Foreign Company Funds Frozen in Turkey Due to Fraud Allegations: Emergency Legal Remedies (2026 Updated Guide)

A foreign company’s bank accounts or funds are frozen in Turkey because of fraud allegations. Learn about seizure orders, criminal investigations, company rights, objections, evidence and emergency legal remedies.

When a foreign-owned or international company discovers that its bank accounts or other funds in Turkey have been frozen because of fraud allegations, the consequences can be immediate. Payroll may become impossible, suppliers may remain unpaid, tax and social-security obligations may accumulate, ongoing investments can stop and ordinary business operations may be severely disrupted. The first priority is to determine who ordered the restriction, which criminal investigation it relates to, what funds are covered and whether the measure is a temporary banking restriction, criminal-procedure seizure or another type of legal measure. A company should not treat every bank “freeze” as legally identical.

Why Can a Foreign Company’s Funds Be Frozen in Turkey?

A restriction may arise during an investigation involving alleged fraud, aggravated fraud, misuse of company accounts, suspicious transfers, money laundering allegations, proceeds of crime or another suspected financial offense.

The existence of a restriction does not by itself establish that the company committed an offense.

Find Out Who Ordered the Freeze

The company should immediately determine whether the restriction results from a prosecutor’s investigation, judicial decision, financial-intelligence process, enforcement proceeding or another administrative or judicial mechanism.

The legal remedy depends heavily on the source of the restriction.

Obtain the Investigation Number

Ask the bank for the information it is legally permitted to provide and identify the relevant prosecutor’s office, court and investigation file where possible.

Without identifying the underlying proceeding, challenging the measure effectively can be difficult.

Is the Entire Account Frozen?

Determine whether the restriction affects the complete balance or only a specified amount.

Also check whether it covers one account, all Turkish accounts, foreign-currency balances, incoming transfers or other company assets.

Identify the Alleged Fraud Transaction

A company should determine which transaction triggered the investigation.

Relevant questions include who sent the money, who received it, what contract supported the payment, what goods or services were supplied and whether the disputed funds can be traced to legitimate commercial activity.

Preserve Bank Records Immediately

Obtain account statements, SWIFT records, transfer receipts, payment instructions and internal approval records.

Financial investigations are often highly dependent on the transaction trail.

Preserve the Commercial Contract

If the disputed payment arose from a genuine transaction, preserve the underlying contract, purchase order, invoice, delivery documentation and correspondence.

The company should be able to explain the economic purpose of the payment.

Invoices Alone May Not Be Enough

An invoice demonstrates how a transaction was documented, but investigators may ask whether the underlying transaction genuinely occurred.

Supporting evidence may include delivery records, customs declarations, warehouse records, service reports and correspondence.

Prepare a Transaction Timeline

Create a chronological record showing the contract, invoice, shipment or service, payment request, bank transfer and subsequent events.

A clear timeline can make a complicated cross-border transaction easier to understand.

Distinguish Company Funds From Alleged Criminal Proceeds

One of the central issues may be whether the frozen balance is actually connected with the alleged offense.

The company should identify legitimate operating funds and document their sources.

Trace the Source of Funds

For substantial balances, prepare evidence showing how the money entered the account.

Relevant evidence may include capital contributions, sales revenue, intercompany loans, export income and other legitimate sources.

What If Only One Payment Is Disputed?

Where an investigation concerns one specific transfer but the company’s entire operating balance has been restricted, the scope and proportionality of the measure should be examined carefully.

The company should document the operational consequences of a complete freeze.

Can the Freeze Be Challenged?

Depending on the legal basis of the measure, an objection or request for reconsideration may be available.

The defense should normally address both the legal requirements for the restriction and the factual connection between the frozen assets and the alleged offense.

Obtain the Formal Decision Where Possible

A telephone statement from the bank is not enough to analyze the legal position.

Counsel should seek access to the relevant decision and determine the authority, date, amount, legal basis and scope of the measure.

File Access Can Be Critical

The criminal investigation file may contain the complaint, transaction information, expert findings and other evidence relied upon when the measure was imposed.

Access can be subject to procedural restrictions during an ongoing investigation, so the actual file status should be checked.

Emergency Applications May Be Necessary

If the freeze threatens payroll, tax payments or ongoing operations, urgency should be documented.

