Turkish customs investigating company bank transfers? Learn which bank records, SWIFT payments, invoices, accounting documents and shareholder transfers authorities may examine, how foreign companies can explain payment discrepancies, and how to defend customs valuation and smuggling allegations in Turkey.

When Turkish customs authorities suspect that an importer has understated the value of imported goods, used false invoices, made undeclared payments to a foreign supplier or concealed part of the purchase price through another company, the investigation can move quickly from the customs declaration to the company’s financial records. Bank transfers are particularly important because they can reveal whether the amount actually paid for imported goods corresponds with the commercial invoice and customs value declared in Turkey. A declaration showing an import value of EUR 300,000 may attract serious scrutiny if banking records appear to show EUR 500,000 transferred to the exporter or related companies. However, a bank transfer exceeding the invoice amount does not automatically prove customs fraud, fake invoicing or smuggling. The additional payment may relate to another shipment, freight, insurance, technical services, royalties, advance payments, loan repayments, tooling, commissions or an entirely separate commercial transaction. The legal question is therefore not simply how much money moved between the parties, but why the payment was made, which contractual obligation it satisfied and whether it should legally have formed part of the customs value of the imported goods. In a 2026 customs investigation, companies should expect financial evidence to become central whenever customs authorities question the economic reality of an import transaction.

Why Do Customs Authorities Examine Company Bank Transfers?

Banking records can provide independent evidence concerning the actual economic relationship between importer and exporter.

Customs authorities may compare the declared customs value with payments connected to the transaction.

A mismatch can trigger further investigation.

Example: Invoice and Bank Transfer Do Not Match

A Turkish company imports machinery.

The customs invoice states:

EUR 400,000.

Banking records show:

EUR 650,000 transferred to the foreign supplier.

The authorities may ask what the additional EUR 250,000 represents.

The company must be able to explain the difference.

A Difference Does Not Automatically Mean Undervaluation

The EUR 250,000 could represent a completely separate obligation.

For example, it might concern installation services provided after importation.

It might relate to another shipment.

It might repay an earlier advance.

It might cover spare parts imported separately.

The entire transaction history must therefore be reconstructed.

What Bank Evidence Can Become Relevant?

Depending on the legal basis and scope of the investigation, authorities may seek financial records capable of establishing the movement of funds connected with the import transaction.

This can include bank-account movements, payment instructions, international transfer information and documents identifying counterparties.

Bank Statements

Account statements can show:

the date of payment;

amount;

currency;

sender;

recipient;

payment description;

and sequence of transactions.

These records can then be compared with customs declarations.

SWIFT Records

International commercial transactions frequently involve SWIFT payment information.

These records can help establish the sending bank, receiving bank, beneficiary, amount, currency and payment reference.

For foreign companies, SWIFT documentation can therefore become highly important evidence.

Payment Instructions

Internal payment instructions may show why a particular transfer was made.

A transfer appearing suspicious in a bank statement may have a clear explanation in the company’s payment-approval records.

Beneficiary Information

Authorities may investigate whether money was transferred directly to the exporter or to another person or company.

Payments to third parties can attract additional scrutiny.

Third-Party Payments

Suppose a foreign supplier tells the Turkish importer:

“Pay EUR 150,000 of the purchase price to Company B.”

Customs authorities may examine whether Company B received part of the economic consideration for the imported goods.

The fact that money did not reach the seller’s own bank account does not necessarily make it irrelevant.

Related Companies

Payments involving affiliated companies can receive particular attention.

The investigation may examine whether payments were divided among a foreign parent company, subsidiary, distributor or other related entity.

Shareholder Accounts

Authorities may also investigate whether company shareholders personally received or made payments connected with the import transaction.

This can become particularly important where commercial funds moved outside ordinary company accounts.

Director Accounts

If a company director personally transfers money to the supplier, investigators may ask whether the payment was made on behalf of the importing company.

The company should document the reason.

Employee Accounts

Using employee bank accounts for corporate transactions can create substantial evidentiary problems.

Even where the underlying transaction is legitimate, the company may need to explain why ordinary corporate banking channels were not used.

Cash Withdrawals

Large cash withdrawals occurring around import transactions can also raise questions.

Authorities may investigate what happened to the money after withdrawal.

Cash Payment to a Foreign Supplier

Where part of an import purchase price was allegedly paid in cash, documentary evidence becomes particularly important.

