Is your Turkish bank account frozen because of a criminal investigation? Learn why prosecutors and courts freeze bank accounts, how foreigners can challenge asset seizure, prove the lawful source of funds and request release of frozen money in Turkey.

Discovering that a bank account in Turkey has suddenly been frozen can create an immediate crisis for a foreign national or foreign business. The account holder may be unable to withdraw money, make international transfers, pay employees, complete an investment transaction or access funds needed for ordinary living expenses.

A bank may tell the customer that the restriction results from a criminal investigation, prosecutor’s office, court order or asset-seizure decision. In more complicated cases, the investigation may concern allegations involving fraud, money laundering, financial offences, company transactions or alleged criminal proceeds.

The first point to understand is that a frozen bank account does not mean that the account holder has been convicted of a crime. Asset seizure during a criminal investigation is generally a protective measure intended to preserve assets while authorities investigate whether they are connected to alleged criminal activity.

Under Article 128 of the criminal procedure framework, bank and other financial institution accounts are among the assets that may be seized where the statutory conditions are satisfied. The provision requires strong suspicion based on concrete evidence both concerning commission of an offence within its scope and the proposition that the identified assets were obtained from that offence. (Kararlar Bilgi Bankası)

For a foreign account holder, the appropriate response is usually to determine immediately who ordered the restriction, under which legal provision, which investigation it relates to, whether the entire account or only specified funds are affected, and what evidence allegedly connects the money to criminal activity.

Why Can a Bank Account Be Frozen During a Criminal Investigation?

A criminal asset restriction is intended to prevent relevant property from being transferred, concealed or dissipated before authorities can determine its legal status.

Article 128 specifically includes accounts held at banks and other financial institutions among the categories of property potentially subject to seizure. (Kararlar Bilgi Bankası)

The measure can arise in investigations involving financial transactions where prosecutors believe particular assets may represent proceeds derived from criminal conduct.

However, the existence of a criminal investigation alone should not be treated as an unlimited justification for freezing every asset belonging to a suspect.

The statutory requirements and connection between the property and alleged offence matter.

Does a Frozen Account Mean the Money Has Been Confiscated?

No.

This distinction is extremely important.

Seizure or freezing is a protective criminal-procedure measure. Confiscation concerns permanent deprivation of property under the applicable substantive and procedural requirements.

A foreigner whose account is frozen has therefore not automatically lost ownership of the funds.

The investigation may ultimately establish that the money is lawful, that the account has no sufficient connection to the alleged offence or that continued seizure is unnecessary.

Can Foreigners Have Their Turkish Bank Accounts Frozen?

Yes.

Foreign nationality does not prevent Turkish criminal authorities from imposing legally authorized measures on assets within the Turkish financial system.

A foreign tourist, resident, investor, shareholder, company director or business owner may therefore become subject to an account restriction.

The Constitutional Court has previously considered criminal asset seizures involving individuals living abroad, confirming that property measures can affect assets located in Turkey even when the individual resides in another country. (Anayasa Mahkemesi)

Foreign status, however, does not eliminate procedural rights or property-right protections.

What Is the Legal Basis for Freezing Bank Accounts?

Article 128 of the criminal procedure framework regulates seizure of real estate, rights and receivables and expressly covers:

bank and financial institution accounts,

rights and receivables,

securities,

company shares,

safe-deposit-box contents,

and other property interests.

The Constitutional Court’s published decisions reproduce these categories when examining asset-seizure disputes. (Kararlar Bilgi Bankası)

This means that an investigation can potentially affect considerably more than the balance of a current account.

What Conditions Are Required Under Article 128?

The measure is not intended to operate merely because someone has been accused of wrongdoing.

Article 128 refers to strong suspicion based on concrete evidence concerning both the relevant criminal conduct and the proposition that the specified assets were obtained from the offence. (Kararlar Bilgi Bankası)

Ministry of Justice materials also explain that the framework includes a reporting mechanism involving the competent financial or regulatory authority concerning the value allegedly obtained from the offence. (Rayp Adalet)

These requirements can become central to an objection.

The defense should ask: What is the alleged offence, and what evidence connects this particular money to that offence?

Who Can Order the Seizure of a Bank Account?

For the asset categories governed by Article 128, current Ministry of Justice training materials state that seizure of real estate, rights and receivables requires a unanimous decision of the competent serious criminal court. (Rayp Adalet)

The precise legal basis should nevertheless always be checked.

