What should foreign shareholders do if their Turkish company’s bank accounts are blocked? Learn how to identify the reason, document legitimate funds, protect salaries and operations, seek partial release, challenge judicial restrictions and manage MASAK-related investigations.

When the bank accounts of a Turkish company owned by foreign shareholders are suddenly blocked, the consequences can be immediate.

The company may become unable to pay:

• Employees;
• Taxes;
• Social security liabilities;
• Suppliers;
• Customs duties;
• Rent;
• Loan instalments;
• Utilities;
• International counterparties.

Foreign shareholders should therefore treat a blocked corporate account as both a legal problem and a business-continuity emergency.

The first step is not simply to ask the bank repeatedly to “remove the block.”

The company must establish why the account is blocked, who imposed the restriction, what transactions are affected and which legal procedure applies.

Why Can a Turkish Company’s Bank Account Be Blocked?

The expression “blocked account” can describe several legally different situations.

The restriction may arise from:

• Internal bank compliance procedures;
• Customer identification or documentation problems;
• Suspicious transaction monitoring;
• A temporary transaction postponement;
• A MASAK-related financial review;
• A criminal investigation;
• A prosecutor- or court-related asset measure;
• Enforcement proceedings;
• Tax or public debt measures;
• Another legally authorized restriction.

These mechanisms should not be treated as interchangeable.

Is Every Blocked Account a “MASAK Freeze”?

No.

This is one of the most important points for foreign shareholders.

A bank employee may use general expressions such as:

“The account is under compliance review.”

or

“There is a MASAK issue.”

That does not necessarily identify the legal basis.

Under Law No. 5549, certain suspicious transactions can be postponed for up to seven working days under the specific statutory postponement mechanism. MASAK’s current guidance confirms the seven-working-day framework for those particular measures.

However, a separate judicial seizure or another statutory measure can operate differently and potentially continue longer.

Therefore:

Seven working days is not a universal maximum for every blocked company bank account in Turkey.

1. Identify Who Actually Blocked the Account

Foreign shareholders should immediately determine whether the restriction comes from:

• The bank itself;
• MASAK-related procedures;
• A prosecutor;
• A court;
• An enforcement office;
• A tax authority;
• Another public authority.

This determines where the company must direct its legal response.

If the bank is implementing a binding judicial decision, repeated negotiations with the branch manager will generally not resolve the underlying restriction.

2. Determine Exactly What Is Blocked

Not every restriction has the same scope.

Ask whether:

• All outgoing transfers are prohibited;
• Incoming payments remain possible;
• Only one transaction is suspended;
• A specific amount is unavailable;
• The entire balance is blocked;
• All company accounts at the bank are affected;
• Accounts at multiple banks are affected;
• Credit cards or other financial products are also restricted.

The legal strategy should reflect the actual scope.

3. Establish the Exact Date the Restriction Began

Create a written chronology.

Record:

• Date account access changed;
• First rejected transaction;
• First communication with the bank;
• Information provided by the bank;
• Documents requested;
• Documents submitted;
• Any official notification received.

This timeline can later become important when challenging the duration of the restriction.

4. Identify the Questioned Transaction

If the restriction appears connected with financial-crime concerns, determine which transaction may have triggered scrutiny.

Common examples include:

• Large international transfer;
• Foreign shareholder payment;
• Shareholder loan;
• Capital contribution;
• Cryptocurrency-related funds;
• Unusual customer payment;
• Funds received from an unrelated third party;
• Rapid incoming and outgoing transfers;
• Payment from a high-risk counterparty;
• Transfer inconsistent with the company’s ordinary business.

Do not assume every transaction in the account is under investigation.

5. Preserve All Banking Records

Immediately preserve:

• Account statements;
• SWIFT records;
• Payment instructions;
• Transfer receipts;
• Bank correspondence;
• Compliance requests;
• Documents previously submitted to the bank.

Do not alter or delete records.

