Imported Goods Are Seized and Company Bank Accounts Are Frozen in Turkey: Emergency Legal Remedies for Foreign Investors (2026 Updated Guide)

Imported goods are seized and company bank accounts are frozen in Turkey. Learn the emergency legal remedies available to foreign investors facing customs, criminal, financial and asset-freezing measures.

When a foreign-owned company in Turkey simultaneously faces seizure of imported goods and freezing of company bank accounts, the situation can rapidly develop from an ordinary customs dispute into a serious financial and criminal investigation. The company may suddenly lose access to imported inventory, working capital, supplier payments, employee salaries and daily operating funds. The most important issue is to determine immediately which authority ordered each measure, why the goods were seized, why the accounts were frozen and whether the two measures arise from the same investigation. Customs detention, criminal seizure, precautionary attachment and judicial freezing orders are legally different measures and may require different objections.

Why Can Imported Goods Be Seized?

Imported goods may be detained or seized because authorities suspect incorrect customs declarations, false documents, undervaluation, incorrect origin, tariff-classification problems, prohibited or restricted imports, smuggling, sanctions-related irregularities or another customs violation.

The legal consequences depend heavily on whether the goods are merely being held during administrative examination or formally seized as evidence or suspected proceeds in a criminal investigation.

Why Can Company Bank Accounts Be Frozen?

A bank-account restriction may arise from a judicial investigation, prosecutor’s request, court order, financial-crime investigation, public receivables enforcement or another legally authorized measure.

The company should obtain the precise legal basis rather than relying on the bank’s statement that the account has simply been “blocked.”

Goods Seizure and Bank Freezing Must Be Analyzed Separately

Even where both measures arise from the same investigation, they may have different legal foundations.

A successful objection concerning imported goods does not necessarily release bank accounts automatically. Likewise, removal of an account restriction does not necessarily resolve the customs dispute.

First Determine Which Authority Ordered the Measures

Immediately identify whether the relevant actions originate from Customs, the public prosecutor, a criminal court, another administrative authority or public-receivables enforcement authorities.

This determines where the defense should be directed.

Obtain the Seizure Documentation

Request copies of available seizure records, inspection reports, customs documents, prosecutor’s decisions, court orders and inventories identifying the goods.

The company should know exactly which goods have been seized and under which legal basis.

Obtain the Bank Freeze Decision

Ask the bank for available information identifying the authority and reference underlying the restriction. Counsel should then obtain the relevant decision through the appropriate procedural channels.

Without the actual decision, the company may not know whether the restriction covers all accounts, a specified amount or particular transactions.

Determine Whether There Is a Criminal Investigation

One of the first questions should be whether a prosecutor has opened an investigation involving suspected customs smuggling, document fraud, money laundering or another alleged offense.

The company’s response should change immediately if the dispute has moved from administrative customs enforcement into criminal procedure.

Do Not Treat a Criminal Investigation as an Ordinary Customs Audit

Once criminal exposure exists, explanations given casually to Customs or other authorities can later become evidence.

Management, employees, customs brokers and logistics personnel should coordinate communications with legal counsel.

Preserve the Customs File

Collect the import declaration, commercial invoice, packing list, purchase agreement, transport documents, certificates, payment records, tariff-classification materials, origin documents and communications with the foreign supplier.

The objective is to reconstruct exactly what information existed when the import declaration was submitted.

Preserve Banking Evidence

Collect payment instructions, SWIFT records, bank statements, supplier payments, financing agreements and documents showing the commercial purpose of transfers connected with the imported goods.

This evidence may become important where authorities question the financial side of the transaction.

Do Not Alter Company Records

Once an investigation begins, employees should be instructed not to delete emails, messages, accounting records, customs files or payment documentation.

Attempts to “clean up” the file can create substantially greater legal risks.

Determine Why Customs Suspects the Transaction

The defense should identify the exact allegation. Is Customs alleging undervaluation? False origin? Incorrect tariff classification? Fake certificates? Undeclared royalties? Prohibited goods? Smuggling?

A generic defense to “customs problems” is insufficient.

Customs Valuation Disputes Require Transaction Evidence

If authorities believe the imported goods were undervalued, preserve contracts, invoices, payment records, price lists, transfer-pricing information and explanations concerning discounts.

A difference of opinion concerning customs value should be distinguished carefully from an allegation that documents were deliberately falsified.

Origin Disputes Require Manufacturing Evidence

If seizure arises from suspected incorrect origin, obtain factory records, bills of materials, manufacturing-flow information, supplier declarations and relevant origin documents.

The country of shipment should not automatically be confused with the country of origin.

Classification Disputes Require Technical Evidence

Where Customs alleges an incorrect tariff code, obtain technical specifications, catalogues, composition information, drawings and independent expert evidence where appropriate.

A genuine classification disagreement should be distinguished from intentional misdeclaration.

