How long can a foreign investor’s Turkish bank account remain frozen during an investigation? Learn about MASAK-related restrictions, judicial seizure, temporary transaction postponement, proportionality, objections and remedies for prolonged account freezes in Turkey.

A foreign investor’s bank account in Turkey can remain restricted for very different periods depending on the legal basis of the freeze.

There is no single rule stating that every bank account connected with a Turkish financial investigation can be frozen for a fixed number of days, weeks or months.

This is because the expression “bank account freeze” can describe several legally different measures, including:

• A bank compliance restriction;
• A temporary anti-money-laundering measure;
• A MASAK-related examination;
• A prosecutor-led criminal investigation;
• Judicial seizure of a bank account;
• An asset-freezing measure based on separate legislation.

Some mechanisms are designed to operate only for a short statutory period. Others can continue during a criminal investigation or prosecution, subject to continued legal justification and judicial review.

For foreign investors, the critical question is therefore not simply:

“How many days can my account be frozen?”

The correct question is:

“Which authority froze the account, under which legal provision, for what reason, and does the continued restriction remain necessary and proportionate?”

There Is No Universal Maximum Period for Every Bank Account Freeze

A common mistake is to assume that all MASAK-related restrictions must automatically disappear after a specific number of days.

That is not correct.

Different legal mechanisms have different rules.

A temporary postponement of a suspicious transaction is fundamentally different from judicial seizure of funds during a criminal investigation.

Therefore, an investor should first identify the precise legal basis before calculating whether the restriction has lasted too long.

MASAK Review and Judicial Seizure Are Not the Same Thing

MASAK is Turkey’s Financial Crimes Investigation Board.

It performs financial-intelligence and anti-money-laundering functions, including examination of suspicious financial activity.

However, not every restriction informally described by a bank employee as a “MASAK block” is necessarily a direct and continuing MASAK freeze.

The restriction may ultimately be based on:

• A prosecutor’s investigation;
• A judicial seizure order;
• A separate statutory asset measure;
• An internal bank compliance process.

This distinction determines both the duration and the available remedy.

Can a Temporary Transaction Restriction Be Short?

Yes.

Certain anti-money-laundering mechanisms are designed to temporarily prevent completion of a transaction while authorities examine whether further action is necessary.

A short-term transaction postponement should not be confused with a subsequent judicial seizure order.

For example, an initial transaction may be temporarily stopped and then become subject to a different legal measure if a criminal investigation develops.

Therefore, the expiry of an initial temporary mechanism does not necessarily mean that the account must become freely usable if another legally valid restriction has subsequently been imposed.

Can a Prosecutor or Court Freeze a Bank Account for Longer?

Potentially, yes.

Under Turkish criminal procedure, bank accounts and other financial assets can be subject to seizure in qualifying criminal investigations where the statutory conditions are satisfied.

Bank-account seizure is implemented by notifying the relevant bank or financial institution.

Such a measure is fundamentally different from a short compliance hold.

Its continuation can depend on:

• Nature of the alleged offence;
• Evidence;
• Relationship between the funds and alleged criminal activity;
• Stage of the investigation;
• Continuing necessity of the measure;
• Decisions of the competent judicial authorities.

Does Criminal Procedure Establish One Automatic Deadline for Every Account Seizure?

No universal short deadline applies to every judicial account seizure.

A judicial protective measure may continue while the legal justification remains, but this does not mean authorities have unlimited power to maintain restrictions indefinitely without adequate justification.

The duration and scope of the measure remain relevant to proportionality.

The Turkish Constitutional Court recognizes that seizure and similar restrictions affecting assets must remain proportionate in both scope and duration.

Can a Bank Account Remain Frozen Until the Criminal Case Ends?

In some circumstances, an asset measure can continue for a substantial part of an investigation or prosecution.

But the statement “the investigation is continuing” does not necessarily justify every restriction forever.

As time passes, authorities and courts may need to demonstrate why continued interference with the investor’s property remains justified.

This is especially important where:

• The investor has provided all requested documents;
• The questioned transaction has been explained;
• No new evidence has emerged;
• The entire account remains inaccessible;
• The restriction substantially exceeds the amount allegedly connected with the investigation;
• The business cannot operate;
• The investor is a good-faith third party.

Is There a Constitutional Limit on How Long a Freeze Can Continue?

There is no single constitutional number of days or months applicable to every case.

Instead, proportionality is critical.

The Constitutional Court has emphasized that temporary measures restricting property rights must not become disproportionate because of their duration. The authorities must have reasonable grounds for the measure, and reasons justifying its continuation must remain demonstrable.

This means that even a measure that was lawful when originally imposed can potentially become disproportionate if it continues for an excessive period without sufficient justification.

