Introduction

Access to the banking system is essential for foreign individuals and companies operating in Turkey.

A foreign investor purchasing real estate may need to transfer several hundred thousand dollars into Turkey.

A foreign-owned Turkish company may receive international customer payments.

An expatriate may receive salary from abroad.

A foreign entrepreneur may move company capital into a Turkish bank account.

An international trading company may receive USD or EUR payments from customers in Europe, the Gulf, Central Asia, Africa or China.

In most cases, these transactions occur without serious difficulty.

However, problems can arise when a bank suddenly:

• blocks an incoming international transfer;
• prevents money from leaving an account;
• restricts internet banking;
• refuses cash withdrawal;
• requests extensive source-of-funds documents;
• suspends a corporate account;
• places a compliance restriction on a customer;
• reports suspicious activity;
• implements a prosecutor’s seizure order;
• applies a tax e-haciz;
• applies an enforcement attachment; or
• freezes assets under a statutory sanctions or terrorism-financing regime.

For a foreign account holder, the situation can be particularly confusing.

The bank may simply state:

“The transaction is under compliance review.”

or:

“There is a legal restriction on the account.”

or:

“You need to contact the relevant authority.”

The customer may not initially know whether the problem comes from:

the bank itself,

MASAK — the Financial Crimes Investigation Board,

a public prosecutor,

a criminal court,

a tax office,

an enforcement office,

or

a statutory asset-freezing decision.

These situations are legally very different.

The first and most important question in every frozen-account case is therefore:

Who imposed the restriction, and under which legal authority?

A bank’s internal anti-money-laundering compliance review is not the same thing as criminal seizure.

A seven-business-day MASAK-related transaction postponement is not the same thing as a tax e-haciz.

A creditor’s enforcement attachment is not the same thing as a terrorism-financing asset freeze.

Each requires a different legal strategy.

The principal Turkish legislation affecting these cases includes:

• Banking Law No. 5411;
• Law No. 5549 on Prevention of Laundering Proceeds of Crime;
• the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism;
• Criminal Procedure Code No. 5271 — CMK;
• Law No. 6183 on the Procedure for Collection of Public Receivables;
• Enforcement and Bankruptcy Law No. 2004;
• Law No. 6415 on Prevention of Financing of Terrorism;
• and other sanctions, tax and financial compliance legislation.

This guide explains why foreign bank accounts may be frozen in Turkey, what banks are legally required to investigate, how criminal and tax freezes work and what a foreign individual or international company can do to recover access to blocked money.

Can Foreigners Open Bank Accounts in Turkey?

Foreign nationals and foreign-linked companies can use Turkish banking services, subject to each bank’s customer acceptance policies and Turkish anti-money-laundering requirements.

A critical point is that banks are required to identify their customers when establishing a permanent business relationship regardless of the amount involved.

MASAK’s current regulation expressly provides that obliged institutions must carry out customer identification when establishing a continuous business relationship without regard to a monetary threshold.

Banks therefore commonly need to establish:

• who the customer is;
• whether the identification documents are genuine;
• the customer’s address and legal status;
• the purpose of the banking relationship;
• expected transaction activity;
• occupation or business activity;
• source of income;
• source of funds;
• and, for companies, who ultimately owns or controls the business.

Foreign citizenship does not remove these requirements.

Indeed, an international customer may require additional documentation because the bank must understand cross-border risk and the economic purpose of international transfers.

Documents a Foreign Individual May Need

The exact documentation varies by bank and customer profile, but a foreign individual may be asked to provide documents such as:

• passport;
• Turkish foreigner identification number where available;
• Turkish tax identification number;
• residence documentation;
• proof of address;
• employment contract;
• salary records;
• company ownership documents;
• tax declarations;
• property sale documents;
• inheritance documentation;
• bank statements from another country;
• or evidence explaining the source of substantial funds.

The important principle is that the bank must be able to understand who the customer is and why the money exists.

A foreigner transferring USD 1 million into Turkey should therefore expect more scrutiny than a customer opening an account to receive an ordinary monthly salary.

Foreign Company and Corporate Bank Accounts

Corporate banking can be more demanding.

A Turkish company owned by foreign shareholders may be asked to provide:

• Trade Registry Gazette;
• articles of association;
• tax certificate;
• signature circular;
• company activity information;
• board or shareholder resolutions;
• identification documents of directors;
• shareholder information;
• ownership structure;
• invoices and contracts;
• and documents identifying the ultimate beneficial owner — UBO / gerçek faydalanıcı.

Turkish AML regulations require obliged institutions to take necessary measures to identify the true beneficial owner behind transactions and legal entities.

This means that a corporate structure cannot normally stop at:

“Shareholder: XYZ Holdings Ltd.”

The bank may ask:

Who ultimately owns XYZ Holdings Ltd.?

If it is owned by another company, the inquiry may continue until the natural persons who ultimately own or control the structure are identified.

