Bank Account Blocked After Online Fraud Complaint in Turkey: How Can Foreigners Challenge It?

Has your Turkish bank account been blocked after an online fraud complaint? Learn why banks freeze accounts, the new 2026 account-suspension procedure, seizure rules, prosecutor applications, evidence needed for release and how foreigners can challenge an unjustified block.

A foreign national may suddenly discover that their Turkish bank account has been blocked after another person files an online fraud complaint.

The foreigner may be unable to withdraw salary, make transfers, pay rent, use a bank card or access money needed for ordinary living expenses. The bank may provide only limited information and state that the restriction is connected to a prosecutor’s office, a criminal investigation or suspicious transactions.

The first question is usually:

“How can I get my Turkish bank account unblocked?”

The answer depends primarily on who imposed the restriction and its legal basis.

This distinction became especially important after a major legislative change that entered into force on 25 December 2025. The new Article 128/A of the Turkish Criminal Procedure Code created a specific procedure allowing banks, payment service providers and crypto-asset service providers to suspend certain accounts for up to 48 hours where there is reasonable suspicion concerning specified technology-related offences, including certain forms of aggravated fraud. The account holder can apply to the public prosecutor for removal of that suspension, and the prosecutor must decide the application within 24 hours.

For foreigners facing an account block in 2026, identifying whether the restriction is a temporary suspension, criminal seizure, compliance restriction or another measure is therefore the essential first step.

Why Can a Bank Account Be Blocked After an Online Fraud Complaint?

Online fraud investigations frequently begin by following the money.

Suppose a fraud victim tells police:

“I was deceived online and transferred 150,000 TRY to this Turkish IBAN.”

Investigators examine the transaction.

The receiving account belongs to a foreign national.

The foreigner may then discover that access to the account has been restricted.

This does not automatically mean that the foreign account holder committed fraud.

The account may have been:

• Used by another person
• Provided to a friend
• Used after a fake job offer
• Hacked
• Used by an employer or colleague
• Used for what appeared to be a legitimate commercial transaction
• Used as an intermediary account without the owner’s knowledge of the fraud

The financial restriction and the determination of criminal guilt are different issues.

2026 Major Change: Article 128/A and the 48-Hour Account Suspension

One of the most important developments for online fraud investigations is Article 128/A of the Turkish Criminal Procedure Code.

The provision was added by Law No. 7571 and entered into force on 25 December 2025.

Under the new mechanism, where there is reasonable suspicion concerning specified offences—including particular forms of aggravated fraud—a bank, payment service provider or crypto-asset service provider may suspend an account involved in the relevant transaction for up to 48 hours.

This is highly relevant to foreigners whose accounts suddenly stop working after an online fraud complaint.

Does the Bank Need to Notify the Prosecutor?

Under Article 128/A, the financial institution must immediately notify the relevant Chief Public Prosecutor’s Office of the suspension and account movements together with the relevant information and documents. The account holder must also be notified of the suspension.

This means the account holder should try to determine immediately:

• When was the suspension imposed?
• Which transaction triggered it?
• Which prosecutor’s office was notified?
• Is there an investigation number?
• Is the restriction still a temporary suspension?
• Has a further judicial measure followed?

These questions determine the next procedural step.

Can the Foreign Account Holder Ask for the 48-Hour Suspension to Be Removed?

Yes.

This is one of the most important features of the new 2026 framework.

Article 128/A expressly allows the account holder to apply to the Chief Public Prosecutor’s Office for removal of the suspension. The prosecutor must decide the application within 24 hours.

Therefore, a foreigner should not automatically wait for the 48-hour period to expire where there are strong grounds showing that the restriction is mistaken or unnecessary.

What Should Be Included in the Application?

A useful application should normally do more than say:

“I need my money. Please remove the block.”

It should address the reason for the suspicious transaction.

Depending on the facts, supporting documents may include:

• Bank statements
• Employment contract
• Salary records
• Invoice
• Sales agreement
• Loan agreement
• WhatsApp conversations
• Emails
• Customer correspondence
• Evidence identifying the actual account user
• Proof of unauthorized account access
• Bank security notifications
• Police complaint
• Cryptocurrency records

The objective is to explain the transaction with evidence.

Temporary Suspension and Criminal Seizure Are Not the Same Thing

This distinction is essential.

A temporary account suspension under Article 128/A is an immediate intervention designed to prevent rapid movement of potentially criminal proceeds.

A seizure measure is a different legal mechanism.