The company should not attempt to create retrospective receipts after an investigation begins.

Foreign Bank Accounts

Where legally obtainable through the applicable investigative mechanisms, foreign financial information can also become relevant.

Foreign exporters should therefore assume that inconsistencies between Turkish and overseas records may eventually become visible.

Foreign Exporter Records

The foreign supplier’s bank statements can corroborate the Turkish importer’s explanation.

If the importer says it paid EUR 400,000 and the exporter’s records show receipt of EUR 400,000 for the same transaction, this can provide significant support.

Correspondent Bank Information

International payments may pass through intermediary banks.

A transaction appearing fragmented in one record may be part of a single international payment chain.

Banking documentation should therefore be interpreted carefully.

Can MASAK Become Involved?

Potentially.

MASAK operates under Law No. 5549 and has broad statutory information-gathering powers in matters falling within its mandate.

Under Article 7 of Law No. 5549, public institutions, real and legal persons and organizations without legal personality are required to provide information, documents and records requested by MASAK and authorized inspection personnel, together with information necessary to access or make those records readable. (Hazine ve Maliye Bakanlığı)

Electronic Records Can Also Be Requested

The statutory framework is not limited to paper documents.

MASAK expressly explains that information and records held in any medium can fall within the information-and-document obligation. (Hazine ve Maliye Bakanlığı)

For companies, this means financial evidence may extend beyond printed bank statements.

Accounting Records Can Become Important

Investigators may compare bank transactions with accounting entries.

If EUR 300,000 was declared as an inventory purchase but another EUR 200,000 was recorded elsewhere, the treatment of the additional payment may be examined.

General Ledger Records

The general ledger can reveal how payments were classified internally.

This can help determine whether a payment genuinely related to goods, services, financing or another transaction.

Supplier Ledgers

Accounts payable records may show how much the company actually owed the foreign supplier.

This is particularly useful where payments were made in installments.

Bank Reconciliation Records

These records can connect accounting entries with actual bank movements.

They may become important where authorities suspect undisclosed payments.

Trial Balances

Accounting balances can also help reconstruct the commercial relationship between the importer and supplier.

ERP Records

Large companies often manage purchase orders, invoices, approvals and payments through ERP systems.

These records can provide powerful evidence concerning transaction chronology.

ERP Metadata Can Be Important

The system may show:

when the purchase order was created;

who approved it;

when the invoice was entered;

whether the amount was changed;

and when payment was authorized.

This can help rebut allegations that documents were created after customs scrutiny began.

Invoice Records

The authorities may compare banking movements against the invoice submitted with the customs declaration.

Any difference should be explained.

Pro Forma Invoices

A pro forma invoice may contain a different amount from the final commercial invoice.

This does not necessarily indicate wrongdoing.

The company should preserve both documents and explain why the amount changed.

Purchase Orders

Purchase orders can demonstrate the original commercial terms agreed before shipment.

They can be particularly useful where authorities suspect that an invoice was altered later.

Sales Contracts

The underlying agreement may identify the price, delivery terms, services, royalties, commissions and other payments associated with the transaction.

Contract Amendments

If the price changed after the original agreement, amendments should be preserved.

Do not replace the original contract with an amended version.

The chronology itself is evidence.

Commercial Correspondence

Emails and business communications can reveal how the parties negotiated the price.

They may also explain payments that appear unrelated when viewed only through a bank statement.

Payment Reference Emails

For example, an accounts-payable employee may have written:

“EUR 75,000 payment relates to Invoice 2026-104, while EUR 20,000 relates to engineering services.”

That contemporaneous explanation can be important.

WhatsApp and Other Messaging Records

Commercial negotiations increasingly take place through messaging applications.

Where legally obtained and relevant, these communications can become part of the evidentiary picture.

Companies should preserve them once an investigation is anticipated.

Do Not Delete Financial Communications

Deleting emails or messages after learning of an investigation can create additional evidentiary difficulties.

Existing records should be preserved in their original form.

What Can MASAK Request From Banks?

Banks and other covered financial institutions operate under extensive obligations arising from Law No. 5549 and related regulations.

MASAK’s current guidance explains that covered entities must provide requested information and documents and must preserve relevant documentation and records for the applicable statutory period. (Hazine ve Maliye Bakanlığı)

How Long Are Relevant MASAK Records Preserved?

