International Trade Fraud in Turkey: Criminal Complaint, Asset Recovery and Remedies for Foreign Companies 2026

Foreign company defrauded in an international trade transaction in Turkey? Learn the 2026 criminal remedies for fake suppliers, false invoices, non-delivery, forged documents, customs fraud, diverted payments, asset seizure and recovery.

A foreign company entering into an international trade transaction with a Turkish supplier, distributor, manufacturer, importer, exporter or intermediary may discover that the commercial relationship was fraudulent only after substantial funds have already been transferred.

The supplier may disappear after receiving an advance payment. Goods may never have existed. Shipping documents may be forged. Containers may contain materially different products. A Turkish company may use false invoices or fabricated warehouse records. Bank details may be changed through a fraudulent email. An intermediary may collect money while falsely claiming to represent a genuine manufacturer.

When this happens, the central legal question is whether the dispute is merely a failed commercial transaction or whether the evidence supports a criminal complaint in Turkey.

That distinction is critical.

Non-payment or non-performance does not automatically constitute fraud.

A criminal case generally requires evidence of deceptive conduct capable of establishing the elements of the applicable offence, rather than merely showing that a contractual promise was later breached. Where the alleged conduct occurred in commercial activity by a merchant, company manager or person acting on behalf of a company, Turkey’s aggravated-fraud provisions can become particularly relevant. Current Article 158 of the Turkish Criminal Code specifically includes fraud committed by merchants, company managers or persons acting on behalf of a company during commercial activities among the aggravated circumstances.

For a foreign company, the correct investigation usually follows this chain:

Seller → Company identity → Contract → Representations → Invoice → Payment → Goods → Shipping documents → Customs records → Delivery → Destination of money → Individuals responsible.

What Is International Trade Fraud?

International trade fraud can arise where deception is used to induce a foreign company to transfer money, release goods, extend credit or enter into a transaction that it would not otherwise have accepted.

Common scenarios include:

• Fake Turkish supplier
• Fake manufacturer
• Advance-payment fraud
• Goods never shipped
• Non-existent inventory
• Forged invoice
• Fake bill of lading
• False warehouse receipt
• Fake customs documents
• False certificate of origin
• Counterfeit product documents
• Different goods loaded into the container
• Quantity manipulation
• Bank-account substitution
• Business email compromise
• Fraudulent distributor
• Fake investment or trading company
• Double sale of the same goods
• False export transaction
• Fraudulent intermediary

Each case should be reconstructed transaction by transaction.

Commercial Dispute or Criminal Fraud?

This is often the first legal issue.

Suppose a foreign buyer pays USD 500,000 for industrial machinery. The Turkish manufacturer genuinely produces the machinery but becomes financially distressed and delivers six months late.

That may primarily be a contractual dispute.

Now consider a different case.

The alleged seller sends photographs of machinery it does not own, produces fabricated warehouse documents, issues a false invoice, receives USD 500,000 and immediately transfers the funds to several related accounts.

That factual pattern may support a very different criminal analysis.

The distinction depends heavily on deception at or around the time the money or property was obtained.

Breach of Contract Does Not Automatically Equal Fraud

Foreign companies should avoid presenting a criminal complaint merely as:

“We paid and they did not deliver.”

The complaint should identify the alleged deceptive conduct.

For example:

“Before payment, the seller falsely represented that 2,000 units had already been manufactured and stored in Warehouse X, supplied fabricated warehouse photographs and documents, and induced the foreign buyer to transfer EUR 800,000.”

That allegation is materially more specific.

Fraud by a Company Manager During Commercial Activity

Article 158 of the Turkish Criminal Code contains aggravated forms of fraud and specifically covers, among other situations, fraud committed by merchants or company managers, or by persons acting on behalf of a company, during commercial activities. It also addresses fraud involving information systems and banks or credit institutions in specified circumstances.

This can be particularly relevant in international transactions because foreign victims frequently deal with individuals acting through a corporate structure.

However, the existence of a company does not itself prove aggravated fraud.

The alleged deceptive acts must still be established.