What Is the Ultimate Beneficial Owner?

The ultimate beneficial owner is the natural person who ultimately owns, controls or benefits from a company or transaction.

The concept is crucial in modern banking compliance.

For example:

A Turkish company is owned by a Dubai company.

The Dubai company is owned by a Cyprus holding company.

The Cyprus company is owned by two individuals.

The bank will generally need to understand the individuals behind the structure rather than accepting the first corporate shareholder as the end of the analysis.

MASAK requires financial institutions to adopt measures designed to identify the real beneficial owner.

A foreign company that cannot explain its ownership chain can therefore face:

• delayed account opening;
• blocked international transfers;
• enhanced compliance review;
• or refusal to continue the customer relationship.

Why Can a Turkish Bank Ask Where Money Came From?

Because Turkish banks are subject to anti-money-laundering and counter-terrorism-financing obligations.

Under Law No. 5549 and the related regulations, banks and other obliged institutions must:

• identify customers;
• understand business relationships;
• monitor transactions;
• identify beneficial owners;
• report suspicious transactions;
• maintain records;
• and apply risk-based compliance procedures.

A bank can therefore ask:

“What is the source of this USD 750,000?”

The customer should be prepared to answer with evidence.

Acceptable documentation may depend on the transaction.

Examples of Source-of-Funds Evidence

Property Sale

A customer may provide:

• title deed;
• sale agreement;
• bank receipt;
• tax documentation;
• and evidence showing payment from the purchaser.

Company Dividend

Documents may include:

• company financial statements;
• shareholder resolution;
• dividend declaration;
• tax documents;
• and outgoing bank records from the company.

Salary or Bonus

Possible documents include:

• employment agreement;
• payroll;
• employer letter;
• and foreign bank statements.

Inheritance

Evidence may include:

• death certificate;
• certificate of inheritance;
• probate order;
• estate distribution documentation;
• and prior bank records.

Sale of Company Shares

Evidence can include:

• share purchase agreement;
• company records;
• closing statement;
• and banking evidence.

Cryptocurrency Proceeds

The bank may expect substantially more information concerning:

• exchange used;
• transaction history;
• wallet history;
• source of original funds;
• tax treatment;
• and conversion into fiat currency.

The issue is not merely whether money exists.

The bank must understand whether the economic story is credible and documentable.

Large Transfers Are Not Automatically Illegal

A large international transfer is not automatically money laundering.

Likewise:

• receiving money from abroad;
• selling cryptocurrency;
• receiving business revenue;
• receiving an inheritance;
• selling foreign property;
• or moving personal savings to Turkey

is not inherently illegal.

However, a transaction may attract increased scrutiny if its characteristics are inconsistent with the customer’s known profile.

For example:

A person who declared monthly income of EUR 3,000 suddenly receives EUR 2 million from an unrelated company.

That does not automatically establish a crime.

But the bank will understandably want to know:

• who sent the money;
• why;
• under which agreement;
• and where the money originally came from.

What Is a Suspicious Transaction Report?

Turkish banks are among the institutions required to submit Suspicious Transaction Reports — Şüpheli İşlem Bildirimi (ŞİB) to MASAK where the legal conditions are met.

Importantly, suspicious transaction reporting is not subject to a minimum monetary threshold.

MASAK’s rules state that suspicious transactions are reported regardless of amount.

A TRY 50,000 transaction can therefore theoretically create suspicion while a USD 1 million transaction may be perfectly legitimate if adequately documented.

The central issue is the nature of the transaction and its surrounding circumstances.

Why Will the Bank Not Tell Me Whether It Reported Me to MASAK?

Because Turkish law contains a strict confidentiality rule.

Under Law No. 5549, obliged institutions cannot disclose to the customer or transaction parties that a suspicious transaction report has been made to MASAK, except within the legally permitted official framework.

MASAK expressly states that a suspicious transaction report cannot be disclosed to transaction parties or other unauthorized persons.

This rule is designed to prevent tipping off.

Therefore, if a customer asks:

“Did you report me to MASAK?”

the bank may legally be unable to provide a direct answer.

This explains why some bank communications appear vague.

A Bank Compliance Block Is Not Necessarily a Government Seizure

This distinction is essential.

A bank may temporarily restrict a transaction because it requires:

• additional KYC information;
• updated identification;
• proof of source of funds;
• beneficial ownership documents;
• sanctions screening;
• transaction explanation;
• or internal compliance approval.

This does not necessarily mean:

• the customer is under criminal investigation;
• MASAK has ordered confiscation;
• a prosecutor has seized the account;
• or the money is permanently frozen.

The first step should therefore be to identify whether the bank restriction is:

internal/compliance-based

or

based on an external legal order.

What Is a MASAK-Related Transaction Postponement?

Turkish AML legislation allows certain suspicious transactions to be temporarily postponed where there is suspicion that the assets are connected with illegal proceeds or unlawful purposes.