Can a Five-Year Bank Account Freeze Be Unlawful?

Potentially, depending on the circumstances.

In one important Constitutional Court case, a bank-account-related restriction remained in place for more than five years and four months.

The Court concluded that the prolonged restriction imposed an excessive burden and violated the right to property because adequate justification had not been demonstrated for maintaining the measure for such an extended period.

However, this judgment should not be misunderstood.

It does not establish a rule that every freeze becomes unlawful after five years.

The decision instead demonstrates a broader principle:

The longer a restriction continues, the more important it becomes that authorities can justify why it remains necessary and proportionate.

Can a Two-Year Freeze Be Challenged?

Potentially.

An investor does not necessarily have to wait five years before questioning a prolonged restriction.

Constitutional Court case law recognizes that duration is one component of proportionality and that asset measures should not impose an excessive individual burden.

Whether two years is excessive depends on factors such as:

• Complexity of the investigation;
• Amount involved;
• Alleged offence;
• Investor’s conduct;
• International evidence requests;
• Whether the investor cooperated;
• Whether the funds can be linked to the alleged offence;
• Whether less restrictive measures are available.

Can Even a Few Months Be Excessive?

Potentially, in an appropriate case.

Duration cannot be assessed in isolation.

Suppose a foreign-owned company has all of its operating accounts frozen even though the investigation concerns one clearly identifiable payment.

The company may be unable to pay:

• 200 employees;
• Taxes;
• Suppliers;
• Customs charges;
• Rent;
• Loan obligations.

The proportionality question may arise much earlier than it would in a highly complex investigation involving multiple transactions demonstrably connected with alleged criminal proceeds.

Does the Amount Frozen Matter?

Yes.

Scope can be as important as duration.

The Constitutional Court’s property-rights jurisprudence emphasizes proportionality between the public objective pursued and the burden imposed on the property owner.

Suppose the investigation concerns an allegedly suspicious payment of USD 100,000 but the investor’s corporate accounts containing several million dollars are entirely inaccessible.

The company should examine whether the scope of the restriction is justified by the actual investigation.

Can Only Part of an Account Be Restricted?

Depending on the legal mechanism and facts, arguments may be available for limiting a measure to the amount connected with the alleged offence.

Constitutional Court jurisprudence has considered the proportionality of asset restrictions and has taken into account circumstances where seizure was limited to the amount associated with the alleged criminal benefit.

Accordingly, investors should not focus solely on complete removal.

In some cases, an alternative strategy may involve requesting:

• Reduction of the restricted amount;
• Release of unrelated funds;
• Release of operational funds;
• Replacement with a less restrictive measure.

What If the Investor Is Not a Suspect?

This can materially strengthen the need for careful proportionality review.

Funds may sometimes be held in an account belonging to someone other than the principal suspect.

Turkish criminal procedure can permit measures affecting assets in another person’s possession under applicable statutory conditions.

However, the good faith of a third-party owner and the connection between the asset and alleged criminal conduct remain important considerations in property-rights analysis.

The Constitutional Court has emphasized the importance of protecting good-faith property owners from excessive asset restrictions.

What If the Foreign Investor’s Company Received Suspicious Money Without Knowing It?

This frequently requires detailed factual analysis.

For example, a Turkish company may receive money from:

• Customer;
• Distributor;
• Foreign buyer;
• Business partner;
• Shareholder;
• Borrower;
• Related company.

Authorities later allege that the funds originated from fraud or another offence.

The company should establish:

1. Why the payment was received;
2. Whether a genuine commercial relationship existed;
3. What goods or services were supplied;
4. Whether the company knew anything about the alleged criminal source;
5. What happened to the funds afterward.

A good-faith commercial recipient is factually different from a company knowingly used to transfer criminal proceeds.

What If the Account Is Frozen Because of an International Transfer?

International transfers can require examination of:

• Sender;
• Beneficial owner;
• Transaction purpose;
• Contract;
• Invoice;
• Country of origin;
• Related companies;
• Ultimate destination of funds.

The investor should reconstruct the transaction with documentary evidence.

Useful records include:

• SWIFT messages;
• Bank statements;
• Contracts;
• Invoices;
• Customs declarations;
• Shipping records;
• Corporate resolutions;
• Accounting entries;
• Source-of-funds evidence.

Does a Foreign Investor Have Fewer Rights Than a Turkish Investor?

Foreign status does not mean that authorities can maintain an arbitrary financial restriction.

The constitutional principles governing legality and protection of property remain relevant to measures affecting assets in Turkey.

The Constitution protects property rights and requires interferences with protected rights to have a legal basis and satisfy constitutional limitations.

The investor’s nationality does not itself prove that funds are suspicious.

What If the Company Cannot Pay Employees?

This should be documented immediately.

