

A foreign national’s salary account is frozen during a criminal investigation in Turkey. Learn whether salary and living expenses can be released, how to challenge the freeze, what evidence should be submitted and which emergency legal remedies may be available.
A foreign national living or working in Turkey may suddenly discover that their bank account has been blocked because of an ongoing criminal investigation. The situation becomes particularly urgent when the frozen account is the person’s salary account and the restriction prevents payment of rent, food, utilities, medical expenses, school fees or other essential living costs. A criminal investigation does not necessarily mean that every amount held by the suspect must remain inaccessible indefinitely. The legal basis, scope, proportionality and continuing necessity of the measure should be examined. Depending on the circumstances, it may be possible to seek removal of the restriction, narrowing of the measure or access to amounts necessary for ordinary living expenses.
Bank accounts may become subject to restrictions where prosecutors or courts consider financial assets relevant to an investigation. Cases involving fraud, money laundering, proceeds of crime, organized crime, misuse of bank accounts, cybercrime and certain financial offences frequently involve examination of bank transactions.
However, the precise legal basis must be identified in each case.
An investigation-stage measure is not the same as a final criminal judgment.
The authorities may be attempting to preserve suspected criminal proceeds, prevent transfer of disputed assets or secure evidence while an investigation continues.
The suspect retains procedural rights to challenge measures affecting their property.
The account holder should identify:
which authority ordered or caused the restriction; which investigation file is involved; whether the measure covers one account or several accounts; whether a specific amount or the entire balance is affected; and the stated legal basis for the restriction.
Without this information, it is difficult to select the correct remedy.
The bank may be able to identify whether the restriction results from a prosecutor’s office, court, financial authority or another legally authorized measure.
Banks generally cannot simply disregard a binding official restriction because the customer explains that the account contains salary.
Where legally accessible, determine the prosecutor’s office, investigation number and allegations involved.
If the investigation file is subject to confidentiality restrictions, access to certain documents may be limited. This does not necessarily prevent counsel from making an appropriate application concerning the frozen assets.
The source of the money can be extremely important.
Relevant evidence may include the employment agreement, payroll slips, social security records, employer correspondence, bank statements showing recurring salary transfers and documentation identifying the employer’s account.
The objective is to demonstrate clearly that the disputed balance represents legitimate employment income.
Prepare a transaction chronology showing when salary entered the account and how much was paid each month.
If the account also contains unrelated transfers, identify them separately rather than describing the entire balance as salary without supporting evidence.
Many people use one account for salary, savings, family transfers and ordinary payments.
If legitimate salary income is mixed with transactions questioned by prosecutors, prepare a detailed source-of-funds analysis distinguishing each category.
Depending on the legal basis and circumstances of the measure, an application may potentially seek complete removal or narrowing of the restriction, including consideration of amounts required for reasonable living expenses.
There is no automatic rule that every person whose account is frozen will immediately receive a fixed monthly allowance.
A fact-specific application supported by evidence is therefore important.
A request for access to living expenses should not simply state that the applicant “needs money.”
Provide evidence of rent, utilities, food obligations, dependants, education expenses, necessary insurance or similar recurring financial obligations.
If the foreign national rents accommodation in Turkey, provide the lease and evidence of the monthly rent.
If eviction or serious contractual consequences are approaching, explain the urgency.
Where the suspect financially supports a spouse, children or other dependants, relevant expenses should be documented.
The application should explain how a complete account freeze affects persons who are not themselves suspects.
Where money is required for necessary treatment or medication, supporting invoices, appointment information or other appropriate documentation can strengthen the urgency of the request.
Applications concerning frozen funds should be precise.
If the monthly salary is a specific amount, demonstrate it through payroll and bank records. If rent is due, provide the lease. If school fees must be paid, provide the relevant documentation.
This may be an important argument.
If the investigation concerns a particular disputed transaction or amount, counsel can examine whether maintaining a restriction over the entire balance is necessary and proportionate.
The answer depends on the legal basis and facts of the investigation.
Suppose the investigation concerns one suspicious transfer while the account also contains months of documented salary income.
The defense should distinguish the questioned amount from independently documented legitimate funds and argue accordingly.
Foreign nationals should collect evidence demonstrating the origin of their money.
Examples include salary payments, business income, property-sale proceeds, inheritance, family support, investment income and documented savings.
Different sources require different evidence.
If the salary account also received transfers from abroad, prepare documentation showing the sender, reason for payment and economic basis.
Unexplained international transfers can complicate an otherwise straightforward salary-release request.
Where the account has been used for cryptocurrency purchases or sales, maintain exchange records and evidence connecting fiat transfers with the relevant transactions.
Do not conceal cryptocurrency activity if it appears in the bank statements.
Fraud investigations frequently involve rapid restrictions on bank accounts because investigators may attempt to trace allegedly transferred victim funds.
The defense should reconstruct the flow of money and identify which transactions are connected with the allegation and which arise from legitimate salary income.
If the foreign national allowed another person to use the account, investigators may examine whether the account holder knowingly participated in the alleged offence.
The account holder should obtain legal advice before providing explanations because statements about control of the account can have criminal-law consequences.
If the origin of a payment is unclear, investigate it before submitting a written explanation.
An inaccurate explanation can later conflict with bank records, messages or statements from other persons.
Obtain complete statements rather than screenshots showing selected transactions.
The defense should understand the entire financial pattern before requesting release.