2026 Amendment Affecting Fraud Cases

A notable 2026 development concerns Article 158.

The current text reflects an amendment adopted in July 2026 concerning certain forms of participation in fraud where participation is limited to providing payment instruments or information necessary to use bank, brokerage, payment-service-provider or crypto-asset-service-provider accounts for the purpose of obtaining unlawful benefit. The provision establishes a specific sentence-reduction mechanism for qualifying participation.

For international trade fraud investigations, this reinforces the importance of distinguishing the roles of:

• Person who deceived the foreign buyer
• Company manager
• Bank-account holder
• Person controlling the account
• Person receiving the proceeds
• Person transferring the proceeds
• Intermediary
• Ultimate beneficiary

Account ownership alone should not replace evidence about actual participation.

Fake Turkish Supplier Fraud

One common scenario begins when a foreign buyer discovers a Turkish company through:

• Online search
• Trade platform
• Exhibition
• Referral
• Social media
• Commercial intermediary

The company appears legitimate and sends:

• Registration documents
• Catalogue
• Invoice
• Bank details
• Product photographs

After payment, communication stops.

The investigation should determine whether the Turkish company was a genuine operating business or merely part of the alleged scheme.

A Registered Company Can Still Be Used in Fraud

Foreign buyers sometimes assume:

“The company is registered, so the transaction must be legitimate.”

That is unsafe.

A legally incorporated company can potentially be used as a vehicle for fraudulent conduct.

Conversely, the fact that a company later becomes insolvent does not prove it was fraudulent from the beginning.

The chronology matters.

Investigate the Company Before and After Payment

Relevant evidence may include:

• Incorporation date
• Registered activities
• Managers
• Shareholders where legally relevant
• Registered office
• Actual business premises
• Employees
• Historical trading activity
• Website history
• Banking information
• Warehouse
• Production capacity

The purpose is to determine whether the commercial story presented to the foreign buyer was genuine.

Fake Manufacturer Scheme

A trader may falsely claim:

“We manufacture these products ourselves.”

The foreign buyer later discovers that the company has:

• No factory
• No production equipment
• No employees capable of production
• No inventory

That evidence can become highly relevant where manufacturing capability was used to induce payment.

Advance-Payment Fraud

Advance payments are common in international trade.

They are not inherently suspicious.

The criminal issue arises where the foreign buyer alleges that the seller never intended to perform and used deception to obtain the advance.

Important questions include:

Did the goods exist?

Were raw materials purchased?

Was production started?

Was shipping booked?

Where did the advance payment go?

What representations were made before payment?

Follow the Money

Financial tracing is often central.

Build a chronology:

Foreign buyer → Turkish company account → Related company → Individual account → Cash withdrawal or further transfer.

The destination of funds may help explain the transaction.

But bank transfers should not be interpreted mechanically.

A transfer to another company may represent:

• Supplier payment
• Freight
• Debt repayment
• Group-company settlement
• Legitimate subcontracting

Each movement requires evidence and context.

Payment to a Personal Account

A seller may instruct a foreign buyer:

“Our corporate account is temporarily unavailable. Send the money to the director’s personal account.”

That should trigger enhanced scrutiny.

Preserve:

• Instruction email
• Messaging records
• Bank details
• Payment receipt
• Identity of account holder
• Explanation given for the change

Business Email Compromise

Not every fraudulent payment is committed by the contractual supplier.

A criminal may compromise an email account and send:

“Our bank account has changed. Please send the invoice payment to this new IBAN.”

The foreign buyer sends the money, but the genuine supplier never receives it.

The investigation should distinguish:

Supplier fraud

from

External cyber fraud

from

Insider participation.

Preserve Email Evidence Properly

Do not preserve only screenshots.

Where possible, preserve:

• Original emails
• Full message headers
• Attachments
• Server logs
• Login records
• Forwarding rules
• Account-recovery records
• Original invoice versions

These can help determine whether an email account was compromised.

Fake Invoice Fraud

An invoice can be genuine, incorrect, manipulated or entirely fabricated.