MASAK states that covered entities must generally preserve relevant documents and records for eight years, with the starting point depending on the type of record. (Hazine ve Maliye Bakanlığı)

This means older transactions may still leave substantial financial documentation.

Banks Also Have Customer Identification Information

Financial institutions must comply with customer-identification requirements.

MASAK explains that institutions subject to these obligations must identify persons conducting transactions and persons on whose behalf or account transactions are conducted. (Hazine ve Maliye Bakanlığı)

This can help authorities determine who actually controlled or benefited from particular transfers.

Beneficial Ownership Can Become Relevant

Where payments move through multiple companies, authorities may seek to understand who ultimately controls or benefits from those entities.

Complex corporate structures do not necessarily prevent investigation of the underlying transaction.

Suspicious Transaction Reports

Banks and other covered entities have suspicious-transaction reporting obligations where statutory suspicion criteria are met.

MASAK explains that transactions involving assets suspected of having unlawful origins or unlawful intended use must be reported under Article 4 of Law No. 5549. (Hazine ve Maliye Bakanlığı)

Can a Company Ask Whether Its Bank Filed a Suspicious Transaction Report?

Generally, the reporting regime contains strict confidentiality requirements.

MASAK states that covered entities cannot disclose to transaction parties or others that a suspicious transaction report was submitted, except within the legally defined exceptions. (Hazine ve Maliye Bakanlığı)

Therefore, a company should not assume that the bank can tell it whether a particular transfer generated a report.

A Suspicious Transaction Report Is Not Proof of a Crime

A suspicious transaction reporting mechanism is designed to identify transactions requiring examination.

It should not be confused with a final judicial finding that money laundering, customs fraud or another crime occurred.

Customs Investigation and MASAK Investigation Are Not Identical

Customs authorities may investigate whether the import declaration was accurate.

MASAK may examine financial activity within its statutory mandate.

Prosecutors may separately investigate suspected criminal conduct.

These processes can intersect without becoming legally identical.

A Company May Face Several Files at Once

For example:

Customs file: Was the correct customs value declared?

MASAK analysis: What financial transactions occurred?

Criminal investigation: Was there intentional criminal conduct?

Administrative penalty proceeding: Are additional duties and penalties payable?

Each issue requires separate analysis.

Customs Value Is Often the Connecting Point

Bank transfers become especially significant where customs authorities suspect that the amount declared as the transaction value does not represent the real economic payment for the imported goods.

Example: EUR 500,000 Declared, EUR 800,000 Transferred

The importer declares EUR 500,000.

Bank records show EUR 800,000 transferred to the supplier.

Customs may initially suspect that EUR 300,000 of the purchase price was concealed.

But further investigation reveals:

EUR 500,000 = imported machinery;

EUR 150,000 = installation services;

EUR 100,000 = spare parts under another shipment;

EUR 50,000 = repayment of an earlier commercial advance.

The company must prove this allocation.

Create a Transfer-to-Invoice Matrix

For each bank transfer, identify:

date → sender → recipient → amount → currency → payment reference → contract → invoice → shipment → customs declaration.

This is one of the most useful defensive tools in a financial customs investigation.

One Payment May Cover Several Invoices

International companies often make consolidated payments.

A EUR 1 million transfer might settle five invoices.

The company should produce the payment allocation.

One Invoice May Be Paid Through Several Transfers

The reverse can also occur.

A EUR 1 million invoice may be paid through a EUR 200,000 advance followed by four installments.

Again, reconciliation is essential.

Advance Payments

An advance payment made months before shipment can appear disconnected from the import transaction.

Purchase agreements and accounting records should establish the connection.

Deposits

A refundable deposit may not necessarily constitute payment for imported goods.

Its legal and customs treatment must be evaluated according to the transaction.

Loan Transactions

A Turkish company may simultaneously owe its foreign parent money under both a goods purchase and an intercompany loan.

Bank transfers between them cannot simply be assumed to represent the import purchase price.

Intercompany Loans Require Documentation

The loan agreement, repayment schedule, accounting entries and interest calculations should be preserved.

Without these documents, an alleged loan repayment may appear to be a concealed purchase-price payment.

Capital Contributions

A shareholder may transfer funds to the Turkish company as capital rather than as payment for imported goods.

Corporate resolutions and accounting treatment can demonstrate the distinction.

Dividend Payments

A Turkish subsidiary may transfer dividends to a foreign shareholder that also happens to supply goods.

