Foreigner Receives Money and Transfers It to Another Account in Turkey: When Can This Become Money Laundering? (2026 Updated Guide)

When can receiving and transferring money through a Turkish bank account become money laundering? Learn the criminal risks for foreigners, MASAK issues, bank freezes and defense strategies in Turkey.

A foreign national who receives money into a Turkish bank account and then transfers it to another account may face serious questions if authorities suspect that the funds originate from a criminal offence. However, receiving money and transferring it onward does not automatically constitute money laundering. The legal assessment depends on the source of the funds, the person’s knowledge, the purpose and circumstances of the transfer, the relationship between the parties and whether the transaction forms part of conduct intended to conceal or legitimize criminal proceeds.

For foreigners, the situation can become particularly serious because a suspicious banking transaction may trigger not only a criminal investigation but also bank account restrictions, MASAK-related reporting, seizure measures, immigration consequences and difficulties with future banking transactions in Turkey.

The most important issue is therefore not simply:

“Did the foreigner transfer the money?”

The more important questions are:

Where did the money come from?

Why was it transferred?

What did the foreigner know?

Who instructed the transfer?

What evidence exists showing the legitimate purpose of the transaction?

What Is Money Laundering Under Turkish Criminal Law?

The principal provision is Article 282 of the Turkish Criminal Code, which concerns laundering assets arising from an offence.

The basic concept is that criminal proceeds may be subjected to transactions designed to conceal their unlawful origin or make them appear legitimate. The exact statutory elements must be assessed according to the conduct alleged in the particular investigation.

Therefore, a banking transaction involving suspicious money should not automatically be treated as proof of laundering.

Receiving Money Does Not Automatically Mean Money Laundering

A foreigner may legitimately receive money for many reasons:

• Salary;
• Consultancy payment;
• Property sale;
• Loan;
• Family support;
• Business transaction;
• Investment;
• Refund;
• Sale of goods;
• Payment under a commercial contract.

The existence of a transfer alone does not establish criminal liability.

The Source of the Money Is Critical

The investigation should establish whether the money actually constitutes proceeds of an underlying offence.

For example, authorities may investigate whether funds originate from:

• Fraud;
• Theft;
• Drug trafficking;
• Smuggling;
• Cybercrime;
• Corruption;
• Unlawful gambling;
• Tax-related offences where relevant to the underlying criminal conduct;
• Other predicate offences.

The alleged underlying offence should therefore be identified.

What If the Foreigner Did Not Commit the Original Crime?

A foreigner can still become the subject of a laundering investigation even if they did not commit the underlying offence.

The key issue becomes what the person knew and what they did with the proceeds.

This is why the person’s role in the transaction must be reconstructed carefully.

Knowledge Can Become a Central Issue

Suppose a foreign national receives money from an acquaintance and transfers it to another account after receiving instructions.

The investigation may ask:

Did the person know the money came from crime?

Did they know why it was being transferred?

Did they receive a commission?

Did they conceal the transaction?

Were there warnings or suspicious circumstances?

The answers can materially affect the legal assessment.

What If the Foreigner Was Asked to “Just Forward the Money”?

This situation deserves particular caution.

A person may be told:

“The money will come into your account. Just send it to this other account.”

That instruction does not automatically establish criminal liability.

However, if the transaction is connected with criminal proceeds and the person knowingly participates in moving or concealing those proceeds, the risk becomes substantially more serious.

What If the Foreigner Received a Commission?

A commission can attract additional attention.

Investigators may ask why the person was paid to receive and transfer funds and whether the commission indicates knowledge or participation in a broader scheme.

The amount and explanation for the payment should therefore be documented.

What If the Transfer Was Requested by a Friend?

Personal relationships do not automatically eliminate criminal risk.

At the same time, a friend or family relationship does not automatically prove knowledge of a criminal source.

The complete communication history should be examined.

WhatsApp Messages Can Become Important Evidence

Preserve messages concerning:

• Why the money was sent;
• Who requested the transfer;
• What the recipient was told;
• Why a particular account was used;
• Where the money was supposed to go;
• Whether a fee was offered;
• Whether the sender described the purpose.

Deleting messages after learning about an investigation can create additional evidentiary problems.