Not every bank restriction originates from Article 128. A bank account can be affected by other criminal, regulatory, tax, enforcement or compliance mechanisms.

This is why the first question should not simply be “How do I unfreeze my account?”

It should be:

“What exactly is the legal basis for this restriction?”

How Is the Bank Freeze Implemented?

Under the Article 128 framework, a decision concerning an account at a bank or other financial institution is communicated immediately to the relevant institution through technical means and is subsequently formally served. Ministry of Justice materials also state that transactions intended to defeat the seizure after the decision has been made are invalid. (Rayp Adalet)

The bank itself may therefore have little discretion once it receives a binding seizure decision.

Arguing with branch employees will generally not resolve a judicial asset restriction.

The underlying decision must be addressed.

Why Does the Bank Sometimes Refuse to Explain the Reason?

Bank employees may only have limited information about the underlying criminal investigation.

They may be able to confirm that a restriction exists but may not be able to explain the evidence, alleged offence or prosecutor’s reasoning.

Defense counsel may therefore need to identify the investigation file and obtain information from the competent judicial authorities to the extent procedurally permitted.

First Step: Identify the Type of Freeze

Not every frozen account involves the same legal mechanism.

Before filing an objection, determine whether the restriction arises from:

a criminal asset-seizure decision,

another judicial measure,

an enforcement proceeding,

a tax-related restriction,

or another legally authorized process.

Using the wrong remedy can waste valuable time.

Second Step: Identify the Criminal Investigation

If the restriction arises from a criminal investigation, determine the relevant prosecutor’s investigation and the alleged offence.

Foreigners sometimes learn about an investigation for the first time when their Turkish bank account stops working.

This can happen where the person lives abroad and has not yet received or understood previous communications concerning the investigation.

Counsel should establish the procedural status before deciding how to respond.

Third Step: Obtain the Asset-Seizure Decision

The defense needs to understand what the competent authority actually ordered.

Important questions include whether the decision identifies the relevant accounts, whether it applies to all assets or specified assets, what alleged offence forms the basis of the measure and what reasoning connects the property to the investigation.

An objection prepared without understanding the underlying decision is significantly weaker.

Fourth Step: Determine Whether All Accounts Are Frozen

A foreigner may hold several accounts at one or more Turkish banks.

The measure may affect one account, several accounts or broader financial interests depending on its terms.

The account holder should document exactly what is inaccessible.

This includes current accounts, foreign-currency accounts, investment accounts and other affected financial assets.

Fifth Step: Trace the Source of the Money

This is often the most important part of the defense.

If the prosecution alleges that the frozen money represents criminal proceeds, the account holder should establish its lawful source.

Useful evidence can include employment income records, company distributions, legitimate investment proceeds, property-sale documentation, inheritance records, banking records from another country, invoices, loan agreements and corporate accounting documents.

The goal is to create a traceable financial history.

Foreign Bank Records Can Be Critical

Suppose a foreign investor transferred EUR 500,000 into Turkey.

If prosecutors later question the source, the defense should ideally be able to show where the money originated before it entered Turkey.

The evidentiary chain may include the foreign account statement, transaction records, underlying sale or investment agreement, corporate documentation and Turkish receiving-account records.

A clear money trail can be substantially more persuasive than a simple statement that the funds are legitimate.

What If the Money Came From Selling Property Abroad?

Document the transaction.

The defense may use the property-sale agreement, ownership records, payment evidence and bank transfer documentation to establish the source.

Where documents originate abroad, procedural requirements concerning translation, authentication or use before Turkish authorities may also need to be considered.

What If the Money Came From a Foreign Company?

The corporate relationship should be documented.

Authorities may need to understand why the company transferred money to the individual.

Was it salary?

A dividend?

Loan repayment?

Reimbursement?

Share-sale proceeds?

An investment?

A shareholder loan?

The legal characterization should correspond with the underlying corporate and banking records.

What If the Frozen Account Belongs to a Company?

Company accounts require separate analysis.

An investigation concerning a shareholder or director does not automatically mean every company asset represents criminal proceeds.

The company may need to establish independent ownership and the commercial source of the funds.

Corporate accounting records, invoices, contracts, payroll information, tax documentation and banking records can become particularly important.

What If Legitimate and Allegedly Suspicious Funds Are Mixed?

This can make the case considerably more complicated.

Suppose a business account contains substantial ordinary trading income but prosecutors challenge one particular transfer.

The defense should reconstruct the account history and determine whether legitimate funds can be separated from the allegedly suspicious amount.