Under the relevant MASAK framework, where a suspicious transaction is reported together with a request for postponement, the transaction may be held pending the competent decision.

The postponement period cannot exceed seven business days from the date of the suspicious transaction report.

This mechanism is designed to create a short window for authorities to investigate and, where appropriate, move toward a judicial or other formal measure.

It should not be confused with permanent confiscation.

Does the Money Automatically Become Free After Seven Business Days?

Not necessarily.

The MASAK postponement mechanism itself is limited.

However, during that period another legal measure may be imposed.

For example:

• a prosecutor may open a criminal investigation;
• a court may issue a seizure decision;
• another competent authority may impose an asset freeze;
• or separate enforcement or tax proceedings may affect the account.

Therefore:

“Seven business days have passed”

does not automatically establish that there is no other restriction.

The exact legal basis must be investigated.

Criminal Seizure of Bank Accounts Under CMK Article 128

A much more serious situation arises when funds are seized as part of a criminal investigation.

Article 128 of the Criminal Procedure Code permits seizure of certain assets belonging to a suspect or defendant where the statutory conditions are satisfied and there are concrete facts supporting strong suspicion that the assets were obtained from specified criminal activity.

The provision expressly includes:

all types of accounts in banks and other financial institutions.

CMK Article 128 is therefore a legal basis through which criminal authorities can place restrictions on:

• Turkish lira accounts;
• foreign currency accounts;
• deposits;
• investment-related rights;
• and other qualifying financial assets.

The measure should be distinguished from a bank’s voluntary internal compliance restriction.

Does Every Criminal Investigation Allow the Authorities to Freeze Every Bank Account?

No.

CMK Article 128 contains statutory conditions and is connected with specified offences and the requirement that the relevant assets have the legally required connection with proceeds of crime.

The law also contains a specialized financial-report mechanism involving institutions such as MASAK or other competent regulatory bodies before the ordinary Article 128 seizure mechanism is applied in the relevant circumstances.

A seizure order should therefore be examined carefully.

Important questions include:

• What offence is being investigated?
• Who is the suspect?
• Which accounts were seized?
• What amount was frozen?
• What alleged criminal proceeds are identified?
• Is there evidence connecting the money to the alleged offence?
• Was the statutory procedure followed?
• Does the seizure cover legitimate funds unrelated to the allegation?

These questions can form the basis of a challenge.

The New CMK Article 128/A and the 48-Hour Account Suspension

A major development entered Turkish criminal procedure at the end of 2025.

Law enacted on 24 December 2025 introduced CMK Article 128/A, creating a specific rapid-response procedure targeting proceeds of certain cyber-enabled offences.

The provision concerns specified forms of:

• aggravated theft committed through information systems;
• aggravated fraud committed through information systems or banking/payment structures;
• and misuse of bank or credit cards.

Where there is reasonable suspicion that an account is being used in such an offence, a:

• bank;
• payment service provider; or
• crypto-asset service provider

may suspend the relevant account for up to 48 hours.

This is particularly significant in modern fraud investigations where stolen money may pass through multiple bank accounts within minutes.

What Happens After a 48-Hour Suspension?

Under Article 128/A:

• the financial institution must immediately report the suspension and account activity to the Chief Public Prosecutor’s Office;
• the account holder is also notified of the suspension;
• the account holder may request removal of the suspension from the Public Prosecutor’s Office;
• and the prosecutor must decide that application within 24 hours.

The proceeds suspected to be connected with the offence may then be formally seized during the suspension period by judicial decision or, in urgent cases, by written prosecutorial order subject to judicial review.

This procedure is different from ordinary MASAK AML postponement.

Example: Money From Online Fraud Passes Into an Innocent Business Account

Consider the following scenario.

A Turkish company legitimately sells a laptop online.

A purchaser pays TRY 250,000.

Unknown to the company, the money came from an account compromised through an online fraud.

The bank detects the transaction chain and suspends the company’s account.

The company may suddenly discover that:

• its entire balance is inaccessible;
• payroll cannot be paid;
• suppliers are waiting;
• and the company is now connected to a criminal investigation.

The key legal question is whether the company knowingly participated in the offence or merely received money through an apparently legitimate commercial transaction.

Evidence may include:

• invoice;
• order information;
• delivery documents;
• customer communications;
• accounting records;
• tax invoice;
• product shipment;
• and normal commercial history.

The existence of frozen money does not by itself prove criminal involvement.

Can Money Belonging to the Victim Be Returned During the Criminal Case?

Article 128/A contains an important restitution provision.

Where seized proceeds are determined to belong to the person harmed by the offence, the property may be returned to its owner during the investigation or prosecution stage.

This can be particularly relevant in:

• online fraud;
• phishing;
• bank account takeover;
• payment fraud;
• and cryptocurrency-related fraud chains.