Bank Records Can Reconstruct the Transaction

Investigators may examine:

• Incoming transfer;
• Sending account;
• Receiving account;
• Time between transactions;
• Amounts;
• Multiple transfers;
• Cash withdrawals;
• International transfers;
• Account holders;
• Payment descriptions.

The complete transaction history may be more informative than a single transfer.

Rapid “Pass-Through” Transactions Can Attract Attention

A foreigner’s account may receive money and transfer substantially the same amount shortly afterward.

That pattern does not itself prove money laundering.

However, investigators may ask why the account was used as an intermediary and whether the account holder understood the purpose.

Multiple Transfers Can Increase Suspicion

Repeated transfers involving unrelated people, companies or accounts may attract greater scrutiny.

The foreigner should be able to explain the commercial or personal reason for the transaction pattern.

International Transfers Require Additional Attention

Funds moving:

Foreign country → Turkish account → another Turkish account → foreign country

may generate questions concerning the ultimate beneficiary and purpose.

This does not automatically mean the transaction is unlawful.

The underlying transaction should be documented.

What If the Foreigner Was Paid for a Genuine Service?

Suppose a foreign consultant legitimately receives USD 20,000 from a Turkish company and later transfers part of the money to a subcontractor.

That may be an ordinary commercial transaction.

Contracts, invoices, service records, tax documents and correspondence can help demonstrate the legitimate purpose.

What If There Is No Written Contract?

The absence of a written contract does not automatically prove criminal conduct.

However, it can make it more difficult to establish the legitimate economic purpose of a significant transfer.

Alternative evidence should therefore be collected.

What If the Money Was a Personal Loan?

A genuine loan can be legitimate.

Evidence may include:

• Loan agreement;
• Messages;
• Repayment schedule;
• Bank records;
• Financial relationship between the parties.

A verbal explanation made only after an investigation begins may receive greater scrutiny than contemporaneous documentation.

What If the Money Came From a Property Transaction?

Property transactions can involve substantial transfers.

The foreigner should preserve:

• Sale agreement;
• Title records;
• Payment instructions;
• Bank records;
• Valuation documents;
• Identity of buyer and seller;
• Commission agreement where applicable.

What If the Foreigner Is a Company Employee?

An employee may have transferred company funds under instructions from a manager or finance department.

The employee’s authority, job duties and knowledge can become important.

The fact that the employee’s account was used does not automatically establish personal criminal responsibility.

What If the Foreigner Was Acting as an Agent?

An agent should preserve the agency agreement and instructions received from the principal.

Investigators may examine whether the agent knew the transaction was unlawful.

What If the Foreigner’s Account Was Used Without Permission?

Identity theft, unauthorized banking access or account compromise can completely change the legal analysis.

Immediately preserve:

• Login alerts;
• Bank notifications;
• Device records;
• Password-change history;
• Police reports;
• Communications with the bank.

What If the Foreigner Gave Their Bank Account Details to Someone?

Providing an IBAN is not automatically criminal.

However, knowingly allowing another person to use the account for suspicious transactions can create serious legal exposure.

A person should never rent, sell or lend their bank account to another person.

MASAK-Related Issues Can Arise

Banks and financial institutions in Turkey have obligations concerning suspicious transactions and financial crime risks.

A suspicious transaction report or compliance review does not itself mean that the customer has been convicted of a crime.

It may, however, trigger additional scrutiny.

Bank Account Restrictions Can Become a Practical Problem

A bank may restrict transactions or request supporting documents where it identifies compliance concerns.

The foreigner should determine:

• What transaction is being questioned;
• What documents the bank requires;
• Whether the account is temporarily restricted;
• Whether there is a formal seizure or another legal measure.

A bank compliance restriction and a judicial seizure are not necessarily the same thing.

A Bank Freeze Does Not Automatically Prove Guilt

The existence of an account restriction should not be presented as proof that the customer committed money laundering.

The legal basis and nature of the restriction should be identified first.

What If Turkish Police Contact the Foreigner?

Do not ignore an official summons or investigative contact.

The foreigner should determine whether they are being called as:

• Suspect;
• Witness;
• Victim;
• Information provider.