6. Prepare a Source-of-Funds File

If the restriction concerns the legitimacy of incoming money, the company should build a complete documentary chain.

For each questioned payment, identify:

Sender → relationship → legal basis → underlying transaction → banking route → accounting treatment → use of funds.

Supporting evidence may include:

• Contracts;
• Invoices;
• Bank statements;
• Customs declarations;
• Shipping documents;
• Loan agreements;
• Corporate resolutions;
• Tax records;
• Accounting entries;
• Shareholder records.

The objective is not simply to state that the money is legitimate.

It is to prove why it is legitimate.

7. Document Foreign Shareholder Loans Carefully

A large payment from a foreign shareholder to a Turkish company may be completely legitimate.

However, the company should be able to establish:

• Identity of shareholder;
• Shareholding relationship;
• Amount;
• Purpose;
• Loan agreement;
• Transfer record;
• Repayment terms;
• Accounting treatment;
• Shareholder’s source of funds where relevant.

A payment should not be described inconsistently as capital, a loan, an advance and commercial revenue.

8. Document Capital Contributions

Where the payment represents investment capital, preserve:

• Shareholder resolution;
• Capital increase documents;
• Corporate records;
• Bank payment;
• Accounting records;
• Relevant registration documentation.

The legal characterization should correspond with the actual transaction.

9. Document International Trade Revenue

If the questioned money comes from an overseas customer, the company should reconstruct the trade.

Useful evidence can include:

• Sales agreement;
• Commercial invoice;
• Customs declaration;
• Bill of lading;
• Packing list;
• Delivery documents;
• Customer correspondence;
• Bank transfer;
• Accounting entry.

A genuine export transaction should ideally have a documentary trail from contract through payment.

10. Identify the Beneficial Owner

Complex foreign ownership structures can create additional compliance questions.

The company should be prepared to document:

• Direct shareholders;
• Indirect shareholders;
• Ultimate beneficial owner;
• Holding companies;
• Group relationships;
• Control structure.

The objective should be transparency rather than unnecessary complexity.

11. Do Not Ignore Requests From the Bank

If the bank requests documents, respond carefully and consistently.

Banks are subject to suspicious transaction reporting obligations under Turkey’s anti-money-laundering framework. MASAK updated its reporting framework in 2025 to reflect sectoral risks and the updated National Risk Assessment.

Incomplete or contradictory answers can prolong compliance problems.

12. Understand That the Bank May Not Disclose Everything

Foreign shareholders sometimes become frustrated because the bank provides very limited information.

This does not necessarily mean that no compliance process exists.

Suspicious transaction reporting is subject to confidentiality requirements.

The company should therefore focus on identifying the legal status through proper channels rather than demanding disclosure that the bank may not lawfully provide.

13. Separate a Temporary Transaction Postponement From a Longer Asset Measure

Under the specific transaction-postponement framework, certain suspicious transactions may be postponed for seven working days. MASAK’s regulation and current FAQ explain how that period operates.

But this does not mean:

Day 8 = every account must automatically be released.

Another legal measure may have been imposed.

If the restriction continues, determine whether there is:

• A criminal investigation;
• A seizure decision;
• Another administrative or judicial measure.

14. Protect Employee Salaries Immediately

If payroll is approaching, prepare:

• Employee list;
• Payroll records;
• Salary amounts;
• Payment date;
• Historical payroll payments.

If legally available under the particular restriction, these documents can support a request seeking access to funds required for payroll.

15. Document Tax and Social Security Obligations

Prepare evidence of:

• Tax liabilities;
• Filing deadlines;
• Social security contributions;
• Payment dates;
• Penalties for non-payment.

A complete freeze can create secondary liabilities even though the underlying investigation concerns an entirely different transaction.

These consequences should be documented.

16. Protect Customs and Import Operations

For companies engaged in international trade, blocked accounts can rapidly generate substantial losses.