The legal basis for the dividend should be documented independently from import transactions.

Management Fees

Multinational groups frequently make management-service payments.

These should be supported by contracts and invoices.

The customs-value consequences of particular payments require separate analysis.

Royalty Payments

Royalty arrangements deserve special attention.

Where a royalty or license payment is connected with imported goods, its customs valuation treatment may become legally significant.

The company should not assume that simply labeling a payment “royalty” removes it from customs scrutiny.

Commission Payments

Commissions paid to agents or intermediaries may also need to be analyzed.

Authorities may ask what services were provided and whether the payment relates economically to the imported goods.

Freight Payments

Payments to carriers should be documented separately.

Bills of lading, freight invoices and payment records can demonstrate why money associated with a shipment did not constitute additional payment to the seller.

Insurance Payments

Cargo insurance premiums can similarly appear in the overall financial history of an import transaction.

Their treatment should be distinguished from the supplier payment.

Tooling and Mould Costs

Manufacturing arrangements sometimes require the importer to finance tooling, moulds or production equipment.

These payments can create complex customs valuation questions.

They should be analyzed rather than automatically excluded.

Free-of-Charge Goods

The absence of a supplier payment does not necessarily mean that goods have no customs value.

Customs valuation rules must still be applied.

Credit Notes

A supplier may later issue a credit note.

The company should explain why it was issued and how it was accounted for.

Refunds From the Supplier

A later refund can also attract attention.

Investigators may ask whether the original declared price was genuine or subsequently adjusted.

The contractual explanation should be documented.

Currency Differences

Payments and invoices may appear inconsistent because of currency conversion.

Companies should identify the currency specified in the contract and the exchange-rate treatment.

Payment Dates Matter

A customs declaration and bank transfer may occur months apart.

The transaction should be examined chronologically rather than by comparing isolated numbers.

What If the Importer Used Several Banks?

Authorities may need to reconstruct payments across multiple financial institutions.

The company should do the same internally before submitting its defense.

Foreign Currency Accounts

EUR, USD, GBP and TRY accounts should all be reviewed where relevant.

Looking at only one currency account can create a misleading picture.

Payment Institutions

Modern companies may also use payment or electronic-money institutions.

MASAK identifies payment and electronic-money institutions among entities subject to relevant AML obligations. (Hazine ve Maliye Bakanlığı)

Cryptocurrency Transfers

If cryptocurrency was used in connection with an import transaction, the investigation can become substantially more complex.

The company may need to establish wallet ownership, transaction history, exchange records and the commercial purpose of the transfer.

Personal Cryptocurrency Wallets Create Additional Risk

Using a shareholder’s or director’s personal wallet for company payments can make the financial trail harder to explain.

Corporate documentation becomes particularly important.

Can Authorities Request Company Accounting Software Records?

Depending on the legal authority and investigation, electronic records can be relevant.

Law No. 5549 expressly encompasses information, documents and records in various media and can require information necessary to make records accessible or readable. (Hazine ve Maliye Bakanlığı)

Can Passwords or Access Information Be Requested?

Within the specific framework of Law No. 5549, MASAK states that persons subject to an information request must provide information necessary to access records or make them readable. (Hazine ve Maliye Bakanlığı)

The precise scope of any individual request should nevertheless be reviewed according to its legal basis and the procedural status of the person or company concerned.

Defense Rights Still Matter

Article 7 of Law No. 5549 itself expressly preserves provisions relating to the right of defense while imposing information-and-document obligations. (Hazine ve Maliye Bakanlığı)

Companies should therefore distinguish a lawful information request from questions concerning individual criminal defense rights.

Company Records and Individual Statements Are Different

Producing existing corporate records is not conceptually identical to a manager giving a substantive statement concerning alleged criminal conduct.

Managers should understand their procedural status.

Is the Director a Witness or Suspect?

This should be clarified before detailed questioning.

A director suspected of participating in false invoicing may have a materially different procedural position from an accounting employee asked to identify payment records.

Do Not Guess About Bank Transfers

A manager should not invent an explanation for a payment they do not recognize.

The accounting and commercial records should be checked first.

Incorrect Explanations Can Become Difficult to Reverse

Suppose a director initially says a EUR 200,000 payment was a loan repayment.

Records later show it was a royalty payment.

Even an innocent mistake can undermine credibility.