Article 128 of the Criminal Procedure Code permits seizure of specified assets, including bank and financial-institution accounts, where the statutory conditions concerning suspected criminal proceeds are satisfied.

Therefore, telling a lawyer merely:

“My account is blocked.”

is not enough to identify the correct remedy.

The underlying document must be examined.

Ask the Bank What Kind of Restriction Exists

The account holder should ask the bank for available information concerning:

• Legal basis
• Date
• Scope
• Authority
• Reference number
• Investigation information
• Whether the measure affects one transaction or the entire account

The bank may not be able to disclose every detail of an ongoing criminal investigation.

Nevertheless, identifying the source of the restriction is crucial.

Is the Entire Account Blocked or Only the Suspicious Money?

This can be a major issue.

Suppose the disputed transfer is:

30,000 TRY

but the account contains:

500,000 TRY

from documented salary, savings and legitimate business activity.

The defense should determine whether the measure actually applies to the entire account balance and whether the scope of the restriction is legally justified.

Where legitimate funds are being affected, their source should be documented carefully.

Separate the Suspicious Transfer From Legitimate Money

Prepare a clear financial breakdown.

For example:

Opening balance: 250,000 TRY legitimate savings

Monthly salary: 70,000 TRY

Disputed transfer: 40,000 TRY

Current balance: 360,000 TRY

Supporting documents can include:

• Payroll
• Employment contract
• Tax records
• Previous bank statements
• Property-sale documents
• Foreign transfer records

This may help demonstrate that not all funds in the account are connected to the disputed transaction.

Can a Foreign Employee’s Salary Be Trapped by the Block?

Potentially, a broadly implemented restriction may prevent practical access to money that includes salary or other legitimate funds.

The account holder should therefore identify legitimate incoming payments precisely.

If salary is involved, preserve:

• Employment agreement
• Payroll records
• Employer confirmation
• Social-security records
• Bank transfer descriptions

The source of legitimate funds can become important when requesting modification or removal of the restriction.

Does the Account Block Mean I Am Guilty of Fraud?

No.

An account restriction is an investigative or protective measure.

It is not a final criminal conviction.

This distinction is especially important because Turkish authorities are actively investigating account-sharing schemes. Prosecutorial authorities warn that fraudsters frequently use bank accounts belonging to other people, particularly by offering account holders commissions or supposedly harmless temporary use.

The fact that the account appears in a fraud transaction therefore justifies investigation.

It does not automatically answer whether the account owner knowingly participated.

What If Someone Else Used My Bank Account?

This should be documented immediately.

Identify:

• Who had the bank card?
• Who knew the PIN?
• Who controlled mobile banking?
• Who received verification codes?
• Who performed outgoing transfers?
• Who made ATM withdrawals?
• Why did that person have access?

Preserve all communications with that person.

“My Friend Used the Account” Is Not Enough

The explanation should be supported by objective evidence.

Useful evidence may include:

• WhatsApp conversations
• Telegram messages
• ATM CCTV
• Device records
• Banking security alerts
• Witnesses
• Transfer instructions

Official prosecutorial warnings make clear that merely stating that the account was given to another person does not prevent an investigation where suspicious funds passed through it.

What If My Account Was Hacked?

Contact the bank immediately and preserve:

• Unknown-device notifications
• Password-reset messages
• Security emails
• Authentication alerts
• SIM replacement information
• Unauthorized transaction notifications

If you previously reported the unauthorized access, preserve the reference number and date.

A hacking explanation supported by contemporaneous technical evidence can be substantially stronger than a general denial.

What If I Was Deceived Through a Fake Job?

Preserve the entire recruitment process.

This may include:

• Job advertisement
• Website
• WhatsApp messages
• Telegram messages
• Emails
• Employment offer
• Recruiter telephone number
• Identity documents
• Payment instructions

Official 2026 warnings specifically identify young people and job seekers as targets of schemes involving temporary account use and commissions.

What If the Money Was a Genuine Commercial Payment?

Document the transaction.

Preserve:

• Contract
• Invoice
• Purchase order
• Delivery records
• Customer messages
• Accounting documents
• Proof of goods or services

A criminal complaint concerning a payment does not automatically convert a genuine commercial transaction into fraud.

The underlying relationship must be investigated.

What If I Sold Something Online?

Preserve:

• Advertisement
• Marketplace listing
• Messages with buyer
• Product photographs
• Delivery evidence
• Courier information
• Invoice or receipt

This can be especially important where a payment is later disputed or where the buyer’s own funds were obtained through another fraud.

Can Police or Prosecutors Examine Other Transactions?

