Your Transfer From Abroad Froze Your Turkish Account: what the bank reported and what you have to prove

Article 4(1) of Law 5549 obliges banks — and payment institutions, exchange offices and the other listed bodies — to report to MASAK, the Financial Crimes Investigation Board, any transaction where there is information, suspicion, or a matter requiring suspicion that the funds concerned come from unlawful sources or are being used for unlawful purposes. The duty has no monetary floor and does not require anyone to accuse you of anything.

Article 4(2) is what makes the branch useless to you. An obliged institution may not disclose that a suspicious transaction report has been filed to anyone outside the supervisory auditors and the courts at trial, and the prohibition expressly covers the parties to the transaction. Article 10(1) then shields the institution from civil and criminal liability for having filed. The manager who says only that the system flagged the transfer is not being obstructive; saying more is itself unlawful.

What draws a report is usually the shape of the transfer rather than its size: a first inbound wire into an account opened weeks earlier, a stated purpose that does not match the account profile, an ordering bank in a jurisdiction under enhanced scrutiny, a partial name match against a screening list, or an onward transfer out on the same day. None of that is evidence of an offence. It is the trigger that moves your file to a desk where someone now has to decide something.

The mechanism matters far more than the wording of the message your bank sent. Three separate powers can hold money in a Turkish account, and each runs on its own clock.

Under CMK 128/A(2) the suspension and the account movements go to the public prosecutor immediately with all documents, and the account holder must be notified too. You may apply to the prosecutor to have the suspension lifted, and the prosecutor decides within twenty-four hours. If the prosecutor instead orders seizure as an urgent measure, that written order goes to the judge within twenty-four hours and the judge must announce a decision within forty-eight hours of the seizure; otherwise the seizure lapses of its own accord.

CMK 128 is the heavier instrument, and it reaches only the offences listed in its second paragraph: theft, robbery, breach of trust, fraud, drug manufacture and trafficking, smuggling offences carrying imprisonment, and others. Laundering under TCK 282 is not on that list. A seizure of your account therefore has to be anchored to a listed predicate offence rather than to the suspicion that produced the report. Once ordered, it is executed by immediate notice to the bank, and any transaction designed to defeat it is void.

Nobody is weighing whether you are an honest person. Two things are being tested: that the sending account and the receiving account belong to the same person, and that the money had a lawful origin one step further back. A source-of-funds file answers both on paper, and it is worth assembling before anyone asks for it.

• The MT103 or equivalent confirmation, showing the ordering customer field with your name and the sending account number.
• Statements from the sending account covering six to twelve months before the transfer, so the balance is seen accumulating rather than appearing.
• The document behind the money: employment contract and payslips, a tax return, a notarised sale contract or land registry extract, a grant of probate, a company distribution resolution.
• Your passport and residence permit, and the account opening file held by the Turkish bank.
• Sworn Turkish translations, with an apostille on foreign public documents.

Asking someone else to receive the funds instead is worse. Under TCK 158(4), added by Law no. 7589 of 16 July 2026 and in force since 31 July 2026, the sentence is halved where participation in a fraud is limited to handing over the details or instruments needed to use an account. A reduction exists because the conduct is punished as participation in the fraud itself, not treated as a favour between friends, and that is the reasoning behind every prosecution over a bank account used to receive someone else's money.

Under CMK 131(1) seized property is returned by decision of the prosecutor, the judge or the court, on request or of their own motion, once it is no longer needed for the investigation and confiscation is out of the picture; a refusal can be appealed. CMK 131(2) adds that money seized under CMK 128 which belongs to the victim, and is no longer needed as evidence, goes back to that victim. That is why funds which merely passed through your account on their way from a defrauded sender will not be released to you, whatever your own paperwork shows.

Objections run under CMK 268: two weeks from the day you learn of the decision, by petition to the authority that made it, which either corrects itself or forwards the file within three days to the criminal judgeship next in number. Where assets were seized without the statutory conditions being met, or were not given back in time, CMK 141(1)(j) gives a claim against the State for pecuniary and non-pecuniary loss.

A frozen account rarely stays a banking problem. It is usually the visible edge of an investigation in which you are already, or are about to become, a suspect, and the same file decides whether the questions turn on laundering under TCK 282 or on the predicate offence behind the transfer. If yours has reached that point, read how an economic crime investigation in Türkiye is built and answered, and finish the source-of-funds file before the interview rather than after it.