Identify the Actual Employees Responsible

The company should determine who:

negotiated the purchase;

approved the supplier;

approved the invoice;

authorized the bank payment;

recorded the transaction;

and instructed the customs broker.

Dual Approval Systems Can Provide Evidence

Corporate payment approval records can demonstrate that transactions followed established internal controls.

Internal Audit Reports

Existing internal audit reports may also help explain historical financial transactions.

Their legal treatment should be reviewed before disclosure.

Do Not Manufacture Documentation

A company should never create a loan agreement after the investigation begins and pretend it existed when the transfer was made.

This can turn an explainable banking discrepancy into a much more serious evidentiary problem.

Preserve Original Records

Original contracts, invoices, bank statements, ERP logs and emails should remain intact.

What If the Bank Transfer Description Is Wrong?

Companies frequently use generic descriptions such as “payment,” “invoice,” or “goods.”

A poor payment reference does not necessarily determine the true legal nature of the transfer.

The underlying records must be examined.

Example: “Goods Payment”

A transfer is labeled “goods payment.”

The company claims it actually relates to installation services.

That explanation is possible, but stronger supporting evidence will be necessary because the payment description points in another direction.

What If the Transfer Has No Description?

Then contracts, accounting entries, emails and invoice reconciliation become even more important.

Related-Party Payments Require a Full Group Map

Multinational companies should identify all entities involved in the transaction.

For example:

Turkish importer;

German parent company;

Chinese manufacturer;

Dutch treasury company;

UAE distributor.

Money may move through several entities even though the goods move directly from China to Turkey.

Centralized Treasury Systems

Large corporate groups often make payments through treasury centers.

A payment from an entity other than the importer does not automatically indicate concealment.

The treasury arrangement should be documented.

Cash Pooling

Intercompany cash-pooling systems can similarly create bank movements that look unrelated to ordinary invoices.

Treasury agreements and accounting records can explain them.

Customs Authorities May Examine Economic Substance

The defense should therefore explain the real commercial structure, not merely the legal names appearing on bank statements.

Previous Imports Can Be Reviewed

If authorities identify a suspicious payment pattern for one shipment, earlier imports involving the same supplier may receive additional scrutiny.

Audit Historical Bank Transfers

The company should compare previous customs declarations against supplier payments.

This internal review can identify recurring discrepancies before authorities raise them.

Example: Monthly Understatement Allegation

Customs alleges that a company declared EUR 100,000 each month but transferred EUR 130,000 to the supplier.

If the pattern continued for three years, the potential exposure can become substantially larger than the current shipment.

Determine Whether the Extra EUR 30,000 Has a Consistent Explanation

If it represents a monthly software license or management service, documentation should exist throughout the period.

A newly created explanation will naturally receive greater scrutiny.

Bank Records Can Support the Company Too

Financial evidence is not only an investigative tool.

It can be some of the strongest defense evidence available.

Example: Customs Suspects a Fake Invoice

Customs alleges that the actual purchase price was EUR 800,000 rather than EUR 500,000.

The company produces:

the sales agreement;

EUR 500,000 invoice;

EUR 500,000 SWIFT transfer;

foreign supplier ledger showing EUR 500,000 receivable;

exporter’s bank receipt;

and accounting records recording EUR 500,000.

That consistent financial trail can strongly support the company’s position.

Financial Evidence Should Be Presented Systematically

Dumping thousands of bank pages into the file can obscure the defense.

Create a structured reconciliation.

Prepare a Transaction Evidence Matrix

For each shipment:

Customs Declaration | Invoice | Contract Price | Bank Payment | Recipient | Accounting Entry | Export Record | Explanation

This allows discrepancies to be identified immediately.

Prepare a Bank Transfer Chronology

Arrange transactions by date.

Chronology can reveal that a supposedly suspicious transfer actually preceded or followed an unrelated commercial event.

Prepare a Counterparty Map

Where multiple foreign entities received payments, explain their relationship and role.

Prepare an Accounting Reconciliation

Every relevant bank movement should correspond with an accounting entry.

Unreconciled transfers should be investigated internally.

What If the Company Discovers a Genuine Undeclared Payment?

The company should not conceal it.

Its legal significance must be assessed.

A genuine customs valuation error, deliberate false declaration and unrelated accounting problem can produce very different consequences.

Do Not Assume Every Error Is Smuggling

Criminal responsibility and administrative customs liability require separate legal analysis.