The company may be unable to pay:

• Customs duties;
• Import taxes;
• Port expenses;
• Storage;
• Freight;
• Demurrage;
• Customs brokers.

Preserve evidence showing the daily financial consequences of the restriction.

17. Notify Critical Counterparties Carefully

Important counterparties may need to be informed if payments cannot be made.

However, communications should be carefully worded.

The company should avoid unnecessary statements suggesting criminal wrongdoing where no such finding exists.

A financial investigation or account restriction does not equal a criminal conviction.

18. Review Loan Agreements

Blocked accounts can trigger financing problems.

Review:

• Payment obligations;
• Default clauses;
• Cross-default provisions;
• Financial covenants;
• Material adverse event clauses;
• Notice requirements.

The company may need to notify lenders before a technical default occurs.

19. Review Major Commercial Contracts

The same applies to:

• Supply agreements;
• Distribution agreements;
• Leases;
• Franchise agreements;
• Construction contracts;
• Major customer contracts.

The company should determine whether delayed payment creates termination or penalty exposure.

20. Can Foreign Shareholders Request Complete Release?

Potentially.

If the legal requirements for the restriction are not satisfied, the appropriate strategy may be to seek complete removal.

Arguments can potentially involve:

• Legitimate source of funds;
• Lack of connection with alleged criminal activity;
• Incorrect identification of transactions;
• Lack of sufficient legal basis;
• Changed circumstances;
• Disproportionate continuation.

The exact remedy depends on the measure.

21. Can the Company Request Partial Release?

Potentially.

Complete removal is not necessarily the only strategy.

Where the investigation concerns only a specific transaction or amount, the company may examine whether it can seek:

• Release of unrelated funds;
• Limitation to the disputed amount;
• Release of historical company savings;
• Access for salaries;
• Access for mandatory public payments;
• Release of subsequent legitimate revenue.

The request should be supported by detailed fund tracing.

22. Why Does Proportionality Matter?

Restrictions on financial assets interfere with property rights.

The Constitutional Court’s case law examines whether such measures maintain a reasonable balance between the public interest and the burden imposed on the property owner.

In one case, the Court specifically noted that the seizure was limited to the financial interest involved and treated this as relevant to proportionality.

This can be important where an investigation concerns a limited transaction but every operating account of a substantial company becomes inaccessible.

23. Can a Company Argue That the Freeze Is Too Broad?

Potentially.

Consider:

Transaction under investigation: USD 200,000

Total company funds restricted: USD 4 million

Employees: 150

Monthly payroll: USD 300,000 equivalent

The company may need to examine whether restricting the entire balance remains necessary.

The amount allegedly connected with the investigation and the amount actually restricted should be compared carefully.

24. Can Operational Payments Be Requested?

Depending on the applicable legal measure, the company may consider seeking narrowly defined access for essential payments.

These might include:

• Salaries;
• Taxes;
• Social security;
• Utilities;
• Critical suppliers;
• Customs charges.

A controlled-payment request can sometimes be more focused than asking for unrestricted access to the entire account.

25. Can New Legitimate Revenue Be Released?

Potentially.

Suppose the original restriction concerns a payment received six months ago, but the company continues receiving legitimate revenue from unrelated customers.

The company should distinguish:

• Historical questioned funds;
• Pre-existing legitimate balance;
• New post-restriction revenue.

Separate tracing may support an argument for narrower treatment.

26. What If Several Company Accounts Are Blocked?

Prepare an account-by-account analysis.

For each account identify:

• Opening balance;
• Questioned transaction;
• Incoming legitimate revenue;
• Current balance;
• Operational purpose.

One account may contain the questioned transaction while another may be used exclusively for payroll or ordinary commercial activity.

27. What If the Company’s Money Is Mixed With Allegedly Suspicious Funds?

Fund tracing becomes more complicated but remains important.

The company should reconstruct:

• Balance before the questioned payment;
• Amount received;
• Subsequent transfers;
• Payments made afterward;
• Remaining balance.