Victims should therefore not always assume they must wait until the end of a multi-year criminal trial before seeking return of clearly identifiable funds.

Tax E-Haciz: When the Tax Office Freezes the Bank Account

Not every bank freeze has anything to do with money laundering or criminal law.

Tax authorities can place electronic attachments on bank accounts for unpaid public debts.

Under Law No. 6183, public receivables can be enforced against rights and receivables held at banks, and attachment notices may be transmitted electronically.

The Turkish Revenue Administration’s e-haciz infrastructure allows tax authorities to communicate electronic attachment notices to participating banks.

Potential debts can include qualifying:

• taxes;
• tax penalties;
• public receivables;
• and related statutory amounts.

A foreign person or foreign-owned Turkish company with Turkish tax obligations can therefore face an e-haciz just like a Turkish taxpayer.

How Can I Know Whether the Freeze Is a Tax E-Haciz?

The correct approach is to examine:

• tax office records;
• payment orders;
• outstanding debt information;
• electronic notifications;
• and the bank’s legal restriction reference.

The Revenue Administration’s digital systems provide services relating to tax debts and electronic attachments.

A tax e-haciz should not be challenged by sending repeated source-of-funds documents to the bank.

The bank is normally implementing the tax authority’s attachment.

The underlying public debt must be addressed.

Private Creditors Can Also Attach Bank Accounts

A private creditor may also pursue a debtor’s bank funds through Turkish enforcement proceedings.

Bank accounts can be affected by attachment procedures under the Enforcement and Bankruptcy Law.

Turkish judicial practice expressly recognizes the service of attachment notices to banks under Article 89 of the Enforcement and Bankruptcy Law.

The source of the restriction may therefore be:

• unpaid commercial debt;
• court judgment;
• loan;
• promissory note;
• unpaid rent;
• contractual receivable;
• compensation claim;
• or another enforcement file.

The debtor should obtain the enforcement file number immediately.

An Enforcement Attachment Is Different From Criminal Seizure

This distinction affects the remedy.

If the bank says:

“There is a prosecutor’s seizure order,”

the matter must be addressed through criminal procedure.

If the bank says:

“There is an enforcement attachment from Istanbul Enforcement Office,”

the issue belongs to enforcement law.

If the bank says:

“There is an e-haciz from the tax office,”

public receivables legislation applies.

Sending the wrong application to the wrong authority wastes valuable time.

Asset Freezing Under Terrorism-Financing Legislation

A separate and much more serious category involves statutory asset-freezing decisions connected with terrorism financing or international sanctions.

Law No. 6415 provides a legal framework for freezing assets in terrorism-financing cases.

MASAK’s official legislation confirms that asset-freezing decisions identify:

• the person or organization affected;
• reasons;
• scope;
• duration;
• and available legal remedies.

Turkey also maintains asset-freezing mechanisms connected with UN Security Council sanctions and proliferation-financing obligations under Law No. 7262.

These measures can affect more than a single ordinary checking account.

They can extend to broader assets and economic resources covered by the statutory decision.

Joint Accounts Can Also Be Affected

Special asset-freezing rules can also create serious problems for joint ownership.

MASAK guidance states that accounts jointly owned with a person or entity subject to an asset-freezing decision may be frozen in their entirety under the applicable framework.

This can create hardship for an innocent co-owner.

For example:

A husband and wife hold a joint account.

One spouse becomes subject to a statutory asset-freezing decision.

The innocent spouse may discover that access to the joint balance has also been restricted.

Such cases require examination of the specific freeze and the procedures for protecting third-party rights.

Bank Secrecy and Why Information May Be Limited

Bank customers frequently assume the bank must disclose every detail of internal and governmental investigations.

That is not always correct.

Turkish Banking Law protects customer and banking secrecy, while creating statutory exceptions for competent authorities and legally authorized disclosures.

At the same time, AML rules specifically prohibit disclosure of suspicious transaction reporting to the customer.

Therefore, a bank may be legally able to say:

“Your transaction is subject to compliance procedures.”

while being unable to say:

“We filed a suspicious transaction report against you yesterday.”

This can be frustrating, but it does not automatically indicate unlawful conduct by the bank.

What Should a Foreign Individual Do When an Account Is Frozen?

The first objective should be classification of the freeze.

Ask the bank, preferably in writing, whether the restriction is connected with:

• internal compliance review;
• missing KYC documentation;
• legal attachment;
• prosecutor’s order;
• court order;
• tax e-haciz;
• enforcement office attachment;
• or another official measure.

The bank may not disclose a suspicious transaction report, but it can often identify whether an external legal order exists or whether further customer documentation is required.

Step 1 — Obtain the Exact Account Restriction

Determine:

• which account is affected;
• which currency;
• whether only outgoing transfers are blocked;
• whether cash withdrawal is blocked;
• whether the entire account is frozen;
• whether only a particular incoming transfer is held;
• and when the restriction began.