The company should explain concretely why maintaining an unnecessarily broad restriction causes serious commercial consequences.

Proportionality Can Be Important

A protective measure should be analyzed in relation to its purpose and factual basis.

If a limited transaction is under investigation, the company may argue—where legally appropriate—that blocking unrelated legitimate funds is excessive.

Can Part of the Money Be Released?

Depending on the legal basis and facts, the company may seek complete or partial removal of the restriction.

A targeted application can identify funds demonstrably unrelated to the alleged offense.

Payroll Problems Should Be Documented

Prepare payroll lists and upcoming salary obligations if employees cannot be paid.

Do not merely state that the company is suffering financial harm; quantify the immediate obligations.

Supplier Payments Can Also Matter

Document critical supplier invoices, lease payments, utilities, logistics expenses and other obligations necessary to maintain business operations.

This evidence can support an argument concerning the practical impact of the restriction.

Tax and Regulatory Payments Should Be Identified

If the freeze prevents legally required payments, preserve documentation showing their amounts and deadlines.

The company should also consider alternative lawful arrangements for meeting obligations while the dispute continues.

Foreign Parent Company Records May Help

Where the Turkish account contains funds transferred by a foreign parent company, preserve board decisions, loan agreements, capital documentation and bank records explaining those transfers.

Intercompany Transfers Require Explanation

Payments between related companies can attract scrutiny if their economic purpose is unclear.

Prepare agreements, accounting records and transfer-pricing documentation where relevant.

Avoid Creating Documents After the Investigation Begins

Companies should not fabricate contracts, invoices or corporate resolutions retrospectively to explain suspicious transfers.

If documentation is missing, address the deficiency transparently.

Directors and Managers May Also Be Investigated

A corporate account freeze can accompany an investigation involving directors, managers, employees or authorized signatories.

The company and individuals should evaluate their positions separately because their interests may not always be identical.

Foreign Directors Should Take Summons Seriously

If a foreign director or manager is requested to give a statement, the person should determine their procedural status and understand the allegations before providing substantive explanations.

Language assistance and legal representation can be particularly important.

The Company Should Conduct an Internal Review

Investigate who approved the disputed transaction, which employee communicated with the counterparty and whether company procedures were followed.

Preserve emails, accounting records and internal messages relevant to the transaction.

Do Not Delete Digital Records

Deleting messages after learning of a criminal investigation can seriously complicate the company’s position.

Implement appropriate preservation measures for relevant corporate records.

Fraud by an Employee Does Not Automatically Mean Corporate Participation

A company may itself have been misused by an employee or third party.

If this occurred, preserve evidence showing the limits of the individual’s authority and the company’s compliance procedures.

Business Email Compromise Should Be Investigated

International companies sometimes transfer money following fraudulent emails or altered payment instructions.

Preserve original emails, headers, payment-change requests and communications with the genuine counterparty.

Fake Invoice Fraud Requires Transaction Reconstruction

If the investigation concerns false invoices, establish whether goods or services were actually supplied and who created or approved the disputed documents.

Third-Party Use of the Company Account Can Create Risk

If company accounts were used to receive or forward money for another person without a clear commercial basis, investigators may scrutinize the transactions closely.

The company should explain the genuine economic rationale where one exists.

Cryptocurrency Connections May Increase Complexity

If disputed funds were transferred to or from cryptocurrency platforms, preserve exchange records, wallet information and transaction histories.

The movement of funds should be reconstructed as completely as possible.

International Transfers Require Cross-Border Evidence

Evidence may be located outside Turkey. Foreign bank statements, contracts, shipping records and corporate records should be collected early.

Where necessary, translations should accurately reflect the original documents.

Customs Records Can Support Legitimate Trade

Where the disputed payment relates to imported or exported goods, customs declarations, transport documents and delivery records can help demonstrate the underlying commercial transaction.

Foreign Court or Investigation Records May Matter

If the same alleged fraud is being investigated abroad, obtain reliable information concerning that proceeding.

Avoid making unsupported representations about foreign proceedings.

Can the Company Recover Damages Caused by the Freeze?

Potential compensation depends on the legal basis of the measure, how the investigation develops and the requirements applicable to compensation claims.