Accounting and forensic financial analysis may be necessary in complex cases.

28. Can Shareholders Simply Open Another Company Account?

A company should not use another account as a method of circumventing a legally binding restriction.

There is a major difference between:

legitimate business continuity using unrestricted funds

and

deliberately moving assets to defeat an official measure.

Any alternative banking arrangement should be reviewed carefully.

29. Should Shareholders Use Their Personal Accounts?

Generally, mixing corporate transactions with shareholders’ personal accounts can create substantial legal, accounting and evidentiary problems.

It may also complicate the financial investigation.

Foreign shareholders should avoid improvised arrangements designed to conceal or reroute company money.

30. Can a Shareholder Inject New Money Into the Company?

Potentially, but the transaction should be reviewed before funds are sent.

Questions include:

• Can the company legally receive the money?
• Will the new money immediately become restricted?
• Is it capital or a shareholder loan?
• Can its source be documented?
• Does the existing decision cover newly received funds?

Do not send substantial new funds without understanding the scope of the existing restriction.

31. Can Directors Become Personally Involved?

Potentially.

Authorities may investigate directors who:

• Authorized questioned transfers;
• Controlled bank accounts;
• Gave payment instructions;
• Signed questionable documents;
• Personally received company money;
• Participated in concealment.

However, a director’s position alone does not automatically establish personal criminal liability.

32. Are Foreign Shareholders Personally Liable for the Company’s Transactions?

Not automatically.

Share ownership and personal criminal responsibility are different issues.

The investigation should distinguish:

• Company;
• Shareholders;
• Directors;
• Employees;
• Beneficial owners;
• Counterparties.

Each person’s actual conduct matters.

33. Can the Shareholders’ Personal Accounts Also Be Examined?

Potentially, particularly where investigators suspect movement of company funds into personal accounts or vice versa.

Foreign shareholders should therefore preserve:

• Personal transfer records;
• Shareholder loan documents;
• Dividend records;
• Capital contribution records;
• Reimbursement documentation.

Corporate and personal money should be clearly distinguishable.

34. Can Company Shares Also Be Restricted?

Potentially.

A criminal investigation concerning corporate finances can, where the applicable statutory conditions are satisfied, lead to protective measures affecting shares or other assets.

A restriction on company bank accounts should nevertheless not automatically be treated as a restriction on every shareholder’s personal property.

Separate legal bases must be examined.

35. Can a Trustee Be Appointed to the Company?

In qualifying investigations and where statutory requirements are met, Turkish criminal procedure can permit a trustee measure affecting company management.

This is significantly different from an ordinary blocked bank account.

Recent Constitutional Court case law has also examined prolonged trustee measures in complex investigations involving international transfers and corporate financial structures, emphasizing the importance of concrete facts, necessity and continuing judicial review.

36. What If the Restriction Continues for Months?

Duration should be monitored continuously.

A measure justified at the beginning of an investigation does not necessarily remain proportionate indefinitely without continuing justification.

The Constitutional Court has previously found a property-rights violation where a bank-related restriction continued for more than five years and four months without sufficient justification for its prolonged continuation.

This does not establish a fixed maximum period.

It demonstrates that duration and continuing justification matter.

37. Should the Company Document Financial Damage?

Yes.

Create a contemporaneous loss file covering:

• Default interest;
• Penalties;
• Cancelled orders;
• Lost customers;
• Supplier claims;
• Emergency financing;
• Storage charges;
• Demurrage;
• Payroll disruption;
• Production stoppage;
• Lost contracts.

Whether compensation can ultimately be obtained depends on the legal basis and outcome, but evidence should be preserved immediately.

38. What Should the Company Never Do?

Foreign shareholders and directors should never attempt to “solve” the problem by creating artificial documentation.

Avoid:

• Fake invoices;
• Backdated contracts;
• False shareholder loans;
• Altered bank statements;
• Fictitious consultancy agreements;
• Undisclosed nominee transactions;
• Destroying emails;
• Deleting accounting records;
• Secretly transferring assets to related companies.