A blocked USD transfer is not necessarily the same legal issue as complete suspension of every company account.

Step 2 — Identify the Authority

Ask whether there is a reference to:

• Public Prosecutor’s Office;
• Criminal Judgeship;
• criminal court;
• tax office;
• enforcement office;
• MASAK-related procedure;
• or another public body.

Obtain the:

• decision number;
• file number;
• authority;
• date;
• and amount affected

where legally available.

Step 3 — Prepare Source-of-Funds Documentation

Where the issue is primarily compliance-related, prepare a coherent documentary package.

Do not send random documents without explanation.

The file should tell one clear economic story.

For example:

Transfer amount: EUR 600,000

Source: sale of apartment in Germany

Evidence:

• property ownership document;
• notarized sale agreement;
• purchaser payment record;
• German bank statement;
• tax documentation where relevant;
• and transfer instruction into Turkey.

The objective is to allow the bank to trace the transaction logically from origin to destination.

Step 4 — Explain the Purpose of the Transfer

Source and purpose are different concepts.

A company may prove that USD 1 million came from a legitimate company but still need to explain why it was transferred.

Possible explanations include:

• purchase of Turkish real estate;
• capital increase;
• shareholder loan;
• payment for goods;
• service invoice;
• acquisition of machinery;
• repayment of debt;
• dividend;
• investment;
• or intercompany transfer.

Contracts and invoices should correspond with the bank payment description.

Step 5 — Review Corporate Beneficial Ownership

Foreign corporate structures should make sure that:

• Trade Registry information;
• shareholder documentation;
• UBO information;
• board authority;
• and banking declarations

are consistent.

An unexplained mismatch can significantly delay the compliance process.

For example, if the bank was told that Company A is owned 100% by Person X but new documents show an offshore company and several undisclosed beneficiaries, enhanced scrutiny should be expected.

Step 6 — Check for a Criminal Investigation

If the bank indicates a prosecutor or criminal court order, the priority changes.

A criminal lawyer should determine:

• prosecutor’s file number;
• alleged offence;
• suspect status;
• seizure order;
• scope of assets seized;
• connection between money and alleged offence;
• and available objection or release procedure.

Merely proving the money is urgently needed to pay salaries does not necessarily invalidate a lawful criminal seizure.

The legal argument should address why the statutory seizure conditions are not met or why the scope is excessive.

Step 7 — Distinguish Legitimate Funds From Alleged Criminal Proceeds

This is often the central issue in criminal account freezes.

Suppose a company account contains TRY 20 million.

The prosecution alleges that TRY 500,000 is related to a fraudulent transaction.

An important defence issue can arise where authorities block the entire account without adequately distinguishing:

• legitimate turnover;
• employee salaries;
• tax payments;
• shareholder capital;
• and the allegedly criminal proceeds.

The proportionality and statutory scope of the seizure should be examined.

Step 8 — Check Tax and Enforcement Records

Where the account holder is a business, verify immediately whether there are:

• unpaid VAT liabilities;
• corporate tax debts;
• SGK/public debts;
• enforcement files;
• judgments;
• promissory note proceedings;
• or creditor attachments.

The bank may be doing nothing more than complying with a legally served attachment notice.

Can a Lawyer Request Release of a Frozen Bank Account?

Potentially, yes, but the application depends entirely upon the reason for the freeze.

Possible procedures include:

Internal compliance case:
submission of evidence and formal bank correspondence.

CMK 128 seizure:
application or objection through the criminal investigation/court framework.

CMK 128/A suspension:
application to the Public Prosecutor’s Office; Article 128/A requires the prosecutor to decide the account holder’s request concerning suspension within 24 hours.

Tax e-haciz:
challenge or payment/resolution of the underlying public receivable under Law No. 6183.

Private enforcement attachment:
applications within the enforcement file and, where necessary, complaint or litigation before the competent enforcement court.

Asset freeze:
use of the specific statutory administrative/judicial remedies applicable to the freezing decision.

There is no universal “bank account unfreeze petition.”

Can a Bank Be Sued for Wrongfully Blocking Funds?

Potentially, depending upon the legal basis.

Where a bank blocks access purely through its own action without sufficient contractual or statutory basis and causes provable loss, contractual or banking-law remedies may potentially arise.

However, the analysis changes significantly where the bank was merely complying with:

• court order;
• prosecutor’s order;
• tax attachment;
• enforcement notice;
• sanctions freeze;
• or another binding legal duty.

A bank cannot generally be expected to ignore a valid judicial or administrative order merely because its customer objects.

The correct defendant may therefore be the public authority or the underlying claimant rather than the bank.

Can a Bank Close a Foreign Customer’s Account?

Banks apply customer-acceptance and risk policies together with their statutory compliance obligations.

