

Foreign Company Bank Account Frozen in Turkey | Criminal Investigation & Legal Remedies 2026
What can a foreign company do when its Turkish bank account is frozen? Learn about MASAK investigations, prosecutor seizure orders, suspicious transfers, company director liability, source-of-funds evidence and legal remedies in Turkey.
A foreign-owned company whose bank account is frozen in Turkey can face immediate operational problems: salaries cannot be paid, suppliers may stop deliveries, tax and social security payments can be disrupted, commercial contracts may be breached and ordinary business operations may become impossible. However, a frozen corporate bank account does not automatically mean that the company, its foreign shareholders or its directors have committed money laundering, fraud or another financial crime. The first and most important question is the legal basis of the restriction. What businesses commonly describe as a “MASAK freeze” may actually arise from an internal bank compliance review, a temporary transaction suspension under Turkey’s anti-money-laundering legislation, or a judicial seizure measure connected with a prosecutor’s criminal investigation. Under Law No. 5549, suspicious transactions must be reported where the statutory suspicion criteria are satisfied, while Article 19/A provides a separate mechanism under which qualifying transactions suspected of links to money laundering or terrorism financing can be suspended for up to seven working days. Criminal investigations can separately result in seizure measures over assets where the applicable legal requirements are satisfied. (Hazine ve Maliye Bakanlığı)
Corporate accounts can become subject to scrutiny where the bank or authorities identify unusual transactions, unexplained international transfers, payments inconsistent with the company’s stated commercial activity, funds allegedly connected with fraud victims, rapid transfers through several companies, cryptocurrency transactions, suspicious cash movements or transactions involving persons already under criminal investigation. Foreign ownership itself does not make a Turkish company suspicious. A company legitimately engaged in international trade may naturally receive substantial payments from abroad and make significant cross-border transfers. The issue usually becomes whether the economic purpose, source of funds, counterparties and ultimate beneficiaries of the transactions can be demonstrated.
This distinction is extremely important. Banks have their own anti-money-laundering and customer due diligence obligations. Law No. 5549 requires obliged institutions to identify customers and take relevant customer-identification measures. The same legislation requires suspicious transaction reporting where there is information, suspicion or grounds requiring suspicion that the assets involved were illegally obtained or are being used for unlawful purposes. (Hazine ve Maliye Bakanlığı) A bank may therefore request invoices, contracts, shareholder information, beneficial ownership information or explanations concerning transactions without there necessarily being an indictment or even an active prosecutor investigation against the company.
A suspicious transaction report is a regulatory report made under the AML framework. It does not constitute a criminal conviction and does not itself establish that the company’s funds represent criminal proceeds. Banks are also generally prohibited from informing transaction parties that a suspicious transaction report has been submitted. (Hazine ve Maliye Bakanlığı) This explains why companies sometimes receive very limited information when they ask the bank why their transactions are being examined.
The bank may be legally restricted in what it can disclose. The company should therefore avoid assuming that the bank’s refusal to provide details proves that MASAK has ordered a permanent freeze. The legal source of the restriction must be determined separately.
A bank may conduct enhanced compliance checks concerning the company, its beneficial owners, shareholders, directors or transactions. During that process, particular banking services may be restricted depending on the circumstances and contractual and regulatory framework.
Article 19/A of Law No. 5549 establishes a separate mechanism where assets involved in a transaction are suspected of links to laundering or terrorism financing. Qualifying transactions can be suspended or prevented from being completed for up to seven working days so that the suspicion can be verified and analyzed and the results can be transmitted to competent authorities where necessary. (Hazine ve Maliye Bakanlığı)
This is one of the most common misunderstandings in practice. The seven-working-day period relates to the specific Article 19/A transaction-suspension mechanism. A prosecutor investigation may separately result in judicial asset restrictions governed by different provisions. MASAK’s own guidance confirms that the seven-working-day period relates to the transaction-postponement mechanism. (Hazine ve Maliye Bakanlığı)
Where there is strong suspicion of money laundering or terrorism financing, Article 17 of Law No. 5549 permits seizure of assets through the procedure connected with Article 128 of the Criminal Procedure Code. (Hazine ve Maliye Bakanlığı) A corporate account restriction imposed through criminal proceedings must therefore be distinguished from ordinary bank compliance controls.