The investigation should ask:

• Who created it?
• Which company issued it?
• Was the transaction real?
• Did the goods exist?
• Was the bank account controlled by the seller?
• Was the invoice altered after issuance?

A document should not be called “fake” merely because its commercial contents are disputed.

False Invoice and Fictitious Export Investigations Are Active in 2026

Turkey continues to investigate alleged false-invoice and fictitious-export schemes.

In June 2026, the Ministry of Justice announced an investigation concerning alleged false invoices and fictitious exports in the fuel sector. According to the Ministry’s announcement, judicial action was initiated against 27 suspects, six companies were seized and trustees were appointed to ten companies. These were allegations in a specific investigation, not findings that apply to ordinary trade disputes, but they illustrate that trade-document fraud can lead to simultaneous fraud, customs, tax and corporate measures.

Fake Bill of Lading

A foreign buyer may receive a document appearing to show that goods have been loaded onto a vessel.

The container never existed.

Immediately verify:

• Carrier
• Vessel
• Container number
• Booking
• Port
• Shipment date
• Consignee
• Original document source

Do not rely solely on a PDF received from the seller.

Container Contains Wrong Goods

Another scenario involves a real shipment but fraudulent contents.

For example:

Contract: copper products.

Container: low-value substitute material.

Preserve:

• Seal number
• Container number
• Loading photographs
• Weight records
• Customs declaration
• Inspection report
• Survey report
• Warehouse records
• Delivery record

Independent inspection can become critical.

Quantity Fraud

The buyer may order 10,000 units but receive 4,000.

That can be a contractual dispute.

The analysis changes if evidence shows that the seller knowingly fabricated loading records showing 10,000 units and used those records to obtain full payment.

The alleged deception should be identified precisely.

False Certificate of Origin

A false origin document can create multiple legal issues.

It may affect:

• Customs duties
• Preferential treatment
• Trade-defense measures
• Import restrictions
• Customer compliance

The foreign victim should determine whether it received the document from the seller, customs broker, intermediary or another party.

Customs Fraud and Commercial Fraud Can Overlap

Turkey’s Ministry of Trade identifies several export-related smuggling scenarios under Law No. 5607, including exporting goods whose export is prohibited by law and obtaining an unlawful advantage by presenting an export as completed when it was not, or misrepresenting characteristics such as type, quantity, quality or price in connection with incentives, subsidies or monetary refunds.

A foreign company may therefore encounter a situation in which conduct that defrauded it also becomes relevant to a Turkish customs or smuggling investigation.

Customs Investigation Does Not Replace the Victim’s Claim

Suppose Turkish authorities investigate the exporter for fictitious exports.

The foreign buyer should not assume that the government investigation will automatically recover its money.

The company should separately evaluate:

• Criminal complaint
• Participation as an injured party where available
• Asset-protection measures
• Commercial claim
• Enforcement
• Contractual remedies

Fake Customs Clearance Documents

A fraudulent seller may send purported customs records to convince the buyer that goods are ready for shipment.

Preserve the original electronic files.

Determine:

• Document number
• Declaration reference
• Customs office
• Date
• Exporter
• Goods
• Quantity

Verification may reveal whether the document corresponds to a real transaction.

Fraudulent Intermediary

An intermediary may falsely claim to represent a legitimate Turkish manufacturer.

The foreign buyer transfers money to the intermediary.

The manufacturer later states:

“We have never dealt with this person.”

The investigation should establish:

• Whether agency authority existed
• Who controlled the email domain
• Who issued the invoice
• Who received payment
• Whether the manufacturer communicated directly
• Whether corporate logos/documents were copied

Identity Theft of a Real Turkish Company

A particularly dangerous scheme involves criminals impersonating a real Turkish business.

They may copy:

• Company name
• Logo
• Website
• Catalogue
• Executive names
• Registration documents

but substitute their own email address and bank account.

The genuine Turkish company may therefore also be a victim.

Criminal Complaint in Turkey

A foreign company that believes it has been defrauded should prepare a transaction-specific criminal complaint rather than a generic allegation.