These actions can substantially worsen the legal situation.

39. First 48-Hour Action Plan

Step 1 — Identify the Restriction

Determine whether it originates from the bank or a public authority.

Step 2 — Determine the Scope

Identify every affected account and amount.

Step 3 — Preserve Banking Records

Secure statements, SWIFT documents and correspondence.

Step 4 — Identify Questioned Transactions

Determine what may have triggered scrutiny.

Step 5 — Build the Source-of-Funds File

Connect every material payment with legitimate commercial documentation.

Step 6 — Protect Payroll

Calculate immediate employee obligations.

Step 7 — Protect Public Payments

Identify tax and social security deadlines.

Step 8 — Review Critical Contracts

Check lenders, suppliers, landlords and major customers.

Step 9 — Assess Legal Remedies

Consider complete removal, narrowing or partial release depending on the measure.

Step 10 — Document Damage

Start recording operational losses immediately.

Frequently Asked Questions

1. Why would a Turkish company’s bank account suddenly be blocked?

Possible reasons include bank compliance procedures, suspicious transaction scrutiny, a temporary transaction postponement, a criminal investigation, judicial seizure, enforcement or other legally authorized measures.

2. Does every MASAK-related block last only seven working days?

No. Seven working days applies to the specific transaction-postponement mechanism. A separate judicial or other legal restriction may continue under different rules.

3. Can foreign shareholders ask the bank to remove the block?

They can seek clarification and provide requested documents, but if the bank is implementing a binding official decision, the underlying measure may need to be challenged through the appropriate legal procedure.

4. Can the company request partial release of funds?

Potentially. Depending on the measure, release of unrelated funds or amounts needed for essential obligations may be sought.

5. Can salaries and taxes be paid from a blocked account?

This depends on the scope and legal basis of the restriction. Where legally available, a company may seek limited access or controlled payment authorization for essential obligations.

6. Can the shareholders use their personal accounts to keep the business operating?

Using personal accounts to circumvent an official restriction can create serious problems. Corporate and personal funds should remain properly documented and separated.

7. Does a blocked company account mean the foreign shareholders are personally under criminal investigation?

No. The company’s financial position and each shareholder’s personal procedural status must be examined separately.

8. Can the company’s other bank accounts also be blocked?

Potentially, depending on the scope of the legal measure. Each account should be analyzed separately.

9. Can a prolonged account restriction be challenged as disproportionate?

Potentially. Scope, duration, necessity and continuing justification are relevant to property-rights analysis. Constitutional Court decisions demonstrate that both proportionality and duration can matter.

10. What should foreign shareholders do first?

Determine who imposed the restriction, which accounts and amounts are affected, what transaction triggered scrutiny, and whether an official investigation or judicial measure exists.

Client-Focused Legal Support for Blocked Turkish Company Accounts

A blocked company bank account can quickly turn a financial investigation into a business-continuity crisis.

Foreign shareholders should address both problems simultaneously.

The legal side requires identifying the authority and legal basis, reconstructing questioned transactions, proving the legitimate source of funds and evaluating whether the restriction can be removed or narrowed.

The commercial side requires protecting payroll, taxes, suppliers, customs operations, financing arrangements and major contracts.

Fırat Fesih Kaya Law Office assists foreign shareholders, foreign-owned Turkish companies, directors and international investors with blocked corporate bank accounts, MASAK-related investigations, source-of-funds disputes, international transfers and judicial asset restrictions in Turkey.

Lawyer Fırat Fesih Kaya provides legal assistance in reconstructing financial transactions, preparing supporting commercial evidence, challenging account restrictions and seeking release of legitimate corporate funds where the applicable procedure permits.

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 appropriate remedy depends on the legal basis, issuing authority, scope of the restriction, source of the company’s funds and circumstances of the individual investigation.