Law No. 5549 also provides a special procedure for urgent circumstances. A public prosecutor may issue a seizure decision where delay would be prejudicial. A seizure implemented without a judicial decision must be submitted to the competent judge within 24 hours, and the judge must decide whether to approve it within a further 24 hours. Where approval is given, the statutory report concerning the value under Article 128 must be obtained within three months and submitted again for judicial approval; otherwise, the prosecutor’s decision becomes ineffective under the provision. (Hazine ve Maliye Bakanlığı)
Because the legal remedy depends on what actually happened. A company cannot effectively challenge a prosecutor’s seizure order by treating the issue merely as a customer-service dispute with the bank. Likewise, a company dealing only with a compliance review should not automatically assume that it has been formally accused of money laundering.
The company should establish whether the restriction originates from the bank itself, an AML-related transaction suspension, a prosecutor’s office or a court-related criminal measure.
Where the restriction originates from criminal proceedings, identifying the prosecutor’s investigation file is an important step toward understanding the allegations and available remedies.
A company may have several accounts at one bank. The restriction may affect one transaction, one account, all accounts at that bank or potentially accounts at several institutions depending on the underlying measure.
The defense should determine which transaction or transaction pattern apparently caused the problem.
One common scenario involves a corporate account receiving money later identified as belonging to a fraud victim.
A Turkish company with foreign shareholders provides technology consulting services. TRY 2 million enters its account from several individuals. The company’s local commercial manager claims the payments relate to customers and subsequently transfers most of the funds to another company. Several senders later file criminal complaints alleging investment fraud. The company account can become part of the financial investigation even if the foreign shareholders never communicated with the alleged victims.
Not automatically. Criminal liability must be individualized.
A foreign investor may own 70% or even 100% of a Turkish company without personally conducting daily banking transactions.
Formal management authority can be relevant, but prosecutors should examine actual conduct, knowledge, banking authority and participation.
This question can become central to the defense.
Determine which directors, employees, accountants or financial managers had access to corporate internet banking.
Banking security records may help establish who actually executed particular transactions.
Corporate authorization rules and bank mandates should be examined.
Emails, WhatsApp conversations and commercial correspondence may identify the person responsible for the transaction.
Following the money beyond the corporate account can be extremely important.
A foreign shareholder living abroad may have delegated Turkish operations to a local director. If the local director subsequently uses the company account for unauthorized or criminal transactions, evidence establishing the actual division of responsibilities becomes crucial.
Board resolutions, powers of attorney, signature circulars, banking authorizations, employment agreements and internal approval procedures can help establish who controlled company finances.
Backdating board resolutions or changing accounting entries can seriously undermine the credibility of the defense.
Foreign-owned companies frequently receive and send large amounts because of import, export, manufacturing and distribution activities.
A EUR 3 million payment for machinery can be completely legitimate.
The company should be able to connect the banking transaction with the underlying business activity.
Relevant evidence may include purchase agreements, commercial invoices, customs declarations, transportation documents, bills of lading and delivery documentation.
Export declarations, invoices, shipping records and customer correspondence can establish the commercial basis for incoming funds.
Where the company provides consulting, software, engineering or other services, the contract alone may not be sufficient.
Reports, project files, emails, deliverables and customer communications can become important.
Financial-crime investigations sometimes involve allegations that invoices were generated merely to provide an apparently commercial explanation for suspicious transfers.
Authorities may examine whether goods were delivered or services actually performed.
Foreign corporate groups frequently transfer money between subsidiaries, parent companies and affiliates.
Shareholder loans, capital contributions, management fees, licensing fees, cost-sharing arrangements and intercompany service payments should be properly documented.