The complaint should explain:

Who made the representation → What was false → When it was made → Why the company relied on it → What money/property was transferred → Who received the benefit → What happened afterward.

Evidence Package

A useful evidence package may include:

• Contract
• Purchase order
• Pro forma invoice
• Final invoice
• Bank transfer
• SWIFT records
• Emails
• Messages
• Product specifications
• Photographs
• Video
• Shipping documents
• Customs records
• Inspection reports
• Corporate documents

Organize evidence chronologically.

Preserve Originals

Do not send investigators only edited PDFs or translated summaries.

Preserve:

Original document + Translation + Explanation.

Foreign-language originals may contain metadata, formatting or other evidentiary information that disappears during translation.

Bank Records

Bank evidence may establish:

• Recipient
• Date
• Amount
• Currency
• Payment reference
• Correspondent-bank route

But it does not automatically establish who controlled the recipient account or who ultimately benefited.

Those are separate investigative questions.

Requesting Investigation of the Money Trail

Where appropriate, the criminal complaint can identify why the movement of proceeds is relevant.

For example:

EUR 1.2 million paid to supplier → same-day transfer to another company → subsequent transfers to individual accounts.

The factual sequence may justify deeper investigation.

Avoid presenting an unexplained transfer as automatic proof of criminality.

Asset Preservation and Recovery

Foreign victims often focus exclusively on obtaining a conviction.

But the commercial objective is usually recovery.

Early strategy should therefore consider whether legally available measures can prevent relevant assets from disappearing while the investigation proceeds.

The availability of any seizure, attachment or other protective measure depends on its statutory requirements and the evidence in the particular case.

Criminal Seizure and Civil Attachment Are Different

Do not confuse:

Criminal seizure of assets

with

Interim attachment in a receivables dispute.

They have different legal purposes and requirements.

In appropriate cases, criminal and civil/commercial strategies may proceed in parallel.

Can the Suspect’s Bank Account Be Frozen?

Potentially, where the statutory requirements for the applicable measure are satisfied.

A victim cannot simply obtain a criminal account freeze because money is owed.

The application should explain the alleged offence, traceable proceeds and evidence supporting the requested measure.

Can Company Assets Be Seized?

Again, potentially under the applicable criminal-procedure framework where statutory conditions are met.

But a corporation’s entire property should not automatically be treated as criminal proceeds merely because one transaction is disputed.

The relationship between the alleged offence and the targeted property matters.

Search and Seizure

International trade fraud cases may involve searches of:

• Company premises
• Warehouses
• Offices
• Computers
• Digital records

Digital evidence can be especially important where invoices, shipping records and customer communications were created electronically.

Important 2026 Digital Evidence Development

The Constitutional Court issued a significant decision in February 2026 concerning Article 134 of the Criminal Procedure Code, which governs searches of computers and related digital seizure measures. The Court annulled specified parts of the provision and ordered the annulment to take effect nine months after publication in the Official Gazette. The Court identified concerns including safeguards relating to digital-data security, access, retention and legal remedies.

Accordingly, in a 2026 international trade fraud case involving seized computers or copied digital evidence, the exact law in force on the date of the measure should be checked carefully.

Forged Commercial Documents

Trade fraud may involve:

• Forged contracts
• Fake signatures
• False invoices
• Fabricated certificates
• Forged warehouse documents
• Manipulated shipping records

Fraud and document-related offences should be analyzed separately rather than assuming every false document automatically produces the same criminal classification.

Cyber Evidence

If the fraud involved electronic communication, preserve:

• IP-related records where lawfully available
• Email headers
• Domain registration evidence
• Server logs
• Login alerts
• Device records
• Message exports

An IP address or account name should not automatically be equated with a particular human being. Attribution requires additional evidence.

Crypto Payments

If payment was converted into crypto assets, preserve:

• Wallet addresses
• Transaction hashes
• Exchange communications
• Payment instructions
• Screenshots
• Original messages

A wallet address can assist tracing, but possession of an address alone does not necessarily establish the identity of the person controlling it.

Foreign Company as Victim

Foreign nationality does not prevent a company from seeking criminal remedies in Turkey where Turkish jurisdiction and the relevant procedural requirements are satisfied.