Where the bank concludes that it cannot adequately understand the customer’s activities, verify identity/beneficial ownership or manage the compliance risks of the relationship, it may decline to establish or continue certain banking relationships subject to contractual and legal requirements.

MASAK’s compliance framework specifically requires enhanced measures for higher-risk customers and business relationships, including obtaining additional information and more frequent updating of customer and beneficial ownership data.

Foreign companies conducting complex international transactions should therefore regard ongoing KYC as a continuing obligation rather than a one-time account-opening exercise.

High-Risk Transactions for Foreign Companies

A transaction is not automatically unlawful because it has one of the following characteristics, but banks may examine transactions more closely where there are factors such as:

• large incoming payments inconsistent with the company’s turnover;
• payments from unrelated third parties;
• numerous payments followed by immediate onward transfer;
• countries with heightened sanctions or financial-crime risk;
• crypto-related transactions;
• unclear loan arrangements;
• undocumented shareholder payments;
• cash-intensive transactions;
• payment descriptions inconsistent with invoices;
• unexplained transfers between connected companies;
• unusually complicated ownership structures;
• or rapid movement of funds through several jurisdictions.

The best compliance protection is not simply telling the bank:

“This money is legal.”

It is being able to demonstrate why it is legal.

Shareholder Loans and Foreign Company Capital

Foreign shareholders commonly transfer money to their Turkish companies.

The payment should be legally classified.

For example:

Is it:

• share capital?
• capital increase?
• shareholder loan?
• payment for goods?
• reimbursement?
• capital advance?

The corporate records, accounting treatment and bank transfer explanation should all be consistent.

A transfer described in the bank message as:

“personal payment”

while company books record it as:

“shareholder loan”

can create unnecessary compliance questions.

Can the Bank Freeze Salaries in a Company Account?

A company account can be subject to a legal restriction even if money in that account is intended for:

• salaries;
• rent;
• tax;
• suppliers;
• or business operations.

The fact that the company needs access urgently does not by itself defeat:

• criminal seizure;
• tax attachment;
• enforcement attachment;
• or statutory asset freeze.

However, depending on the relevant legal framework, arguments concerning third-party rights, legitimate funds, proportionality or permitted essential payments may become relevant.

Under terrorism-financing asset-freezing rules, for example, the legislation contains mechanisms governing permitted payments through frozen accounts in specified circumstances.

What If the Money Belongs to Someone Else?

Third-party ownership is an especially important issue.

Examples include:

• client funds;
• escrow-type money;
• money mistakenly transferred;
• funds belonging to another company;
• proceeds held temporarily;
• or victim funds traced through a fraud chain.

The person claiming ownership should gather evidence showing:

• origin;
• beneficial ownership;
• transaction purpose;
• contractual relationship;
• and why the account holder did not own the money economically.

Under the new CMK Article 128/A framework, property belonging to the victim may be returned when ownership is established.

Can Foreign Currency Accounts Be Frozen?

Yes.

The fact that the account holds:

• USD;
• EUR;
• GBP;
• CHF;
• or another currency

does not generally prevent the Turkish bank from implementing a legally valid restriction.

A legal seizure or attachment can affect qualifying bank rights and receivables irrespective of the account denomination.

Likewise, converting TRY into USD does not protect money from a lawful seizure.

Moving Money After Learning About a Freeze Can Make the Situation Worse

Once a company becomes aware that transactions are under serious compliance or criminal review, attempting to rapidly move remaining money through:

• other banks;
• relatives;
• employees;
• crypto accounts;
• or offshore entities

can create additional suspicion.

The correct response is legal and documentary.

Particularly in criminal cases, attempts to conceal or dissipate funds can materially worsen the account holder’s position.

Practical Example: Foreign Investor’s USD 1 Million Transfer Is Blocked

Assume a UAE resident transfers USD 1 million to a Turkish bank to purchase commercial property.

The bank blocks the transaction and asks for source-of-funds evidence.

The investor should not immediately assume they are accused of money laundering.

A properly structured response might include:

• passport and residency records;
• company ownership documents;
• evidence showing how the investor accumulated the money;
• audited company financial statements;
• dividend documents;
• foreign bank statements;
• Turkish property purchase agreement;
• seller information;
• and an explanation of the transaction.

If the bank instead states that a prosecutor has issued a seizure decision, the situation becomes fundamentally different and the criminal file must be examined.

Practical Example: Foreign Company’s Account Frozen After Fraud Payment

A Turkish trading company owned by foreign shareholders receives TRY 2 million from a new customer.

Two days later the account is suspended.

The company learns that the customer allegedly obtained the money through cyber fraud.

Under the post-2025 Article 128/A mechanism, qualifying bank accounts connected to specified cyber-enabled fraud offences can be suspended for up to 48 hours and potentially subjected to formal seizure.

The company should immediately preserve:

• contract;
• invoice;
• delivery documentation;
• emails;
• customer identity information;
• accounting record;
• shipment tracking;
• and any evidence showing legitimate commercial conduct.