A letter from the employer confirming employment, salary amount, payroll account and payment dates may help establish the legitimate nature of recurring deposits.
It should correspond with payroll and bank records.
Depending on the scope of the restriction, future incoming amounts may also become inaccessible.
The foreign employee should therefore determine whether the measure concerns the existing balance, a specified amount or the account itself.
This should not be done as an attempt to circumvent an existing judicial or prosecutorial measure.
Before changing payroll arrangements, the employee should understand the scope of the restriction and obtain appropriate legal advice.
Attempts to move funds through relatives, friends or newly opened accounts after learning of an investigation may create additional suspicion.
The lawful approach is to challenge or seek modification of the restriction through the appropriate procedure.
Potentially. The available objection or application mechanism depends on the legal basis of the measure and the authority responsible for it.
The defense should obtain the relevant decision where possible and identify the correct procedural route.
If the account has no demonstrated connection with the alleged offence, counsel may seek complete lifting of the measure rather than merely requesting living expenses.
The submission should explain why continuing the restriction is unnecessary.
Where complete removal is unlikely at the current stage, an alternative request can focus on clearly documented legitimate funds or necessary expenses, depending on the applicable legal framework.
Structuring primary and alternative requests can be useful.
A measure affecting property should be examined in light of its purpose, scope and duration.
If an investigation concerns a limited transaction but the person has been deprived of access to all lawful income for an extended period, proportionality can become an important part of the defense.
A restriction that may have been considered necessary at the beginning of an investigation should not simply be ignored for months.
The continuing legal and factual justification should be reviewed as the investigation develops.
Counsel should determine the procedural status of the application and whether another remedy is available under the particular legal basis.
Repeated informal visits to the bank will generally not resolve a restriction imposed by a competent authority.
Bank employees generally cannot determine that salary is lawful and release it contrary to an official restriction.
The legal measure itself normally needs to be addressed.
Prepare a separate account schedule showing each bank, account type, balance, source of funds and relevant transactions.
This can help demonstrate whether the measure is broader than necessary.
If an account is jointly used with a spouse or another person, identify ownership and transaction patterns carefully.
Rights of third parties may also need to be considered.
A foreign company manager may have personal salary accounts as well as access to corporate accounts.
Do not mix the company’s assets with the individual’s property when preparing the defense.
Where another person’s assets are affected, their legal position should be assessed separately.
Evidence establishing ownership of the funds can become particularly important.
If the account freeze is connected with an active criminal investigation, financial explanations may affect the substantive criminal defense.
Banking evidence should therefore be reviewed together with the allegations before the suspect gives a detailed statement.
A foreign suspect who cannot adequately understand Turkish criminal proceedings should ensure that they understand the questions, documents and financial allegations before making statements or signing records.
Financial terminology can be especially difficult to translate accurately.
If a police or prosecutor’s statement inaccurately describes the source of salary or transactions, request correction before signing.
A mistranslated or inaccurate explanation may later be treated as an inconsistency.
The application for release of funds should not contradict the substantive criminal defense.
For example, describing a payment one way in the account-release application and differently during the criminal statement can create avoidable problems.
A strong application may include bank statements, payroll slips, employment agreement, employer confirmation, evidence of social security registration where relevant, lease agreement, utility bills, dependant expenses, documentation concerning legitimate foreign transfers and a clear transaction chronology.
Only documents relevant to the actual case should be submitted.
When a foreign national’s salary account is frozen because of a Turkish criminal investigation, the immediate priorities are to identify the authority and legal basis, obtain the investigation information, preserve the relevant decision, collect complete bank statements, prove the salary source, separate disputed transfers from legitimate income, document essential monthly expenses and submit the appropriate request for complete or partial removal of the restriction.
At the same time, the financial explanation should be coordinated carefully with the person’s criminal defense.
Potentially, where the applicable legal conditions for the relevant protective or financial measure are satisfied. The precise legal basis should always be identified.
No. A temporary investigative restriction and final confiscation are different legal concepts.
Depending on the circumstances and legal basis, it may be possible to request lifting or narrowing of the restriction and raise documented essential living needs. Release is not automatic.
Payroll slips, employment contracts, employer confirmation and recurring bank transfers matching payroll records can be important evidence.
The transactions should be separated through a detailed source-of-funds analysis. The defense should identify legitimate salary amounts independently from disputed transactions.
Normally, a bank cannot simply disregard a binding restriction imposed by the competent authority.
Before changing financial arrangements, the person should determine the scope of the existing measure. Any attempt to circumvent an official restriction can create additional problems.
Potentially. If the factual or legal basis is disputed, counsel can evaluate the appropriate procedure for seeking removal of the measure.
Documented dependant expenses can be included when explaining the practical and proportionality consequences of the restriction.
Identify exactly who imposed the restriction and why. Then obtain complete bank records, document the lawful source of the salary and essential living expenses, and coordinate the request for release with the overall criminal defense before making detailed financial statements to investigators.
A frozen salary account can immediately affect a foreign national’s ability to pay rent, household expenses, family obligations and other essential costs, while explanations concerning the account can also affect the underlying criminal investigation. Fırat Fesih Kaya Law Office assists foreign nationals, foreign company managers and international clients whose bank accounts or other assets are restricted during criminal proceedings in Turkey. Lawyer Fırat Fesih Kaya provides legal assistance in examining the legal basis of account restrictions, preparing requests for release or limitation of the measure, documenting legitimate sources of funds, protecting property rights and coordinating financial evidence with the criminal defense.
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