The procedural rights can differ.

A Foreigner Has the Right to Understand the Proceedings

Where the suspect does not sufficiently understand Turkish, appropriate interpretation and procedural safeguards become particularly important.

The person should not sign a statement they do not understand.

Do Not Guess During a Police Statement

If the foreigner does not remember why a transfer occurred, they should not invent an explanation.

It is better to state accurately what they remember and distinguish known facts from assumptions.

Obtain Legal Assistance Before Giving a Detailed Statement

A foreign suspect should consider obtaining a criminal defense lawyer before answering detailed questions concerning suspicious banking transactions.

This is particularly important where the investigation concerns Article 282 or another serious offence.

Preserve the Full Banking History

Do not provide only the single transfer that appears favorable.

The surrounding transactions may explain the legitimate purpose of the disputed payment.

The complete account history can sometimes be essential to understanding the transaction.

Build a Transaction Timeline

For example:

10 March: Company signs consultancy agreement.

15 March: USD 30,000 transferred.

16 March: USD 20,000 transferred to subcontractor.

17 March: Invoice issued.

20 March: Service delivered.

A chronological record can make the economic purpose easier to understand.

Identify the Ultimate Beneficiary

Ask who ultimately received the funds.

A transaction may look suspicious when viewed only as:

Account A → Account B

but become understandable when the full commercial chain is shown.

Explain Why the Foreign Account Was Used

If there was a legitimate reason for using a particular Turkish account, document it.

For example:

• Turkish project expenses;
• Local supplier payments;
• Employment expenses;
• Property acquisition;
• Investment activity.

Do Not Create Documents After the Investigation Begins

Do not fabricate contracts, invoices or payment explanations to make an old transaction appear legitimate.

Authentic contemporaneous evidence is much safer.

Preserve Original Digital Evidence

Keep original:

• Emails;
• WhatsApp conversations;
• Bank statements;
• Invoices;
• Contracts;
• Accounting records;
• Transfer instructions.

Do not alter screenshots or selectively delete messages.

What If the Money Was Already Transferred Again?

The fact that funds have already left the account does not necessarily end the investigation.

Authorities can investigate the complete transaction chain.

The foreigner should therefore preserve evidence showing why the onward transfer occurred.

What If the Foreign Company Ordered the Transfer?

The company’s internal authorization system may become important.

Preserve:

• Board resolutions;
• Payment instructions;
• Internal emails;
• Accounting records;
• Employee authority documents.

What If the Transfer Was a Mistake?

If the money was received accidentally and immediately returned, preserve evidence of:

• The mistaken transfer;
• Notification to the sender;
• Bank correspondence;
• Return transaction.

The circumstances and knowledge at the time remain important.

What If the Foreigner Was Deceived Too?

A person who unknowingly received criminal proceeds may themselves be a victim or witness rather than a participant.

Evidence showing how the person was deceived can therefore be critical.

What If the Foreigner Received Money From a Cryptocurrency Transaction?

Crypto-related transfers can receive heightened scrutiny because transaction chains may involve multiple wallets, exchanges and jurisdictions.

Preserve:

• Wallet addresses;
• Transaction hashes;
• Exchange records;
• Purchase agreements;
• Communications;
• Source-of-funds evidence.

What If the Foreigner Received Money From a High-Return Investment?

This can create significant risk if the investment was actually part of a fraudulent scheme.

The person should preserve evidence showing:

• Who contacted them;
• What they were promised;
• Why they received the funds;
• Whether they knew the source;
• Whether they were paid for recruiting others.

What If the Foreign Account Was Used by a Fraud Network?

Investigators may examine whether the account holder was a participant, an unwitting intermediary or another victim.

The defense should focus on the person’s actual knowledge and role rather than merely the existence of the account transaction.

What If the Foreign National Lives Outside Turkey?

Jurisdictional and procedural issues may become more complicated when the person resides abroad.

However, leaving Turkey does not automatically eliminate an investigation or possible procedural obligations.

Legal advice should be obtained before deciding whether to travel to Turkey.

Immigration Consequences Should Also Be Considered

For a foreign national, a criminal investigation can have consequences beyond the banking issue.