Potentially, investigators may examine the broader transaction pattern where relevant.

They may look for:

• Other incoming payments
• Repeated transfers
• Common recipients
• Cash withdrawals
• Cryptocurrency purchases
• Commission payments
• Multiple alleged victims

A 2026 organized fraud investigation publicly described by a Chief Public Prosecutor’s Office involved evaluation of victim statements, banking movements, communications records and digital evidence together.

Repeated Suspicious Transactions Can Make the Challenge More Difficult

One unexplained payment and dozens of similar payments present different evidentiary circumstances.

For example:

One transfer → immediate bank notification

is very different from:

Thirty unrelated transfers → immediate withdrawals → commission retained → funds forwarded to cryptocurrency accounts.

The challenge should address the complete account history rather than focusing selectively on one transaction where a wider pattern exists.

What If I Already Returned the Money?

Preserve evidence showing:

• Amount
• Recipient
• Date
• Time
• Why it was returned
• Who instructed the return

Be particularly careful where the money was sent to an account different from the original sender’s account.

That can create an additional transaction requiring explanation.

What If the Fraud Money Is Still in the Account?

Do not attempt to defeat the restriction by moving funds through another bank or another person’s account.

If the money is genuinely disputed, address it through the bank, prosecutor and applicable legal procedure.

Attempts to conceal or move the funds can make the factual situation significantly worse.

Can the Bank Simply Keep the Account Blocked Forever?

The answer depends on the legal basis.

A temporary Article 128/A suspension is governed by its specific statutory framework and should not simply be confused with a longer-term seizure measure. The new provision allows an initial suspension of up to 48 hours and gives the account holder a direct route to seek removal from the prosecutor.

If a different judicial or prosecutorial measure subsequently exists, that measure must be challenged according to its own rules.

Therefore, always ask:

What legal measure currently exists today?

not merely:

Why was the account originally blocked?

What If the 48 Hours Have Passed but the Account Is Still Blocked?

Do not assume that the bank is simply continuing the original suspension.

Determine whether:

• A prosecutor has issued a further instruction
• A seizure measure has been imposed
• A judicial decision exists
• Another statutory restriction applies
• The bank has a separate compliance restriction

The correct challenge depends on what replaced or followed the initial suspension.

How Can a Seizure Decision Be Challenged?

Where the restriction is based on a criminal-procedure seizure measure rather than only the initial Article 128/A suspension, counsel should obtain and examine the relevant decision and use the applicable criminal-procedure remedy.

The challenge may address matters such as:

• Statutory conditions
• Connection between funds and alleged offence
• Scope of seizure
• Evidence concerning legitimate source
• Necessity
• Continued justification for the measure

Article 128 expressly covers bank and other financial-institution accounts among assets that may be seized when its statutory requirements are satisfied.

Can the Account Holder Request Release of Legitimate Funds?

Depending on the legal measure and facts, the source and character of legitimate funds should be raised when requesting removal or narrowing of the restriction.

For example, the account may contain:

• Salary
• Rental income
• Savings predating the alleged offence
• Family support
• Business revenue
• Proceeds from a documented property sale

Evidence should trace these funds clearly.

Proportionality Can Matter

Asset restrictions interfere with a person’s ability to use property.

The Constitutional Court has addressed seizure measures within the framework of property rights and the availability of procedural remedies. Its materials concerning criminal seizure emphasize the importance of using the remedies available under criminal procedure to challenge the legality and continuation of the measure.

A challenge should therefore explain concretely why continued or excessively broad restriction is unjustified in the individual case.

Can Foreigners Challenge the Block Just Like Turkish Citizens?

Foreign nationality does not prevent an account holder from using the procedural remedies applicable to the measure.

The foreigner should nevertheless take particular care with:

• Translation
• Notification
• Understanding the investigation number
• Understanding the authority issuing the decision
• Criminal and immigration consequences

A foreign account holder should not sign a Turkish-language statement or document they do not adequately understand.

Can the Block Affect a Residence Permit?

A bank-account block does not itself equal cancellation of a residence permit.

Likewise:

Account block ≠ criminal conviction ≠ automatic deportation.

If a separate immigration measure is initiated, it should be analyzed independently under immigration law.

Can the Block Affect a Work Permit?

A bank restriction itself should not automatically be confused with a work-permit decision.

However, a foreign employee may face practical difficulties if salary becomes inaccessible or if the criminal investigation affects the employment relationship.

Any separate employment or work-permit decision should be reviewed on its own legal basis.