The existence of an additional payment does not automatically establish intentional criminal conduct.

Anti-Smuggling Investigation

Where authorities suspect that payments demonstrate deliberate concealment of the true import value, the investigation may move into the Anti-Smuggling Law framework.

The company should determine whether a prosecutor’s investigation exists.

Obtain the Investigation Number

Identify the Public Prosecutor’s Office and investigation file.

The customs and criminal files should then be coordinated.

Company Directors Can Face Individual Scrutiny

Investigators may ask who approved the transfer and whether that person knew what was declared to customs.

Signature Authority Alone Is Not Enough to Explain Responsibility

A director may technically authorize payments without participating in customs classification or valuation.

Actual conduct should be established.

Customs Broker Evidence

The company should also preserve what information was provided to the customs broker.

If the broker received the genuine invoice and payment information, that may become important.

What If the Broker Received a Different Invoice?

The company must identify who created and transmitted it.

Email attachments and document metadata may become decisive.

Can Company Accounts Be Frozen?

In serious criminal or money-laundering investigations, financial assets can potentially become subject to protective measures where the statutory requirements are satisfied.

A bank’s internal compliance restriction, a MASAK-related measure and a prosecutor or court seizure measure should not automatically be treated as the same thing.

Obtain the Legal Basis for Any Freeze

The company should determine:

which authority imposed it;

which accounts are affected;

the date of the measure;

and the investigation file.

A Bank Saying “Compliance Review” Is Different From a Judicial Seizure

The legal remedies may differ substantially.

The company should obtain accurate information before filing objections.

Business Continuity Should Be Addressed

A frozen operating account can prevent payroll, tax payments, supplier payments and customs clearance.

The company should document these consequences immediately.

Can Authorities Request Information Directly From the Company?

Under the Law No. 5549 framework, MASAK’s statutory information power extends to public bodies, natural persons, legal entities and organizations without legal personality. (Hazine ve Maliye Bakanlığı)

Accordingly, companies should take formal information requests seriously.

What Happens If Requested Information Is Not Provided?

Failure to comply with applicable statutory information and documentation obligations can create separate legal consequences.

The company should not simply ignore a formal request because it considers the underlying investigation unjustified.

But the Scope Should Still Be Reviewed

The legal basis, authority, requested period and categories of records should be identified.

This allows the company to produce responsive evidence accurately while protecting applicable procedural rights.

Foreign Companies Should Coordinate Evidence Across Countries

The Turkish importer may hold the customs declaration.

The foreign exporter may hold the original invoice.

A European treasury company may hold the payment documentation.

The parent company may hold the supply agreement.

All relevant records should be coordinated.

Foreign Accounting Evidence Can Be Critical

Where Turkish customs questions whether the foreign seller genuinely received only the declared amount, the seller’s ledger and bank account can provide independent corroboration.

Translation Should Be Planned Early

Foreign bank statements and contracts may need Turkish translation for effective use in proceedings.

Waiting until an objection deadline approaches can cause unnecessary difficulties.

The First 24 Hours After a Financial Customs Investigation Begins

The company should preserve bank statements, SWIFT records, invoices, contracts, ERP records and accounting data; identify the investigated shipments; determine whether MASAK or prosecutors are involved; and prevent automatic deletion of relevant electronic records.

The First 72 Hours

Management should reconcile the declared customs values against actual supplier payments, identify third-party and related-party transfers, classify each payment according to its commercial purpose and determine whether any unexplained difference exists.

The First Week

The company should complete an initial financial reconstruction, audit previous transactions involving the same supplier, identify potential customs valuation issues, calculate possible exposure and develop separate strategies for customs, MASAK and criminal proceedings where applicable.

What Companies Should Never Do

Companies should not create retrospective service agreements to explain suspicious transfers, backdate loan agreements, alter payment descriptions, replace invoices, delete banking emails, destroy accounting records or pressure employees to provide false explanations.

The financial trail is often independently preserved by banks and counterparties.

Manipulating internal records can therefore make the defense substantially worse.

