts may exist, but they do not reflect a genuine, arm’s-length investment. If discovered, the authorities may conclude that the legal conditions for exceptional acquisition of citizenship were never met. That conclusion directly supports a decision to revoke the naturalisation decision.
- Administrative Revocation of Citizenship
Turkish law allows the cancellation of naturalisation decisions where citizenship was obtained by giving false information or hiding essential matters. Key points for investors:
– There is generally no strict time limit: if the fraud or misrepresentation is discovered years later, the file can be reopened.
– Revocation decisions are administrative acts and can be challenged before the administrative courts, but the burden is heavy if the documents on record reveal obvious inconsistencies.
– Revocation has retrospective character: it is treated as if the person should not have become a citizen in the first place.
The consequences go beyond the individual investor. Where the spouse and minor children also obtained Turkish citizenship based on the same investment, their status may be reviewed. If they acted in good faith and were unaware of the fraud, they may have stronger arguments to keep their citizenship, but this has to be assessed case by case.
- Criminal Investigations and Asset Freezes
The same facts that justify revocation can also support criminal investigations. Typical offences that may be considered include:
– Use of forged or untrue documents in official procedures.
– Fraud against a public institution by creating an artificial picture of compliance.
– Money laundering, if the structure also involves the concealment of illegal proceeds.
During such investigations, prosecutors may request seizure of the investor’s bank accounts and Turkish real estate to secure potential confiscation or criminal fines. This means that the investor can wake up not only with citizenship at risk, but also with blocked accounts and frozen properties, unable to liquidate assets or exit the investment easily.
- Practical Compliance Guidance for Investors
For foreign investors considering, or already holding, Turkish citizenship by investment, a conservative and transparent approach is the only safe strategy:
– Reject any proposal involving “cash-back”, hidden discounts, double contracts or promises that you will recover most of the price after approval.
– Use genuinely independent, licensed valuation companies and never pressure them to adjust figures.
– Ensure all payments come from your own account, with a clear and lawful source of funds, and maintain complete documentation.
– Avoid nominee arrangements where another person appears as the owner, or where you only lend your name to the transaction.
– Work with an independent Turkish lawyer who represents only your interests, not those of the developer or marketing intermediary.
Citizenship by investment can be a legitimate and beneficial route, but if the foundation is artificial, the legal risk never expires. An investor who builds their application on fake valuations or sham payments is effectively placing a time bomb under their own legal status. True, transparent investment is the only realistic way to ensure that Turkish citizenship, once granted, remains secure in the long term.
Yanıt yok