A company should therefore preserve evidence of its losses from the beginning without assuming that every loss will automatically be recoverable.

Document Business Interruption Losses

Maintain evidence of cancelled contracts, delayed projects, financing costs, penalties, payroll problems and supplier claims.

Causation between the freeze and each claimed loss should be documented.

Reputation Damage Should Be Managed Carefully

Banks, suppliers and business partners may become concerned after learning that accounts are restricted.

Communications should remain accurate and should not interfere with the criminal investigation.

Do Not Move Assets to Evade the Investigation

Attempts to conceal or rapidly transfer assets after learning of an investigation can create additional legal risks.

Any financial restructuring should have a legitimate commercial basis and comply with applicable restrictions.

Review Other Turkish Bank Accounts

Determine whether restrictions exist at other banks or whether they may be affected by the same investigation.

This allows the company to understand its total exposure.

Review Personal Accounts of Managers Separately

A company account restriction does not automatically mean that managers’ personal assets are subject to the same measure.

Any personal restrictions should be examined under their own legal basis.

What If the Company Is Actually the Fraud Victim?

The company may have transferred money because it was deceived or may have received funds without knowing their criminal origin.

Its procedural strategy should reflect the actual facts, including whether the company should assert victim status or seek recovery from responsible persons.

Criminal Complaint by a Customer Does Not Automatically Prove Fraud

Commercial disputes sometimes lead to criminal complaints.

The existence of unpaid invoices, contractual disagreement or failed performance should be distinguished carefully from evidence establishing fraudulent conduct.

Commercial Dispute or Criminal Fraud?

One important defense issue can be whether the dispute concerns an ordinary contractual failure or alleged deception existing from the beginning.

Contracts, negotiations, performance history and communications can be critical.

Prepare an Emergency Defense File

The company’s counsel should organize the relevant judicial decision, bank records, disputed transactions, contracts, invoices, customs records, delivery evidence, corporate approvals, accounting entries, source-of-funds documents and operational-loss evidence.

A structured file allows urgent applications to be made efficiently.

Frequently Asked Questions

Can a foreign company’s Turkish bank account be frozen during a fraud investigation?

Potentially, where the applicable criminal-procedure or other legal requirements for the particular measure are satisfied.

Does an account freeze mean the company is guilty?

No. A protective restriction during an investigation is not itself a criminal conviction.

Can the company challenge the freeze?

Potentially. The available objection or release procedure depends on the legal basis and authority responsible for the measure.

Can only part of the account be released?

Depending on the circumstances, a request may potentially seek partial release by demonstrating that particular funds are unrelated to the alleged offense or by challenging the scope of the restriction.

What documents are most important?

Bank statements, transaction records, contracts, invoices, delivery evidence, customs documents, accounting records and source-of-funds evidence can be particularly important.

Can payroll obligations support an urgent application?

They may be relevant when demonstrating the practical impact and proportionality of the restriction. Payroll and other obligations should be documented precisely.

Can company directors also become suspects?

Potentially, depending on their role, knowledge and involvement in the alleged transactions. Individual criminal responsibility requires separate examination.

What if the company received suspicious money without knowing its origin?

The company should reconstruct the transaction and preserve evidence concerning the commercial reason for receiving the funds and the knowledge of relevant personnel.

Can the company claim compensation later?

Potentially, depending on the legal basis, outcome of the proceedings and applicable compensation requirements. Financial losses should therefore be documented from the beginning.

What should the company do first?

Identify the authority and investigation behind the freeze, obtain the underlying decision where possible, trace the disputed funds and immediately prepare documentary evidence showing the legitimate commercial source and purpose of the company’s money.

Client-Focused Legal Support for Frozen Company Funds in Turkey

A fraud investigation involving corporate funds can rapidly become a business emergency involving bank-account restrictions, seizure measures, criminal allegations, director liability, payroll disruption and substantial commercial losses. Fırat Fesih Kaya Law Office assists foreign companies, international investors and foreign executives facing financial restrictions and criminal investigations in Turkey. Lawyer Fırat Fesih Kaya provides legal assistance in identifying the underlying investigation, reviewing seizure and freezing measures, preparing objections and release applications, coordinating financial evidence and representing foreign companies and executives during criminal proceedings.

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