The company should document its legal existence and the authority of the person acting for it.

Power of Attorney

A foreign company pursuing proceedings in Turkey will generally need to organize representation and corporate authorization documents appropriately.

The required formalities depend on the country of origin and the intended use of the document.

Do this early rather than after an urgent procedural deadline arises.

Company Representative Versus Witness

The individual who negotiated the transaction may possess the most important factual knowledge.

The legal team should distinguish:

• Corporate representative
• Direct victim contact
• Witness
• Signatory
• Payment approver

Prepare the factual chronology before statements are given.

Do Not Exaggerate the Complaint

A strong criminal complaint is evidence-driven.

Avoid claiming:

“Every document is fake.”

when only one invoice is disputed.

Avoid claiming:

“The company never existed.”

if it is registered but allegedly misrepresented its capacity.

Precision improves credibility.

Commercial Case Can Continue Alongside Criminal Investigation

The existence of a criminal investigation does not necessarily eliminate contractual remedies.

Depending on the transaction, the foreign company may also consider:

• Contract termination
• Restitution
• Damages
• Debt recovery
• Interim protection
• Arbitration
• Litigation

The contract’s jurisdiction and dispute-resolution clauses should be reviewed.

Arbitration Clause Does Not Necessarily Eliminate Criminal Issues

A contract may require commercial disputes to be arbitrated.

That does not necessarily transform alleged criminal deception into an ordinary contractual matter.

At the same time, a criminal complaint should not be used merely as leverage in a genuine contractual disagreement.

The two legal tracks must be distinguished.

Insolvency After Payment

A seller may have intended to perform but later become insolvent.

That fact can strongly affect the criminal analysis.

Review:

• Financial position when contract signed
• Existing inventory
• Production activity
• Supplier purchases
• Other customer orders
• Payments
• Subsequent insolvency

Fraud should not be inferred solely from business failure.

Multiple Foreign Victims

The case may become materially different if investigators discover several unrelated foreign buyers reporting the same pattern.

For example:

Same machinery → Same photographs → Same warehouse → Same seller → Five advance payments → No deliveries.

A repeated pattern can become important evidence concerning the original representations and alleged intent.

Historical Transactions Matter

Turkey continues intensive retrospective review of customs and foreign-trade transactions. The Ministry of Trade reported that secondary-control and post-clearance work resulted in TRY 8.9 billion in additional assessments and penalties during the first seven months of 2026, a 29% increase compared with the same period of the previous year.

This means an investigation triggered by one suspicious international transaction can expose a broader history of customs and trade activity.

2026 Enforcement Environment

Recent enforcement also demonstrates that Turkish authorities may investigate trade-related allegations through several legal tracks simultaneously.

The June 2026 fuel-sector investigation announced by the Ministry of Justice involved allegations concerning false invoices and fictitious exports as well as fraud, tax and smuggling-related conduct, with measures affecting companies and individuals.

For foreign victims, this means that an apparently simple “supplier fraud” may eventually intersect with tax, customs, document, cyber or asset-recovery issues.

What Should the Foreign Company’s Internal Investigation Determine?

The company should answer at least these questions:

1. Who first introduced the seller?
2. Who communicated with the seller?
3. What representations induced the transaction?
4. Were those representations documented?
5. Who signed the contract?
6. Who issued the invoice?
7. Who owned the receiving bank account?
8. What payment was made?
9. Did the goods exist?
10. Were goods produced?
11. Were goods shipped?
12. Were shipping documents genuine?
13. Were customs records genuine?
14. Where did the money go?
15. What happened after payment?

These answers can determine whether the matter should be approached primarily as a commercial dispute, criminal fraud case or both.