The company should prepare evidence showing:

• Payroll obligations;
• Number of employees;
• Salary dates;
• Social security payments;
• Tax obligations;
• Supplier debts;
• Rent;
• Customs charges;
• Essential operational expenses.

These documents may support an argument that the breadth or continued application of the measure creates severe consequences.

Can Operational Funds Be Released?

Depending on the legal basis of the restriction, a request for partial release or narrowing of the measure may be considered.

The company may seek to demonstrate that particular amounts are needed for legitimate obligations such as:

• Salaries;
• Taxes;
• Social security contributions;
• Essential suppliers;
• Customs payments;
• Court-ordered obligations.

Whether such a request is available and which authority can decide it depends on the type of freeze.

Can the Investor Object While the Investigation Is Still Pending?

Potentially, yes.

An investor should not necessarily assume that no remedy exists until the criminal investigation ends.

Where criminal-procedure seizure is involved, the applicable objection and lifting procedures should be examined.

The investor may challenge:

• Legal basis;
• Scope;
• Connection with alleged offence;
• Continued necessity;
• Proportionality;
• Excessive duration.

Can the Investor Ask for the Freeze to Be Reviewed Again?

Potentially.

A measure that was justified at the beginning of an investigation may require reassessment after new evidence emerges.

For example:

Month 1: Authorities do not know the origin of USD 2 million.

Month 4: The investor provides contracts, invoices, customs records and bank statements.

Month 8: Foreign banking information confirms the transaction.

If the original suspicion has materially weakened, continued restriction may require renewed justification.

What If Authorities Give No Explanation for Months?

The investor should identify the formal procedural status rather than relying exclusively on information from the bank.

Relevant questions include:

• Is there a criminal investigation?
• What is the investigation number?
• Was a judicial seizure order issued?
• Which authority issued it?
• Has the measure been reviewed?
• What assets are covered?
• What offence is being investigated?

Access to certain investigation information may be restricted, but the legal status of the measure should still be investigated through the appropriate procedure.

Can the Bank Remove the Freeze on Its Own?

Not necessarily.

If the bank is complying with a prosecutor’s or court’s legally binding decision, repeated requests to the branch may not solve the problem.

The challenge must be directed at the underlying legal measure.

By contrast, if the restriction is purely an internal bank compliance decision, a different approach may be necessary.

Does Filing an Objection Automatically Unfreeze the Account?

No.

An objection or request to lift the restriction does not necessarily produce immediate release.

The competent authority must decide the request.

This makes the supporting evidence especially important.

What Evidence Should Accompany a Request to Lift the Freeze?

Depending on the case:

1. Bank statements;
2. SWIFT documents;
3. Contracts;
4. Invoices;
5. Customs declarations;
6. Shipping records;
7. Accounting records;
8. Tax declarations;
9. Corporate records;
10. Shareholder information;
11. Beneficial ownership records;
12. Loan agreements;
13. Source-of-funds evidence;
14. Payroll documents;
15. Evidence of operational losses.

The objective should be to demonstrate both the legitimacy of the funds and the disproportionate consequences of continuing the restriction.

Can a Foreign Investor Claim Compensation Later?

Potentially, depending on the legal basis and outcome.

Turkish criminal procedure provides compensation mechanisms for certain unlawful protective measures, and Constitutional Court case law also recognizes the importance of effective remedies concerning interference with property.

Whether compensation is available in a particular account-freeze case depends on the type of measure, procedural history and circumstances.

What Damages Should a Company Document?

Even before knowing whether compensation will ultimately be available, the company should document losses such as:

• Bank charges;
• Default interest;
• Penalties;
• Cancelled contracts;
• Lost customers;
• Supplier claims;
• Emergency borrowing costs;
• Employee claims;
• Customs and storage costs;
• Business interruption.

Contemporaneous evidence is significantly more useful than attempting to reconstruct losses years later.

Can Lost Profits Be Recovered?

This depends on the applicable cause of action and strength of evidence.

Lost-profit claims require strong proof of causation.

The company should preserve:

• Existing contracts;
• Confirmed orders;
• Historical revenue;
• Cancelled transactions;
• Correspondence explaining cancellation;
• Financial statements.

Purely speculative profits are more difficult to establish.

When Does a Long Freeze Become a Property-Rights Issue?

There is no automatic numerical threshold.

Instead, the analysis considers factors such as:

• Lawfulness;
• Purpose;
• Duration;
• Scope;
• Investor’s conduct;
• Connection with alleged offence;
• Availability of review;
• Reasons for continuing the measure;
• Economic burden.

The Constitutional Court has expressly emphasized that temporary asset measures can become disproportionate where their duration imposes an excessive burden without adequate continuing justification.

Can the Constitutional Court Become Relevant?