A payment should not simply be described as “company money” if it was actually a shareholder loan. The underlying legal and accounting documentation should reflect the genuine transaction.
Capital injections should correspond with corporate resolutions, accounting records and the relevant corporate-law procedures.
Dividend payments should be supported by the appropriate corporate decisions and financial records.
Intellectual-property agreements and calculations supporting the payment should be preserved.
Financial institutions are required to understand relevant customer and beneficial ownership structures. MASAK guidance also addresses identification of beneficial owners and particular attention to legal entities. (Hazine ve Maliye Bakanlığı)
A Turkish company owned through holding companies in several jurisdictions is not inherently unlawful. However, the actual beneficial ownership structure should be explainable.
Where formal shareholders differ from the persons actually controlling the business, authorities may investigate the real economic relationship.
The company should establish the origin of every substantial disputed payment.
Where the company received substantial investment from a foreign shareholder, authorities or compliance departments may also seek evidence explaining how the investor acquired the underlying wealth.
A foreign shareholder transfers EUR 4 million into the Turkish subsidiary.
The immediate source is the shareholder’s Swiss bank account.
But the complete evidence may establish:
Sale of Foreign Company → EUR 6 Million Sale Proceeds → Shareholder’s Bank Account → EUR 4 Million Capital Investment → Turkish Company Account.
That documentary chain can provide a coherent lawful explanation.
Historical statements can be crucial where capital originated abroad.
Share purchase agreements, dividend resolutions and audited financial statements may establish the origin of investment capital.
Tax documentation may further support the legitimate accumulation of wealth.
Corporate cryptocurrency transactions can receive significant scrutiny where they form part of disputed financial flows.
A company’s use of cryptocurrency does not itself establish money laundering.
The company should be able to reconstruct:
Corporate Bank Account → Cryptocurrency Platform → Cryptocurrency Purchase → Wallet → Subsequent Transaction → Final Beneficiary.
Do not assume that access to the platform will remain available throughout the investigation.
Blockchain records may become important evidence for both investigators and the defense.
This requires immediate preservation of internal evidence.
Objective evidence is needed.
Who could initiate transfers?
Did the employee require director authorization?
Were suspicious transactions discussed internally?
Did the employee transfer money to personal accounts or related persons?
The employee’s role and authority should be documented.
Foreign investors can discover that a local partner has used company banking facilities for transactions outside the agreed business.
Bank statements, internal emails, accounting records and corporate documents can become difficult to obtain after a shareholder dispute escalates.
The conduct may potentially create both corporate-law disputes and criminal-law issues.
A legitimate business can become indirectly affected because it received funds from a customer who is suspected of criminal activity.
The underlying commercial relationship should be examined.
If the company sold machinery worth TRY 5 million and legitimately received TRY 5 million, the contract, invoice, delivery and accounting evidence can be highly significant.
Where appropriate to the business model, records showing how the counterparty relationship was established may also become relevant.
The scope of any judicial measure should be examined carefully rather than assumed to be unlimited.
A corporate account may contain legitimate operating revenue alongside one disputed transfer.
Prepare an account analysis identifying Opening Balance → Ordinary Business Revenue → Disputed Transfer → Subsequent Transactions → Current Balance.
If TRY 15 million was already in the account before a disputed TRY 500,000 payment arrived, the lawful origin of the pre-existing funds should be demonstrated.
Depending on the alleged offense and applicable judicial measures, a financial investigation may extend beyond a bank account.
Law No. 5549 Article 17 provides for asset seizure through the procedure under Article 128 of the Criminal Procedure Code where strong suspicion exists concerning laundering or terrorism financing. (Hazine ve Maliye Bakanlığı)
Where investigators allege that assets or corporate structures were used in connection with criminal proceeds, ownership interests may become part of the investigation depending on the circumstances.
This distinction is essential. A procedural seizure during an investigation is not equivalent to final confiscation following criminal proceedings.
Potentially, but the appropriate legal route depends on the nature of the restriction.