A blanket restriction affecting substantially more property than necessary can raise proportionality concerns.

Can an Entire Account Be Frozen Because of One Transaction?

Whether that is lawful and proportionate depends on the circumstances and legal basis of the measure.

The defense should identify the amount allegedly connected to the offence and compare it with the total restricted assets.

If a questionable transaction concerns a limited amount while a much larger pool of independently documented legitimate assets is frozen, that distinction should be raised.

Can Money Deposited Before the Alleged Crime Be Important?

Yes.

Timing can be extremely persuasive.

If the prosecution alleges that money was generated by conduct occurring in 2025 but bank records demonstrate that the relevant funds had already been in the account since 2022, that chronology may undermine the alleged connection.

Financial investigations are often resolved through transaction history rather than general explanations.

Can Salary Income Be Released?

Potentially, depending on the scope and legal basis of the restriction.

Where an account contains clearly identifiable salary or other lawful income unrelated to the alleged offence, counsel can assess whether this supports full or partial lifting of the measure.

The application should document the source rather than relying solely on hardship.

Can the Freeze Be Partially Lifted?

A request does not necessarily have to be framed as all or nothing.

Depending on the case, counsel may argue that the entire restriction should be removed or, alternatively, that it should be narrowed to the amount genuinely connected to the investigation.

This can be particularly important for companies needing to pay employees, taxes and ordinary operating expenses.

Can You Challenge a Bank Account Seizure?

Yes.

Ministry of Justice materials expressly state that seizure of real estate, rights and receivables under Article 128 can be challenged through the general objection procedure. (Rayp Adalet)

An effective objection should normally address the specific statutory and factual weaknesses of the measure rather than merely asserting that the account holder needs access to the money.

What Arguments Can Be Used in an Objection?

Depending on the facts, relevant arguments may concern lack of sufficient evidence connecting the assets to the alleged offence, lawful origin of the money, disproportionate scope of the restriction, third-party ownership, excessive duration or changes in circumstances that make continued seizure unnecessary.

The strongest objection is usually supported by documentary evidence.

Can the Account Holder Request Release During the Investigation?

Potentially.

There is no reason to assume that a person must wait until the final criminal judgment before raising the continuing necessity of an asset restriction.

Protective measures must remain legally justified while they continue.

The Constitutional Court emphasizes that interference with property rights must maintain a fair balance between the public interest and the burden imposed on the individual. (Anayasa Mahkemesi)

Does the Prosecutor Have to Prove the Foreigner Is Guilty First?

No conviction is required merely to impose an interim protective measure.

That is precisely why such measures can operate during an investigation.

But the absence of a conviction does not mean that authorities have unlimited discretion.

The statutory evidentiary threshold for the particular measure must still be satisfied.

What Is the Role of Financial Intelligence Reports?

Financial analysis can become particularly important in Article 128 investigations.

Ministry of Justice materials explain that, depending on the case, a report concerning the alleged criminally derived value is obtained from the relevant authority, including the Financial Crimes Investigation Board or another listed financial or regulatory institution. The materials state that the report is generally to be prepared within three months, with a possible two-month extension where special circumstances require it. (Rayp Adalet)

The contents and significance of the relevant financial analysis can therefore become central to the defense.

Does a Financial Intelligence Review Automatically Mean Money Laundering?

No.

Financial intelligence and criminal liability are not the same thing.

Suspicious transactions can trigger scrutiny for many reasons.

The criminal case must still be evaluated according to the elements of the alleged offence and the evidence.

A foreigner should therefore avoid assuming that financial scrutiny itself amounts to proof of criminal conduct.

What If the Foreigner Is Not a Suspect?

This can create an important third-party property issue.

Money may be held in an account connected to a transaction involving another suspect, or authorities may allege that assets were transferred to another person.

The Constitutional Court’s property-rights case law emphasizes the importance of the relationship between the owner’s conduct, the alleged illegality and the property affected. It also recognizes the importance of allowing good-faith owners to recover property or obtain appropriate redress. (Anayasa Mahkemesi)

A genuine third-party owner should therefore document independence from the alleged offence carefully.

What If the Account Belongs to a Spouse?

Marriage alone does not automatically answer the ownership or criminal-origin question.

The source of the funds and the circumstances of transfer must be examined.

If the spouse independently earned the money or owned it before the alleged criminal conduct, supporting banking and financial documentation may become highly important.

What If the Foreigner Lives Outside Turkey?

Living abroad does not prevent a restriction from affecting assets held in Turkey.