False-Document Allegations Require Immediate Investigation

If Customs suspects a forged invoice, Certificate of Origin, A.TR, EUR.1 or another document, determine who created, issued, transmitted and submitted the document.

The Turkish importer may have received the document from the foreign supplier without knowing that it was inaccurate.

Importer Knowledge Can Become Critical

Criminal liability should not automatically be inferred merely because an incorrect document appeared in the customs file.

The investigation should examine who knew what, when they knew it and what role each individual actually played.

Corporate Liability and Individual Liability Must Be Distinguished

The company, shareholder, director, employee, customs broker and foreign supplier are separate actors.

A manager should not automatically be treated as personally responsible merely because they hold a senior corporate title.

Directors Should Identify Their Actual Role

Where a director or foreign manager is questioned, determine whether they participated in purchasing, customs instructions, invoice approval, supplier selection, payment arrangements or document preparation.

Corporate authority alone does not answer every question concerning personal criminal responsibility.

Customs Broker Communications Are Important

Collect instructions sent to the customs broker and documents provided before the declaration.

These records can help establish whether the company accurately disclosed the transaction or whether an error arose during customs processing.

Why Are Bank Accounts Relevant to a Customs Investigation?

Authorities may examine whether funds in company accounts are connected with alleged criminal activity, disputed imports or transactions under investigation.

The legal basis for freezing must nevertheless be identified and assessed separately.

Is the Entire Account Frozen or Only a Specified Amount?

This distinction can be commercially crucial.

The company should determine whether the restriction applies to all transactions, particular accounts or an amount connected with the alleged offense.

Proportionality Should Be Examined

A restriction affecting a company’s entire operating capital can have severe consequences.

Where permitted by the applicable procedure, the defense should examine whether the scope and continued necessity of the measure are justified in light of the amount and allegations under investigation.

Document the Company’s Operating Needs

Prepare evidence concerning employee salaries, taxes, rent, utilities, loan payments, critical suppliers and other essential operating expenses.

This information can support arguments concerning the practical effect of an excessively broad restriction.

Can the Bank Freeze Be Challenged?

Potentially. The appropriate objection depends on the legal basis and authority that ordered the restriction.

The defense should identify the available procedure immediately because financial restrictions can cause severe losses within days.

Can the Seizure of Goods Be Challenged?

Potentially. The correct remedy depends on whether the goods are held under customs legislation, seized within criminal proceedings or subject to another administrative measure.

The seizure record and underlying decision should be reviewed before choosing the remedy.

Request Release Where the Legal Basis No Longer Exists

If evidence has been preserved and continued possession of the goods is unnecessary, the company may evaluate whether return or release can be requested under the applicable procedure.

For perishable, depreciating or commercially sensitive goods, urgency should be documented.

Perishable Goods Require Immediate Action

Food, pharmaceuticals, chemicals and other time-sensitive products can lose substantial value while proceedings continue.

Document expiry dates, temperature requirements and deterioration risk immediately.

Machinery and Production Inputs Can Create Business Interruption

If seized goods are raw materials, components or machinery required for production, prepare evidence showing the effect on the company’s operations.

Production schedules, customer contracts and factory records may become important.

Can Security Be Offered Instead?

Depending on the legal basis of the measure, the possibility of security, partial release or another less restrictive mechanism may need to be evaluated.

No universal right to substitute security should be assumed.

Emergency Judicial Protection May Be Necessary

Where administrative or judicial measures threaten irreversible commercial damage, available urgent remedies should be assessed immediately.

The correct court and procedure depend on the legal nature of the disputed measure.

Customs Objection Deadlines Must Also Be Protected

If Customs separately issues additional duty or penalty decisions, those administrative decisions may have their own objection periods.

A criminal investigation does not necessarily suspend or replace customs-law deadlines.

Multiple Proceedings Can Run at the Same Time

A company may simultaneously face a customs assessment, administrative penalty, seizure of goods, criminal investigation and bank-account restriction.

Each file should be mapped separately with its own authority, deadline and remedy.

Create a Case Matrix

For complex investigations, prepare a table identifying each decision, issuing authority, legal basis, notification date, amount or asset affected, objection deadline and responsible lawyer or company representative.

This prevents urgent deadlines from being missed.

Foreign Parent Companies Should Coordinate Carefully

If the Turkish importer belongs to an international group, headquarters should establish a controlled investigation-response process.

Uncoordinated communications from different group companies can create inconsistencies concerning pricing, origin or payment structures.

Intercompany Transactions May Be Examined

Where the Turkish company purchases goods from a foreign parent or affiliate, authorities may scrutinize pricing and payment arrangements more closely.

Prepare transfer-pricing documentation and commercial explanations where relevant.

Do Not Make Unexplained Emergency Transfers

Once an investigation is known, unusual transfers between related companies can attract additional scrutiny.

Legitimate payments should remain properly documented and consistent with ordinary business activity.