Can the Bank Account Block Lead to Police Questioning?

Yes.

If the account received alleged fraud proceeds, police or prosecutors may seek an explanation.

Typical questions include:

• Do you know the victim?
• Why did the money enter your account?
• Who gave the victim your IBAN?
• Who controlled the account?
• Why was the money transferred onward?
• Who withdrew it?
• Did you receive a commission?
• Were there other similar payments?

Reviewing the transaction history before giving speculative explanations can be important.

Do Not Guess About Old Transactions

If you do not remember why a transfer occurred, do not invent an explanation merely because you feel pressured to answer immediately.

Your explanation can later be compared with:

• Bank records
• WhatsApp
• Email
• CCTV
• Device evidence
• Cryptocurrency records

First reconstruct the transaction.

Can the Phone Be Seized During the Investigation?

Potentially.

A phone may contain evidence concerning:

• Banking applications
• WhatsApp
• Telegram
• Email
• Cryptocurrency
• Account-security alerts
• Communications with other suspects

Any seizure and digital examination should be assessed under the applicable criminal-procedure rules.

Do not delete potentially relevant information after learning about the investigation.

Do Not Factory-Reset the Phone

A factory reset can destroy evidence that may actually support the account owner’s explanation.

For example, messages may show:

“Please let my customer send the payment to you because my account is temporarily unavailable.”

Whether that explanation ultimately succeeds depends on the full evidence.

But destroying the message makes it harder to establish what the account owner was told.

ATM CCTV Can Help Challenge the Allegation

Suppose suspicious money enters the foreigner’s account and is withdrawn 15 minutes later.

The foreigner says:

“Another person had my bank card.”

ATM CCTV may help identify who physically performed the withdrawal.

Relevant footage may need to be preserved promptly because surveillance data can eventually be overwritten.

Digital Evidence Can Identify the Actual Account User

Depending on the case, relevant evidence may include:

• Banking-device information
• Authentication records
• Telephone data
• Messages
• IP information
• Security notifications

The defense should distinguish:

account owner

from

actual account operator

where the evidence supports that distinction.

What If the Complaint Is False?

A false or mistaken complaint can still trigger temporary investigative measures.

The defense should respond with objective documentation rather than simply stating:

“The complainant is lying.”

Potential evidence includes:

• Contract
• Invoice
• Delivery records
• Complete conversation
• Payment explanation
• Witnesses
• Commercial records

What If the Victim Sent the Money Voluntarily?

Voluntary transfer alone does not necessarily resolve whether fraud occurred.

Fraud allegations often involve claims that the victim voluntarily transferred money because they were deceived.

The relevant question may therefore be:

What representations caused the payment?

If the account owner did not make those representations, identify who did.

What If Multiple Complaints Have Been Filed?

This can significantly increase the complexity of the case.

Create a table or chronology showing:

Complainant → Amount → Date → Reason believed by account owner → Subsequent transfer → Ultimate recipient

Repeated transfers should be analyzed individually and collectively.

Do Not Try to Bypass the Block

Do not attempt to:

• Move funds through another person’s account
• Open accounts solely to conceal transactions
• Ask someone else to withdraw disputed funds
• Alter bank records
• Fabricate invoices
• Delete communications

The legal objective should be to challenge the restriction through the correct procedure, not circumvent it.

First 24 Hours After Discovering the Account Block

A foreign account holder should promptly:

1. Contact the bank through an official channel.
2. Determine the date the restriction began.
3. Ask what authority or legal basis is identified.
4. Determine whether Article 128/A is involved.
5. Obtain the investigation or reference number where available.
6. Determine whether the measure affects the entire account.
7. Identify the suspicious transaction.
8. Download complete bank statements.
9. Separate legitimate funds from disputed funds.
10. Preserve WhatsApp, Telegram, email and SMS communications.
11. Preserve employment and commercial documents.
12. Preserve bank-security notifications.
13. Identify who controlled the account.
14. Identify outgoing transfers and ATM withdrawals.
15. Preserve CCTV where relevant.
16. Do not delete digital evidence.
17. Do not attempt to circumvent the restriction.
18. Consider an immediate prosecutor application if the restriction is an Article 128/A suspension.
19. Determine whether a longer-term seizure measure has followed.
20. Prepare a documented request for removal or narrowing of the restriction.

What Should a Strong Challenge Explain?

A well-prepared application should answer:

Who owns the account?

Why did the disputed money arrive?

Did the owner know the complainant?

Who communicated with the complainant?

Who supplied the IBAN?

