A blocked account in Türkiye, and the clock you did not know was running.

CMK 128 allows seizure where there are strong grounds of suspicion based on concrete evidence both that the offence under investigation was committed and that the asset was derived from it. What can be seized is broad:

• Immovable property; land, sea and air transport vehicles.
• Any kind of account at a bank or other financial institution.
• Any kind of right or receivable held with real or legal persons.
• Negotiable instruments; shareholdings in a company; the contents of a safe deposit box; and other assets.

The asset itself must belong to the suspect or the accused. The article adds only that seizure is still possible where such an asset is in the possession of someone other than the suspect or accused — possession, not ownership. That single sentence is regularly over-read, which is how spouses, business partners and companies find themselves inside a file they are not accused in.

Two safeguards worth knowing

First, an order under this article requires a report on the value derived from the offence, obtained as relevant from the Banking Regulation and Supervision Agency, the Capital Markets Board, the Financial Crimes Investigation Board, the Treasury or the Public Oversight Authority. That report is to be prepared within three months, extendable on request by two further months where special reasons require it.

Second, under CMK 128/9, seizure under this article and the appointment of a trustee can only be ordered by a judge.

CMK 128 applies only to a listed set of offences. Those most often relevant here include fraud (TCK 157 and 158), breach of trust (155), fraudulent bankruptcy (161), theft (141, 142), usury (241), rigging of tenders (235) and of performance (236), embezzlement (247), extortion in office (250), bribery (252), forming an organisation to commit crime (220/3), drug manufacture and trafficking (188), counterfeiting of money, and offences under the Anti-Smuggling Law that carry imprisonment.

Whether the offence in the file is on that list is a real question, not a technicality. If it is not, the order was made under a power that does not extend to it.

How a seizure is executed

An order over immovable property is executed by annotation on the land register, and over vehicles by annotation on the relevant registry. An order over a bank account is executed by immediate notification to the institution by technical means, followed by formal service — and any transaction on the account after the order which is intended to defeat it is void. Orders over shareholdings are notified immediately to the company and to the trade registry.

CMK 128/A was added at the end of 2025 and it works very differently. It applies where there is reasonable suspicion — a lower threshold than CMK 128 — of qualified theft (142/2-e), qualified fraud (158/1-f and 158/1-l), or misuse of bank or credit cards (245).

• The bank, payment service provider or crypto-asset service provider may itself decide to suspend the account for up to forty-eight hours. No judge and no prosecutor is involved in that decision, though CMK 128/A/4 also contemplates an account suspended on the prosecutor's written order. Under CMK 128/A/6 the natural or legal persons who decide the suspension are not held legally liable for it, so the claim you may be looking for against the institution does not exist; the route is the application to the prosecutor.
• The suspension and the account movements are reported immediately to the public prosecutor with all information and documents. The account holder is also notified.
• The account holder may apply to the prosecutor to have the suspension lifted. The prosecutor decides within twenty-four hours.
• Within the suspension period, the funds may be seized on a judge's decision, or in urgent cases on the prosecutor's written order. A seizure without a judge's decision is submitted for approval within twenty-four hours, and the judge announces the decision within forty-eight hours of the seizure — failing which the seizure lapses automatically.
• Where it is established that the money belongs to the victim of the offence, it is returned to them during the investigation or prosecution.
• The requirement in CMK 128 to obtain that valuation report from the BRSA, the Capital Markets Board, MASAK, the Treasury or the Public Oversight Authority does not apply to this route (CMK 128/A/4).

The recurring pattern is that money arrived from somewhere the recipient did not check, and the account was frozen because it was downstream of a complaint made by someone else. Being the unwitting last link in a chain is not a defence that asserts itself. It is a case that has to be built from the transaction history, the commercial relationship and the correspondence.

Three things are worth saying to anyone in that position:

• Do not move the remaining funds. Transactions intended to defeat a seizure order are void, and the attempt becomes part of the file.
• The company is a separate problem. Shareholdings can be seized and a trustee can be appointed to manage seized assets. That reaches partners who are not suspects.
• An economic crime file frequently carries a travel restriction under judicial control, and a criminal outcome carries consequences for residence and re-entry that are decided elsewhere on a seven-day clock.