Frequently Asked Questions

Can foreigners open bank accounts in Turkey?

Yes, subject to bank policies, identification and Turkish AML/KYC requirements.

Why is my Turkish bank asking where my money came from?

Banks are legally required to identify customers, understand business relationships, monitor suspicious transactions and determine beneficial ownership.

Is receiving a large amount from abroad illegal?

No. A large transfer is not automatically illegal, but the bank may require evidence explaining its source and purpose.

Can a bank ask for my foreign tax return?

It may request additional information reasonably connected with understanding the customer, source of income or source of funds under its compliance procedures.

Can a Turkish bank report me to MASAK?

Banks are among the institutions subject to suspicious transaction reporting obligations.

Is there a minimum amount before a suspicious transaction can be reported?

No. MASAK states that suspicious transaction reporting applies regardless of transaction amount.

Will my bank tell me if it filed a suspicious transaction report?

Generally no. Turkish law prohibits disclosure of suspicious transaction reporting to unauthorized persons, including transaction parties.

Can MASAK freeze my account forever?

The specific suspicious-transaction postponement mechanism is limited to seven business days. A separate judicial, administrative or statutory measure may subsequently continue the restriction.

Can a prosecutor freeze a bank account?

Criminal procedure contains several mechanisms for seizure or suspension of bank funds, including CMK Article 128 and the newer Article 128/A procedure for specified cyber-enabled offences.

What is the 48-hour account freeze?

Under CMK Article 128/A, banks, payment institutions and crypto-asset providers may suspend accounts for up to 48 hours where the statutory reasonable-suspicion conditions exist concerning specified cyber-related theft, fraud and card offences.

Can I challenge the 48-hour suspension?

Yes. The account holder may apply to the Public Prosecutor’s Office, and the prosecutor must decide the application within 24 hours.

Can the tax office freeze my Turkish account?

Yes. Public receivables may be enforced against bank rights and receivables under Law No. 6183, including through electronic attachment procedures.

Can a private creditor freeze my bank account?

A creditor can use Turkish enforcement procedures to attach qualifying bank funds where the legal requirements are satisfied.

Can terrorism-financing legislation freeze a bank account?

Yes. Law No. 6415 and related legislation contain broader asset-freezing mechanisms.

Can a joint account be frozen?

Yes, particularly under specific statutory asset-freezing regimes. MASAK guidance expressly addresses jointly held accounts in this context.

Can a lawyer get my account released?

Potentially, but the correct procedure depends entirely on whether the restriction comes from the bank, prosecutor, court, tax office, enforcement office or another authority.

Can I sue the bank?

Possibly if the restriction was legally unjustified and attributable to the bank, but not every bank freeze is the bank’s own legal decision.

Does a bank have to accept my explanation of the source of funds?

No. The bank must assess the documents under its legal and risk obligations.

What documents should a foreign company keep?

At minimum, companies should maintain clear corporate ownership records, contracts, invoices, tax/accounting records, bank statements and documentation proving the economic basis of major international transfers.

Step-by-Step Response to a Frozen Bank Account in Turkey

A practical legal response can be organized as follows.

Step 1 — Do Not Guess

Determine whether the restriction is:

• compliance;
• MASAK-related;
• criminal;
• tax;
• enforcement;
• or sanctions-related.

Step 2 — Contact the Bank in Writing

Request confirmation of the nature and scope of the restriction to the extent the bank is legally permitted to disclose it.

Step 3 — Obtain the File or Decision Number

Where an external authority is involved, identify:

• authority;
• file;
• date;
• amount;
• and legal basis.

Step 4 — Preserve Transaction Evidence

Download bank statements and preserve contracts, invoices and correspondence immediately.

Step 5 — Prepare Source-of-Funds and Source-of-Wealth Evidence

Separate:

Where did this specific money come from?

from

How did the customer acquire their overall wealth?

Banks may examine both.

Step 6 — Trace the Funds

Prepare a chronological path showing movement from the economic source to the Turkish bank account.

Step 7 — Check Criminal Exposure

Where a prosecutor is involved, obtain the investigation file and determine whether the account holder is:

• suspect;
• third party;
• victim;
• or merely recipient of transferred funds.

Step 8 — Challenge the Correct Measure

Use the remedy appropriate to the authority.

Step 9 — Do Not Sign Inaccurate Explanations

An inconsistent bank statement can later appear in criminal, tax or compliance proceedings.

Step 10 — Fix the Structural Problem

For corporate customers, correct deficiencies involving:

• beneficial ownership;
• shareholder loans;
• undocumented payments;
• accounting;
• invoices;
• and customer verification.

Conclusion

A frozen bank account in Turkey is not a single legal problem.

The expression “bank freeze” can describe several completely different measures.