The company may need to provide corporate KYC, beneficial ownership and transaction documentation and address the restriction through the banking relationship.
The statutory mechanism and applicable timeframe must be identified correctly.
Where the account has been restricted pursuant to a criminal-procedure decision, the defense should obtain and examine the decision and use the remedies available under the applicable procedural rules.
A corporate account should not be treated as criminal property merely because one questioned transaction passed through it.
Invoices, tax declarations, payroll records and historical account activity can establish that substantial portions of the account derive from ordinary business.
Where a measure affects assets substantially beyond the disputed transaction, the evidentiary connection and proportionality should be examined within the relevant procedural framework.
A complete corporate freeze can prevent payment of employees, taxes, rent, suppliers, utilities and contractual obligations.
The company should create a clear record showing the concrete consequences of the restriction.
Identify unpaid payroll obligations.
Document statutory payments that are becoming due.
Identify suppliers whose non-payment threatens operations.
Record unavoidable operating expenses.
Identify contractual penalties or termination risks created by inability to make payments.
Where legally relevant, the actual impact of a broad restriction can support arguments concerning the scope and proportionality of the measure.
Creating alternative payment routes solely to circumvent a lawful restriction can create further problems.
This can make legitimate business revenue appear intentionally concealed.
Such conduct can significantly complicate the defense.
Contemporaneous evidence is much stronger.
Communications can establish who negotiated and authorized disputed transactions.
Preserve both electronic and physical records.
Export original transaction histories.
Different witnesses giving artificially identical explanations can create credibility problems.
A serious financial-crime investigation may involve investigative measures concerning company premises and records where the statutory conditions are satisfied.
Computers, accounting systems, emails and corporate messaging records may become important.
A foreign director may be questioned concerning corporate transactions even where daily operations were delegated.
Financial investigations can concern transactions occurring years earlier.
The director should understand the date, amount, sender, recipient and alleged concern.
Foreign directors who do not adequately understand Turkish should ensure that criminal proceedings and statements are properly understood.
Precise language concerning authority, knowledge and banking control can materially affect the investigation.
Turkish criminal-law analysis generally requires careful distinction between the conduct attributed to natural persons and legal consequences potentially applicable to legal entities.
One shareholder may have actively managed the company while another was a passive investor.
One director may control finances while another handles technical operations.
Actual authority should be established.
A transaction may pass through a company but ultimately benefit another person.
This can fundamentally change the defense.
Alleged Victim → Turkish Company → Supplier Company → Individual X
If Individual X controlled both companies and received the ultimate benefit, that relationship may be more significant than the fact that a passive foreign shareholder formally owned shares in the first company.
Identify every affected account, obtain whatever information the bank can legally provide concerning the restriction, preserve complete account statements, identify recent unusual transactions and determine whether a prosecutor or court file exists.
Prepare a transaction map for each disputed payment:
Sender → Amount → Contract → Invoice → Commercial Purpose → Company Account → Subsequent Recipient → Final Known Beneficiary.
Secure banking authorizations, shareholder and director records, accounting data, invoices, contracts, tax documentation, customs records, cryptocurrency histories, employee access information and relevant communications.
Identify Person → Position → Banking Authority → Transaction Limit → Authentication Method → Relevant Period.
Identify Date → Sender → Amount → Purpose → Supporting Documents → Person Who Approved → Subsequent Destination.
Where broader seizure measures exist, identify Asset → Acquisition Date → Purchase Price → Funding Source → Supporting Documents → Alleged Connection With Offense.
This can be one of the strongest structural elements of the defense.
Where investment capital came from an overseas parent company, obtain the parent’s corporate resolutions and banking evidence immediately.
Do not wait until the indictment to request historical foreign bank statements.