Potentially, after applicable ordinary remedies have been exhausted and subject to the requirements governing individual applications.

The Constitutional Court has developed substantial case law concerning seizure, asset restrictions and the constitutional right to property.

However, an individual application is not ordinarily a substitute for using available objections and judicial remedies at the appropriate earlier stages.

2026 Practical Timeline for a Frozen Bank Account

There is no universal legal timeline, but investors can think about the process in stages.

Initial Stage

Identify whether the issue is:

• Bank compliance;
• Temporary transaction postponement;
• MASAK-related process;
• Prosecutorial measure;
• Judicial seizure.

Early Investigation

Obtain available information and reconstruct the questioned transactions.

Continuing Restriction

Submit evidence and assess whether the measure remains necessary.

Prolonged Restriction

Examine proportionality, scope, duration and whether authorities continue to provide a legitimate justification.

Judicial Challenge

Use the procedural remedy applicable to the actual measure.

Post-Investigation

If the measure was unlawful or caused compensable damage, evaluate available compensation remedies.

10 Questions Foreign Investors Should Ask Immediately

1. Who froze the account?

Bank, prosecutor, court or another authority?

2. What is the legal basis?

Do not rely on the phrase “MASAK block.”

3. When did the restriction begin?

Establish the exact date.

4. What amount is restricted?

Entire balance or specific funds?

5. Which transaction is being investigated?

Identify the disputed money flow.

6. Is there a judicial decision?

Obtain it where legally accessible.

7. Can the source of funds be documented?

Prepare evidence immediately.

8. Is the company unable to operate?

Document the consequences.

9. Can a narrower measure achieve the same purpose?

Consider partial release or limitation.

10. Has the measure continued longer than its justification?

Duration should be reviewed as the investigation progresses.

Frequently Asked Questions

1. How long can a foreign investor’s bank account remain frozen in Turkey?

There is no single maximum period applicable to every account restriction. The answer depends on whether the measure is a temporary anti-money-laundering restriction, judicial seizure, bank compliance measure or another statutory restriction.

2. Does every MASAK-related freeze end after a few days?

No. A short-term transaction restriction and a subsequent judicial seizure are legally different measures. A criminal-procedure seizure can potentially continue for substantially longer.

3. Can a judicial bank account seizure continue during the investigation?

Potentially, yes, provided the legal requirements for the measure and its continued application remain satisfied.

4. Can the investor challenge the freeze before the investigation ends?

Potentially, yes. Depending on the legal basis, the investor may seek removal, limitation or review of the measure.

5. Is there an automatic one-year maximum?

No general one-year maximum applies to every Turkish bank-account freeze. Any time limit must be identified from the specific legal mechanism involved.

6. Can a very long freeze violate property rights?

Yes, potentially. The Constitutional Court has emphasized that asset restrictions must remain proportionate in scope and duration and has found a violation where a bank-account restriction continued for more than five years without adequate justification.

7. Can the company request partial release?

Depending on the legal mechanism, the company may seek limitation of the restriction or release of funds unrelated to the investigation.

8. Does being a foreign investor make a longer freeze lawful?

No. Foreign nationality itself does not provide justification for an arbitrary or disproportionate asset restriction.

9. Can the company claim damages for an unlawful freeze?

Potentially, depending on the legal basis, procedural history, outcome and evidence of actual loss.

10. What is the most important first step?

Determine exactly who imposed the freeze, when it began, which amount is affected, what legal provision supports it and whether a prosecutor or judicial decision exists.

Client-Focused Legal Support for Prolonged Bank Account Freezes

A foreign investor should not assume that a bank account can lawfully remain frozen indefinitely merely because a Turkish investigation is still open.

At the same time, there is no universal deadline requiring every account restriction to be removed after the same number of days.

The legal analysis must distinguish between a temporary anti-money-laundering measure, bank compliance restriction, prosecutorial investigation and judicial seizure order.

Where a restriction becomes prolonged, the key questions increasingly concern its legal basis, continuing necessity, scope, connection with the alleged offence and proportionality.

Fırat Fesih Kaya Law Office assists foreign investors, foreign-owned companies and corporate executives with prolonged bank-account restrictions, MASAK-related financial investigations, judicial seizure measures, source-of-funds disputes and applications seeking removal or limitation of asset restrictions in Turkey.

Lawyer Fırat Fesih Kaya provides legal assistance in reconstructing disputed financial transactions, preparing source-of-funds evidence, challenging prolonged restrictions and evaluating compensation claims arising from allegedly unlawful asset measures.

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

This article is intended for general information and does not constitute legal advice. The permissible duration and appropriate remedy depend on the precise statutory basis of the restriction, the issuing authority, the investigation stage, the funds concerned and the procedural history of the individual case.