The restriction may result from:

a bank’s internal compliance review,

MASAK’s anti-money-laundering framework,

a criminal seizure order,

the new CMK Article 128/A cyber-fraud procedure,

a tax e-haciz,

a creditor’s enforcement attachment,

or

a statutory terrorism-financing or sanctions freeze.

The legal response depends on identifying the correct category.

For ordinary bank compliance cases, the central issue is usually documentation.

Banks are required to identify customers when establishing permanent business relationships and must take measures to identify beneficial owners.

Foreign individuals and companies should therefore expect questions concerning:

• identity;
• source of funds;
• source of wealth;
• ownership;
• business activities;
• customers;
• contractual purpose;
• and international transaction patterns.

A customer saying:

“It is my money.”

may not be sufficient.

The bank may need documentary evidence showing why it is the customer’s money and how it was obtained.

The situation becomes more serious where suspicious transaction procedures are involved.

Banks must report suspicious transactions regardless of amount, while Turkish law prohibits them from disclosing the existence of such reports to transaction parties.

This explains why customers sometimes receive limited information during AML investigations.

The MASAK transaction-postponement regime allows qualifying suspicious transactions to be delayed for up to seven business days.

But that seven-day period should not be mistaken for an absolute maximum duration for every bank freeze.

During that period, authorities may obtain a separate judicial or statutory measure.

Criminal seizure is one example.

CMK Article 128 allows qualifying bank accounts and other financial rights to be seized where the strict statutory conditions concerning criminal proceeds and specified offences are met.

The introduction of CMK Article 128/A in December 2025 has made rapid bank intervention particularly important in cyber-fraud cases.

For specified aggravated theft, fraud and bank-card offences, banks, payment institutions and crypto-asset service providers may now suspend accounts for up to 48 hours when the statutory reasonable-suspicion threshold exists. The financial institution must immediately inform the Public Prosecutor’s Office, and the account holder has a specific right to request removal of the suspension.

This development is especially important for foreign companies.

An otherwise legitimate business can become involved in a criminal transaction chain simply because a customer pays with stolen or fraudulently obtained money.

When this happens, the company’s strongest protection is usually detailed commercial documentation:

• contract;
• invoice;
• delivery;
• tax records;
• customer communication;
• and proof of genuine business activity.

Tax and creditor freezes should be treated differently.

Law No. 6183 allows public authorities to attach bank rights and receivables electronically for qualifying public debts.

Private creditors can likewise use Turkish enforcement proceedings to reach bank assets through attachment procedures.

In those situations, submitting invoices to the bank’s compliance department will not solve the problem.

The underlying enforcement or tax debt must be addressed through the proper legal channel.

Foreign account holders should therefore follow a simple rule:

Never start by asking only “How do I remove the block?”

Start by asking:

“Who placed the block, under which law, for what amount and under which file number?”

Once those four questions are answered, the legal strategy becomes substantially clearer.

For foreign companies operating in Turkey, prevention is equally important.

Corporate accounts should maintain clear alignment between:

• shareholder structure;
• ultimate beneficial owners;
• accounting;
• tax records;
• contracts;
• invoices;
• bank transfer descriptions;
• and actual commercial activity.

International payments should be explainable before the bank asks questions.

Shareholder loans should be documented as shareholder loans.

Capital payments should be documented as capital.

Customer receipts should correspond with invoices.

Intercompany transfers should have an identifiable commercial or financial purpose.

This dramatically reduces the risk that a legitimate transaction will appear economically inexplicable.

Finally, account holders should avoid reactive conduct.

Rapidly moving money to another bank, converting funds into cryptocurrency, using employees’ accounts or transferring balances to relatives after learning of an investigation may create far greater problems than the original banking restriction.

The correct approach is:

identify the legal basis → secure the records → trace the money → prove the economic source → determine the competent authority → challenge the specific restriction.

For foreign individuals and international companies, a frozen Turkish bank account can affect:

• property acquisitions;
• payroll;
• supplier payments;
• company operations;
• residence and investment plans;
• and even criminal exposure.

Early legal review can therefore be decisive, particularly where the customer cannot determine whether the issue is merely compliance-related or has already developed into a criminal, tax or enforcement proceeding.

Legal Disclaimer

This article provides general legal information concerning bank accounts, frozen funds, AML/MASAK compliance, criminal seizure, tax attachments and enforcement proceedings in Turkey as of August 2026.

It does not constitute legal, banking, tax or financial advice regarding any specific account, transaction or investigation.

The applicable procedure can vary depending upon:

• nationality;
• residence;
• bank;
• account type;
• source of funds;
• beneficial ownership;
• transaction history;
• criminal allegations;
• tax liabilities;
• enforcement proceedings;
• sanctions status;
• corporate structure;
• and the exact authority that imposed the restriction.

A foreign individual or company whose Turkish bank account has been blocked should obtain case-specific legal advice after identifying the precise legal basis and authority responsible for the restriction.