Depending on the allegations and procedural outcome, residence status, entry restrictions, deportation-related measures or other immigration consequences may need separate assessment.

A criminal defense strategy should therefore consider immigration consequences where relevant.

Criminal Investigation and Civil Recovery Are Different

If the foreigner was actually defrauded into receiving or transferring funds, the person may have separate rights against the individuals who deceived them.

Do not assume that participation in an investigation automatically resolves the underlying financial dispute.

What Should a Foreigner Do Immediately?

The first steps should be:

1. Stop unexplained transfers.
2. Preserve complete bank records.
3. Preserve all communications.
4. Identify the source and ultimate destination of the money.
5. Gather contracts and invoices.
6. Determine whether the account was used under someone else’s instructions.
7. Identify the legal status of the investigation.
8. Obtain appropriate legal assistance.
9. Do not delete or alter evidence.
10. Do not create documents retroactively.
11. Do not make speculative statements to investigators.
12. Assess possible immigration consequences.

Can the Foreigner Challenge a Money-Laundering Allegation?

Yes, where the factual and legal elements alleged by the prosecution are not established.

A defense may focus on issues such as:

• Legitimate source of funds;
• Lack of knowledge;
• Absence of intent or required mental element;
• Genuine commercial purpose;
• Lack of connection to the predicate offence;
• Unauthorized use of the account;
• Misidentification;
• Incomplete transaction analysis;
• Reliable documentary evidence.

The precise defense depends on the allegation and evidence.

The Best Defense Is Usually Transaction-Specific

A general statement such as:

“I did not know it was illegal.”

may be insufficient by itself.

A stronger defense can reconstruct the transaction:

Who sent the money → why it was sent → what the foreigner understood → why it was transferred → who ultimately received it → what documents confirm the explanation.

Frequently Asked Questions

Does receiving money into a Turkish bank account automatically mean money laundering?

No. The source of the money, the person’s knowledge, the purpose of the transaction and the conduct surrounding the transfer must be examined.

Can a foreigner be investigated for money laundering without committing the underlying crime?

Yes. The investigation may concern whether the person knowingly participated in handling criminal proceeds even if someone else committed the underlying offence.

Is transferring money to another account illegal?

Not by itself. Legitimate transfers are ordinary banking activity. The legal risk depends on the source, purpose and circumstances.

What if someone told me to transfer the money?

The instruction itself does not establish criminal liability. Investigators may nevertheless examine who gave the instruction and what the account holder knew about the transaction.

Can WhatsApp messages help the defense?

Yes. Messages can help establish the purpose of the payment, instructions received, the person’s understanding and communications with the sender or beneficiary.

What if my Turkish bank account is frozen?

First determine whether the restriction is an internal bank compliance measure, a formal administrative action or a judicial seizure. The appropriate response depends on the legal basis.

Can a foreigner be arrested for transferring suspicious money?

Potentially, depending on the allegations, evidence and procedural circumstances. A suspicious transfer alone does not automatically require arrest.

What if I received criminal proceeds without knowing their source?

Lack of knowledge can be highly important, but the complete circumstances must be examined, including whether there were facts that allegedly should have alerted the person to the unlawful source.

Can immigration consequences arise?

Potentially. Criminal allegations involving a foreign national can have separate immigration implications depending on the offence, procedural stage and eventual outcome.

What should I do before speaking to Turkish police?

Determine your procedural status, obtain appropriate legal assistance where necessary, ensure you understand the proceedings and avoid signing a statement that you do not understand.

Client-Focused Legal Support for Foreigners Facing Money-Laundering Investigations in Turkey

A foreign national who receives and transfers money through a Turkish bank account may face criminal investigation, bank restrictions, asset-seizure measures and immigration-related consequences if authorities suspect that the funds are connected with criminal proceeds. Fırat Fesih Kaya Law Office assists foreign nationals, investors, employees, company managers and business owners facing financial-crime investigations in Turkey.

Lawyer Fırat Fesih Kaya provides legal assistance in reviewing suspicious banking transactions, preparing criminal defenses, analyzing MASAK-related issues, challenging unlawful seizure or account restrictions, preserving digital and financial evidence and coordinating criminal and immigration strategies for foreign clients.

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