Who controlled mobile banking?

What happened to the money?

Which funds are legitimate?

What evidence supports the account owner’s explanation?

Why is continued restriction unnecessary or excessive?

A documented factual explanation is usually more useful than a generic request stating that the account holder needs access to money.

2026 Current Legal Position

The legal landscape changed materially at the end of 2025.

Article 128/A, effective from 25 December 2025, introduced a specific mechanism for rapidly suspending accounts involved in transactions connected with specified technology-related offences. Financial institutions can impose an initial suspension for up to 48 hours in the circumstances defined by the provision, must notify the prosecutor and account holder, and the account holder can apply to the prosecutor for removal of the suspension. The prosecutor must decide that application within 24 hours.

This reform is particularly significant in 2026 because online fraud proceeds can move through several accounts extremely quickly.

At the same time, longer-term seizure and other account restrictions remain separate legal issues and should not be confused with the initial 48-hour suspension.

For foreigners, the correct approach is therefore:

Identify the legal basis → identify the disputed transaction → preserve evidence → document legitimate funds → identify actual account control → use the correct procedural remedy → separately defend the underlying fraud allegation.

Frequently Asked Questions

1. My Turkish bank account was blocked after someone filed an online fraud complaint. Does that mean I am guilty?

No. An account restriction is an investigative or protective measure and is not itself a criminal conviction.

2. Can a Turkish bank temporarily suspend an account because of online fraud?

Yes, in the specific circumstances covered by Article 128/A. The provision introduced at the end of 2025 allows qualifying accounts to be suspended for up to 48 hours where the statutory reasonable-suspicion threshold is met.

3. Can I challenge the 48-hour suspension?

Yes. Article 128/A allows the account holder to apply to the Chief Public Prosecutor’s Office for removal of the suspension, and the prosecutor must decide the application within 24 hours.

4. What if my account is still blocked after 48 hours?

Determine whether a further prosecutorial or judicial measure has replaced or followed the initial suspension. Do not assume that the original temporary measure is the only restriction still operating.

5. Can my entire account be blocked because of one disputed transfer?

The answer depends on the legal basis and scope of the measure. If legitimate funds are also affected, document their sources and raise the scope of the restriction in the appropriate challenge.

6. What if another person used my account?

Preserve evidence showing who actually controlled the card, mobile banking and transactions. Account ownership and actual account use are distinct factual questions.

7. What if I was tricked into receiving the money?

Preserve the complete recruitment, employment or transaction communications. Evidence showing what you were told at the time may be central to determining your knowledge and intent.

8. Should I delete messages with the person who used my account?

No. Those messages may be among the most important pieces of evidence supporting your explanation.

9. Can the bank account block automatically lead to deportation?

No automatic equivalence should be assumed. A bank-account restriction, criminal prosecution and immigration removal decision are separate legal matters.

10. What is the first thing a foreigner should do?

Identify the exact legal basis for the block. The remedy for a temporary Article 128/A suspension can be different from the remedy applicable to a criminal seizure or another banking restriction.

Legal Assistance for Foreigners With Blocked Bank Accounts After Fraud Complaints in Turkey

A blocked Turkish bank account can create immediate problems for a foreign national who needs access to salary, savings, business income or ordinary living expenses.

But the first objective should not simply be to send a generic request to the bank.

The legal strategy should determine:

Who imposed the block? What is its statutory basis? Which transaction triggered it? Is it an Article 128/A suspension or another measure? Does it affect legitimate funds? Who actually controlled the account? What evidence explains the transaction?

Fırat Fesih Kaya Law Office provides criminal and foreigners-law assistance to foreign nationals, foreign employees, students, investors, executives and foreign-owned businesses whose Turkish bank accounts are restricted in connection with online fraud investigations.

Lawyer Fırat Fesih Kaya assists foreign clients with account-suspension applications, criminal seizure disputes, aggravated-fraud investigations, suspicious IBAN transactions, police and prosecutor statements, account-control evidence, WhatsApp communications, ATM CCTV, cryptocurrency transactions and related digital evidence.

Early legal action can be particularly important under the new 2026 framework because an initial account suspension can operate on a short statutory timeline, while a later seizure measure may require a different procedural challenge.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower No:148, 06520 Balgat, Çankaya, Ankara, Turkey

This publication is provided for general informational purposes and does not constitute legal advice. The appropriate remedy depends on the exact legal basis for the restriction, the procedural stage of the criminal investigation, the source of the funds and the evidence concerning the account holder’s knowledge and control.