The Constitutional Court has previously considered a case involving an individual resident abroad whose assets in Turkey were seized during a criminal investigation. (Anayasa Mahkemesi)

A foreign resident should not ignore the matter merely because they are outside Turkey.

The investigation and asset restriction may continue.

Does the Foreigner Have to Travel to Turkey to Challenge the Freeze?

Not necessarily in every case.

Depending on the procedural situation and authorization, counsel may be able to make applications concerning the seizure while the client remains abroad.

However, the investigation may separately require the person’s statement or appearance.

The account issue and the suspect’s procedural obligations should therefore be considered together.

Can a Bank Freeze Affect Immigration or Travel?

The bank restriction itself is not automatically an international travel prohibition.

Criminal investigations can, however, involve separate judicial-control measures affecting travel.

A foreigner should therefore determine whether the file contains only a financial restriction or also an arrest warrant, judicial-control decision or international travel restriction.

Can Authorities Freeze Cryptocurrency or Other Assets?

Criminal investigations are increasingly broader than ordinary bank accounts.

Depending on the applicable legal mechanism and facts, investigators may pursue other property interests believed to be connected to criminal activity.

The defense should therefore conduct a complete asset review rather than focusing solely on one bank account if the investigation is financial in nature.

Can the Freeze Continue for Years?

Duration matters.

An initially lawful protective measure can become increasingly burdensome if it continues without adequate reassessment.

In 2025, the Constitutional Court again emphasized in property-related proceedings that prolonged restrictions require an appropriate balance between the public objective and the burden placed on the property owner. (Kararlar Bilgi Bankası)

The Court’s broader property-rights jurisprudence similarly stresses that seizure measures must not be arbitrary or disproportionate. (Anayasa Mahkemesi)

This does not create a universal maximum duration for every frozen bank account. It means that continued necessity and proportionality matter throughout the life of the measure.

What If Authorities Never Review Whether the Freeze Is Still Necessary?

Counsel should consider making a formal request for review or lifting of the restriction and use the available objection mechanisms.

Passively waiting can be particularly damaging where the account contains substantial legitimate funds.

Documenting repeated attempts to obtain review can also become important if the restriction later raises broader property-rights issues.

Can a Foreign Company Claim That the Freeze Threatens Its Business?

Yes, the practical consequences can be explained.

A frozen operating account can prevent payment of salaries, suppliers, taxes and contractual obligations.

However, commercial hardship alone may not defeat a properly justified criminal asset measure.

The stronger argument combines hardship with legal issues such as lack of connection between legitimate corporate funds and the alleged offence or excessive breadth of the restriction.

Can You Open Another Bank Account to Avoid the Freeze?

A person should not attempt to defeat or circumvent a lawful asset-seizure decision.

Ministry of Justice materials state that transactions designed to render an Article 128 seizure ineffective after the decision has been issued are invalid. (Rayp Adalet)

Attempts to conceal or transfer assets after learning about an investigation can also seriously damage the defense.

The restriction should be challenged through lawful procedures.

Should You Transfer Money Before Authorities Freeze Other Accounts?

Do not attempt to conceal or dissipate assets to frustrate an anticipated judicial measure.

Such conduct can create additional evidentiary and legal problems.

Instead, preserve financial records and obtain advice concerning the investigation.

What Should You Not Do After Discovering the Freeze?

Do not destroy bank records, fabricate contracts, create backdated loan agreements or ask another person to falsely claim ownership of the money.

Do not pressure witnesses or business partners to change explanations concerning transactions.

Financial investigations depend heavily on objective records, and attempts to manufacture an explanation can create much greater problems than the original disputed transaction.

What Evidence Should You Collect Immediately?

The most useful evidence usually establishes the complete financial history of the funds. Relevant material may include bank statements, transfer confirmations, contracts, invoices, company accounts, tax documents, payroll records, investment agreements, property-sale records, inheritance documents and foreign banking records.

The documents should tell a coherent story.

Where possible, the trail should show where the money originated, why it was transferred and why the account holder was legally entitled to receive it.

A Practical Example

Assume a foreign investor has EUR 800,000 frozen in a Turkish account during an investigation concerning a disputed EUR 150,000 business transaction.

The defense discovers that EUR 650,000 came from the documented sale of property abroad before the disputed transaction occurred.

The remaining EUR 150,000 came from the business transaction under investigation.

That factual separation could become highly significant.

Instead of arguing generically that all EUR 800,000 should be released, the defense can present a transaction-based analysis demonstrating why the majority of the account has an independently documented lawful origin.