30 Immediate Steps for a Foreign Company After Suspected Trade Fraud

1. Stop additional payments.
2. Contact the company’s bank immediately where appropriate.
3. Preserve payment records.
4. Preserve SWIFT information.
5. Preserve original emails.
6. Preserve email headers.
7. Preserve messaging records.
8. Preserve contracts.
9. Preserve purchase orders.
10. Preserve invoices.
11. Preserve product photographs.
12. Preserve video calls or meeting records lawfully available.
13. Verify the Turkish company’s identity.
14. Verify the person claiming to represent it.
15. Verify the recipient bank account.
16. Verify the shipment.
17. Verify the carrier.
18. Verify the container number.
19. Verify warehouse information.
20. Preserve customs documents.
21. Obtain an independent inspection where useful.
22. Prepare a payment chronology.
23. Prepare a communication chronology.
24. Identify every individual involved.
25. Identify possible other victims where lawfully known.
26. Do not delete or alter evidence.
27. Do not create retrospective documents.
28. Evaluate urgent asset-protection measures.
29. Review contractual remedies.
30. Coordinate criminal recovery and commercial enforcement strategies.

Frequently Asked Questions

1. Can a foreign company file a criminal complaint for trade fraud in Turkey?

Potentially yes, where the alleged conduct falls within Turkish jurisdiction and the procedural requirements are satisfied. The complaint should identify the alleged deception, payment or property loss and persons involved.

2. Is failure to deliver goods automatically fraud?

No. Non-delivery can result from an ordinary contractual breach, insolvency or another commercial problem. Criminal fraud requires analysis of the deceptive conduct and the elements of the applicable offence.

3. Is fraud committed through a company treated more seriously?

Article 158 includes specified aggravated forms of fraud, including fraud committed by merchants, company managers or persons acting on behalf of a company during commercial activities.

4. Can money transferred to a fraudulent Turkish supplier be recovered?

Recovery may be possible depending on where the money went, available assets, timing and applicable criminal or civil measures. Early financial tracing can be important.

5. Can Turkish authorities freeze the suspect’s bank account?

Potentially where the statutory conditions for the relevant criminal-procedure measure are satisfied. A disputed commercial debt alone does not automatically justify a criminal freeze.

6. What if the Turkish company’s email was hacked?

Then the genuine supplier may also be a victim. Email headers, login records, bank-change instructions and other digital evidence should be preserved to distinguish external cyber fraud from supplier fraud.

7. What if the bill of lading or customs document is fake?

Preserve the original file and verify it through the relevant transaction records. A forged shipping or customs document can materially change the criminal analysis.

8. Can criminal and commercial proceedings continue at the same time?

Depending on the circumstances, yes. Criminal investigation and contractual recovery serve different purposes and may require coordinated strategies.

9. What if the seller claims it simply became insolvent?

Insolvency does not automatically eliminate or establish fraud. The company’s position and conduct when it obtained the foreign buyer’s money should be examined carefully.

10. What is the most important first step after discovering international trade fraud?

Preserve the complete evidence and reconstruct the transaction from the first representation through the final movement of money. The strongest cases usually show clearly what was represented, why it was false, who made the representation, what the foreign company transferred in reliance on it and where the proceeds went.

Legal Assistance for Foreign Companies Facing International Trade Fraud in Turkey

International trade fraud can create simultaneous criminal, customs, banking, cyber, contractual and asset-recovery problems. A foreign company may need to act before funds are transferred again, digital evidence disappears, goods are moved or the suspected company becomes insolvent.

Fırat Fesih Kaya Law Office provides legal assistance to foreign companies, multinational groups, importers, exporters, manufacturers, investors and international traders affected by commercial and international trade fraud in Turkey.

Lawyer Fırat Fesih Kaya assists foreign clients with criminal complaints, fake supplier investigations, advance-payment fraud, false invoices, forged trade and shipping documents, business email compromise, fraudulent intermediaries, customs-related fraud, evidence preservation, financial tracing and coordination of criminal and commercial recovery strategies.

Early intervention can be especially important where a substantial advance payment has just been transferred, the supplier has disappeared, bank details were changed shortly before payment, shipping documents appear fabricated, several foreign buyers may have been targeted or there is a risk that relevant assets will be transferred.

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. Criminal liability and recovery options depend on the specific representations, transaction documents, payment flows, contractual structure, jurisdiction, available evidence and individual conduct involved.