Review Sanctions and Compliance Issues

If the investigation involves a sanctioned supplier, intermediary, vessel or payment route, conduct a separate sanctions and compliance review.

Customs, banking and criminal risks may overlap.

Foreign Suppliers Must Preserve Evidence

Send an immediate preservation request to the supplier covering invoices, production records, origin evidence, contracts, certificates and correspondence.

Supplier cooperation may become essential to the Turkish defense.

Supplier Liability Should Also Be Reviewed

If the investigation arose because the foreign supplier provided false origin information, manipulated invoices or invalid certificates, the Turkish importer may have contractual claims.

Those private-law claims should be preserved while the public investigation continues.

Insurance Policies Should Be Reviewed

Depending on the facts, relevant policies may include cargo, crime, directors’ and officers’ liability or other commercial coverage.

Notice requirements should be checked promptly.

Document All Financial Losses

Maintain records of storage charges, demurrage, lost production, financing costs, cancelled orders and other losses.

Whether those losses can ultimately be recovered depends on the legal basis and responsible party, but evidence should be preserved from the beginning.

Do Not Assume Seizure Means Guilt

Seizure and freezing measures are protective or investigative measures. Their existence does not itself establish final criminal liability.

The defense should focus on the evidence and legal requirements underlying the allegations.

Prepare Management Before Statements

Foreign directors or managers summoned by investigators should understand the subject of the investigation and their procedural rights before providing statements.

Interpreters should be arranged where necessary.

Avoid Speculative Answers

If a manager does not know who prepared an origin certificate or calculated a customs value, they should not guess.

Corporate investigations often involve technical facts handled by different departments.

Review Electronic Evidence

Emails, messaging applications, ERP records and approval systems may demonstrate how customs and purchasing decisions were made.

Preserve relevant electronic data systematically.

Protect Legal Privilege and Defense Strategy

Internal investigation work should be coordinated carefully with counsel. Sensitive legal analysis should not be distributed unnecessarily throughout the corporate group.

Review Historical Imports

Authorities may expand the investigation to previous declarations involving the same supplier, product, valuation method or origin.

Conduct an internal review before additional questions arrive.

Review Goods Already in Transit

Determine whether other shipments use the same documents, supplier or customs methodology.

It may be commercially prudent to resolve identified compliance problems before additional goods reach Turkish Customs.

Immediate 48-Hour Response Strategy

During the first stage, the company should identify every authority involved, obtain seizure and freezing decisions, confirm whether a criminal investigation exists, preserve customs and banking records, stop document deletion, determine the precise customs allegation, map procedural deadlines, notify relevant insurers and suppliers, assess urgent objections and document the operational consequences of the restrictions.

Speed matters because a manageable customs dispute can become a severe liquidity and business-continuity problem when company accounts and imported inventory are simultaneously inaccessible.

Frequently Asked Questions

Can Turkish authorities seize imported goods and freeze company accounts at the same time?

Potentially, where separate legal grounds support the respective measures. Each decision should be examined independently.

Does seizure mean the company committed customs smuggling?

No. Seizure does not itself establish final criminal liability.

Can a foreign-owned company’s bank accounts be frozen?

Potentially, where an authorized authority orders a restriction under the applicable legal framework. The precise decision and scope should be obtained immediately.

Can the company challenge the bank freeze?

Potentially. The appropriate procedure depends on which authority imposed the measure and its legal basis.

Can seized imported goods be recovered before the investigation ends?

Potentially, depending on the nature of the seizure, evidentiary needs and applicable procedure.

What if the goods are perishable?

The deterioration risk, expiry date and storage conditions should be documented immediately and raised in any urgent request for relief.

Is the company director personally criminally liable for customs errors?

Not automatically. Personal criminal liability requires analysis of the individual’s actual conduct, knowledge and involvement rather than corporate title alone.

What if the foreign supplier provided the incorrect documents?

Preserve evidence showing what the supplier provided and what the Turkish company knew. Contractual claims against the supplier may also arise.

Can customs penalties and criminal proceedings continue simultaneously?

Potentially. Administrative customs proceedings and criminal investigations may involve separate legal issues and procedural deadlines.

What should the foreign investor do first?

Identify every decision and authority involved. Goods seizure, customs penalties, criminal investigation and bank-account freezing should be separated into distinct legal files while the overall defense remains coordinated. Immediate attention should then be given to objection deadlines, preservation of evidence, liquidity and business-continuity risks.

Client-Focused Legal Support for Emergency Customs and Asset-Freezing Cases

Simultaneous customs seizure and financial restrictions can threaten the continued operation of a foreign-owned company in Turkey. Fırat Fesih Kaya Law Office assists foreign investors, international companies, importers and company directors facing customs investigations, seizure of imported goods, financial restrictions, customs penalties and related criminal proceedings. Lawyer Fırat Fesih Kaya provides coordinated legal assistance concerning emergency objections, release of seized assets, customs defense, criminal investigations, management liability and contractual claims against foreign suppliers.

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