A foreign company facing a frozen Turkish bank account should begin by determining whether the restriction originates from the bank’s compliance process, an Article 19/A transaction suspension or a judicial measure within a criminal investigation. The company should then identify every disputed transaction and reconstruct its genuine economic purpose through banking records, contracts, invoices, customs documentation, accounting records and communications. If fraud-linked money entered the corporate account, the investigation should establish who provided the payment instructions, who controlled internet banking, who authorized the onward transfer and who ultimately received the economic benefit. Foreign shareholders and directors should document their actual management roles rather than allowing formal corporate titles to substitute for proof of personal involvement. Where legitimate investment capital originated abroad, the company should establish both source of funds and, where necessary, source of wealth through foreign corporate, banking and tax records. If cryptocurrency was involved, bank transfers should be connected with exchange and blockchain evidence. Where judicial seizure exists, the actual decision, legal basis, scope and procedural chronology should be examined, including the special requirements applicable to urgent seizure decisions under Law No. 5549 where relevant. The company should also document the operational consequences of the freeze, including salaries, taxes, suppliers and contractual obligations. The practical roadmap is therefore: identify who imposed the restriction → determine its legal basis → identify the prosecutor file if one exists → obtain the relevant decision → identify the triggering transactions → preserve corporate records → reconstruct source of funds → prove genuine commercial activity → identify actual banking authority → trace onward transfers → identify ultimate beneficiaries → separate legitimate revenue from disputed funds → obtain foreign parent-company evidence → preserve cryptocurrency records → examine the scope and procedural validity of judicial seizure → challenge the restriction through the appropriate legal procedure → document business-continuity consequences → protect the individual position of foreign shareholders and directors → maintain the complete financial evidence file throughout the investigation.
A restriction may arise because of a bank compliance review, suspicious transactions, an Article 19/A AML transaction suspension or a judicial measure connected with a criminal investigation. The exact legal basis must be identified before selecting a remedy.
No. A restricted bank account does not automatically establish money laundering or another criminal offense. The circumstances, legal basis of the restriction and underlying transactions must be examined.
No. The seven-working-day period concerns the specific transaction-postponement mechanism under Article 19/A of Law No. 5549. A separate judicial seizure can operate under a different legal framework.
Potentially, where the statutory requirements for the relevant criminal-procedure measure are satisfied. In urgent money-laundering cases, Article 17 of Law No. 5549 also provides a special prosecutor-seizure mechanism subject to judicial approval requirements.
Not automatically. Share ownership alone does not establish personal criminal responsibility. Actual knowledge, conduct, banking authority, communications and financial benefit should be examined.
Responsibility cannot properly be determined solely from job titles. Investigators should examine actual authority, knowledge, instructions, banking access and involvement in the disputed transactions.
Important evidence can include bank statements, banking authorizations, contracts, invoices, accounting records, customs documents, corporate resolutions, foreign parent-company records, tax documents, emails, internal messages and cryptocurrency transaction histories where relevant.
This depends on the specific judicial or banking restriction. Where legitimate operating funds can be distinguished from disputed transactions, their lawful origin and the scope and proportionality of the restriction may be raised through the appropriate procedure.
The company should document payroll, taxes, social security obligations, essential suppliers, rent, utilities and contractual obligations affected by the restriction. These operational consequences may be relevant when challenging or seeking modification of the measure.
Determine who imposed the restriction and under which legal authority. The company should then identify any prosecutor investigation, preserve its financial records, determine the transactions under scrutiny and prepare the appropriate response or challenge based on the actual legal measure.
Foreign-owned companies facing frozen or restricted bank accounts in Turkey may simultaneously encounter MASAK-related scrutiny, suspicious transaction investigations, fraud allegations, money-laundering investigations, prosecutor proceedings, corporate asset seizure and disruption of ordinary business operations.
Fırat Fesih Kaya Law Office provides legal assistance to foreign companies, international investors, shareholders and directors dealing with bank-account restrictions and financial-crime investigations in Turkey.
Fırat Fesih Kaya can assist with identifying the legal basis of corporate bank-account freezes, criminal investigations, MASAK-related proceedings, source-of-funds documentation, judicial seizure objections, shareholder and director liability, cryptocurrency investigations and applications concerning restricted corporate assets.
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