2026 Legal Strategy for Customs Investigations of Company Bank Transfers

A foreign company or Turkish importer facing scrutiny of bank transfers in a customs investigation should first reconstruct the complete financial history of each challenged import transaction. Every customs declaration should be matched with the corresponding commercial invoice, purchase contract, bank transfer, SWIFT record and accounting entry. Payments exceeding the declared invoice value should then be classified individually to determine whether they concern imported goods, another shipment, services, freight, insurance, royalties, commissions, loans, dividends, capital contributions or another commercial obligation. Third-party and related-company payments require particular attention because authorities may examine their economic connection with the imported goods. If MASAK becomes involved, companies should understand that Law No. 5549 provides significant information-and-document powers while expressly preserving defense-right considerations. (Hazine ve Maliye Bakanlığı) The company should also audit historical imports involving the same supplier because one unexplained payment pattern can lead to examination of multiple declarations. The practical strategy is therefore: identify the investigated imports → preserve all financial evidence → match declarations with invoices → reconcile every bank transfer → trace SWIFT payments → explain third-party transfers → separate goods payments from services and financing → verify accounting and ERP records → examine related-party transactions → review previous imports → determine whether MASAK or a prosecutor is involved → protect individual defense rights → challenge unsupported customs valuation conclusions → address any account-freezing measures → pursue the appropriate administrative and judicial remedies.

Frequently Asked Questions

1. Can Turkish authorities examine a company’s bank transfers during a customs investigation?

Potentially, yes. Financial records can become important where authorities investigate customs value, invoice authenticity, undeclared payments or suspected criminal conduct. MASAK also has broad statutory information-and-document powers under Law No. 5549. (Hazine ve Maliye Bakanlığı)

2. Can MASAK request company documents and electronic records?

Yes, within its statutory authority. Law No. 5549 requires requested persons and entities to provide qualifying information, documents and records, including information needed to access or render electronic records readable. (Hazine ve Maliye Bakanlığı)

3. Does a bank transfer larger than the customs invoice prove undervaluation?

No. The difference may concern services, another shipment, financing, freight, royalties or another commercial obligation. The company should prove the reason through contemporaneous records.

4. Can authorities investigate transfers to companies other than the foreign exporter?

Potentially. Third-party payments may be relevant where authorities suspect that they economically represent part of the consideration for the imported goods.

5. Can shareholder or director bank transfers become relevant?

Yes, particularly where personal accounts were used to make or receive payments connected with company imports. The commercial purpose of those transfers should be documented.

6. Can the company find out whether its bank made a suspicious transaction report?

Generally, the reporting framework restricts disclosure. MASAK explains that covered entities may not disclose suspicious transaction reporting to transaction parties except within statutory exceptions. (Hazine ve Maliye Bakanlığı)

7. How long can relevant AML records be retained?

MASAK states that covered entities generally have an eight-year preservation obligation for relevant documents and records, with the starting date depending on the type of record. (Hazine ve Maliye Bakanlığı)

8. Can bank records help defend the importer?

Absolutely. Consistent invoices, SWIFT transfers, supplier bank receipts and accounting records can provide strong evidence that the declared transaction genuinely occurred at the stated price.

9. Can a customs investigation of bank transfers become a criminal investigation?

Potentially. If authorities suspect intentional concealment, fake invoicing, smuggling or laundering of criminal proceeds, separate criminal proceedings may arise. Administrative customs liability and criminal responsibility should be analyzed independently.

10. What should a foreign company do first when authorities begin examining its bank transfers?

Preserve the bank and SWIFT records, identify every challenged customs declaration, reconcile payments against invoices and contracts, investigate unexplained transfers, determine whether MASAK or prosecutors are involved and preserve all applicable procedural rights.

Legal Support for Customs Investigations of Company Bank Transfers in Turkey

Customs investigations involving company finances can expand rapidly from a single import declaration into an examination of bank statements, SWIFT transfers, supplier payments, shareholder and director transactions, third-party payments, accounting records, ERP systems, customs valuation, fake-invoice allegations, MASAK analysis and Anti-Smuggling Law proceedings.

Fırat Fesih Kaya Law Office provides legal assistance to foreign exporters, Turkish importers, multinational groups and foreign-owned companies facing customs and financial investigations in Turkey.

Fırat Fesih Kaya can reconstruct disputed import transactions, analyze company bank transfers and customs declarations, coordinate financial evidence, challenge customs valuation and false-invoice allegations, represent companies and managers in customs and criminal proceedings, address seizure or account-freezing measures and pursue appropriate administrative and judicial remedies.

Phone: +90 312 434 22 22
Mobile Phone: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yildirim Tower, Balgat, Cankaya / Ankara, Turkey