Ten Steps Foreigners Should Take After a Bank Account Is Frozen

1. Confirm which accounts and funds are restricted.
2. Identify the legal basis for the restriction.
3. Determine which criminal investigation is involved.
4. Obtain and review the relevant seizure decision where procedurally possible.
5. Identify the alleged offence.
6. Trace the source of every significant disputed amount.
7. Collect Turkish and foreign bank statements.
8. Document third-party or corporate ownership where relevant.
9. File a reasoned objection or request to lift or narrow the restriction.
10. Continue challenging unnecessary or disproportionate restrictions where the legal conditions no longer exist.

The objective should be to turn a confusing financial restriction into a documented legal and accounting analysis.

Frequently Asked Questions

Can a foreigner’s bank account be frozen during a criminal investigation in Turkey?

Yes. Article 128 expressly includes accounts at banks and other financial institutions among property interests that may be seized when the statutory requirements are satisfied. (Kararlar Bilgi Bankası)

Does a frozen account mean I have been convicted?

No. A criminal asset freeze is generally a protective measure and does not itself establish criminal guilt or permanently transfer ownership of the funds.

Who can order an Article 128 asset seizure?

Current Ministry of Justice materials state that seizure of the property rights governed by Article 128 requires a unanimous decision of the competent serious criminal court. (Rayp Adalet)

Can I object to the bank account freeze?

Yes. Ministry of Justice guidance confirms that an Article 128 seizure concerning real estate, rights and receivables can be challenged through the applicable objection procedure. (Rayp Adalet)

Can I prove that the frozen money came from a lawful source?

Yes, and this can be one of the most important parts of the challenge. Bank statements, contracts, invoices, property-sale records, company documents and foreign banking records may establish the origin of the funds.

Can only part of the account be released?

Depending on the circumstances, counsel can examine whether a partial lifting or narrowing of the restriction is legally justified, particularly where specific legitimate funds can be distinguished from amounts allegedly connected to the investigation.

Can company accounts be frozen because a director is under investigation?

Potentially, but the legal basis and relationship between company property and the alleged offence must be examined. Independent corporate ownership and legitimate business income can be important to the challenge.

Can my account remain frozen until the entire criminal trial ends?

Not necessarily as an automatic rule. Continued restrictions must remain legally justified, and proportionality and the ongoing connection between the measure and its legitimate purpose can be challenged. The Constitutional Court’s property-rights jurisprudence requires a fair balance between public interests and the burden imposed on the property owner. (Anayasa Mahkemesi)

Can I simply transfer assets elsewhere to avoid the freeze?

You should not attempt to circumvent a lawful seizure. Ministry of Justice materials state that transactions intended to defeat an Article 128 seizure after the decision has been made are invalid. (Rayp Adalet)

I live abroad. Can I still challenge a Turkish account freeze?

Potentially, yes. Residence abroad does not remove property rights or available procedural remedies. Depending on the case, counsel may be able to pursue applications in Turkey while the foreign account holder remains abroad.

Client-Focused Legal Support for Frozen Bank Accounts in Turkey

A bank account freeze following a criminal investigation should be addressed through the underlying judicial measure, not merely through correspondence with the bank. Once the financial institution receives a binding seizure decision, the key dispute generally concerns whether the legal conditions for that decision exist and whether they continue to justify restricting the account.

For foreign account holders, the most effective strategy frequently begins with financial tracing. If the money came from salary, foreign investments, property sales, legitimate company revenue, inheritance, shareholder transactions or another lawful source, the documentary chain should be reconstructed carefully. Where only part of an account is allegedly connected to the investigation, the defense should also examine whether freezing the entire balance remains justified.

Article 128 provides a framework for seizure of bank accounts and other property interests where the statutory requirements are met, while Ministry of Justice materials confirm that such measures can be challenged through the applicable objection procedure. (Kararlar Bilgi Bankası) Constitutional property-rights principles provide an additional safeguard: restrictions should not operate arbitrarily and must maintain a fair balance between the legitimate public purpose and the burden imposed on the property owner. (Anayasa Mahkemesi)

Fırat Fesih Kaya Law Office assists foreign nationals, investors, shareholders, executives and foreign companies with frozen bank accounts, criminal asset seizures, release of seized funds, financial investigations, challenges to asset restrictions, third-party property claims, company account restrictions and criminal defense proceedings in Turkey.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yıldırım Tower, Balgat, Çankaya, Ankara, Turkey