What should a foreign or local company director do after being summoned by a Turkish prosecutor? Learn about director liability, prosecutor statements, company bank accounts, fraud, money laundering, tax allegations, asset freezes and criminal defense strategy in Turkey.

A company director summoned by a Turkish prosecutor should not assume that holding a managerial title automatically creates criminal liability for every transaction carried out through the company. At the same time, a prosecutor’s summons should never be treated as a routine corporate formality. In commercial and financial investigations, company directors may be questioned about bank transfers, invoices, company accounts, payments to related parties, customer funds, tax-related transactions, cryptocurrency movements, alleged fraud, money laundering, customs transactions or actions performed by employees and other directors. Recent Turkish investigations demonstrate that prosecutors may simultaneously examine company executives, corporate accounts, digital evidence and company assets. In an August 2026 investigation, for example, the Ministry of Justice reported that 47 individuals identified as company managers were called to give statements in an investigation concerning 25 companies. ( The central defense question should therefore be individualized: What did this particular director authorize, know, control or personally do?

Why Has the Company Director Been Summoned?

A director can be summoned because investigators believe that the person has information about company activities, because the director had authority over a disputed transaction, or because the director is personally suspected of participating in an offense. The first step is therefore determining whether the director is being called as a suspect, witness, complainant or another participant in the investigation. A director should not prepare a substantive statement until the procedural status and general nature of the allegation are understood.

Being a Director Does Not Automatically Mean Being Guilty

Turkish criminal responsibility is fundamentally personal. A company may employ hundreds of people and process thousands of transactions. The fact that an individual appears in the trade registry as a director does not by itself establish that the person personally committed every offense allegedly connected with company operations.

The prosecutor will generally need to investigate the director’s actual conduct in relation to the alleged offense. This makes the distinction between formal corporate authority and actual operational control extremely important.

What Should a Director Do Immediately After Receiving a Prosecutor Summons?

The summons should first be examined carefully. Determine which prosecutor’s office issued it, whether an investigation number is stated, when attendance is required and what procedural capacity is indicated. The director should then preserve potentially relevant corporate and personal evidence rather than deleting or reorganizing records.

Do Not Delete Emails, WhatsApp Messages or Company Records

Once an investigation is known, deleting records can create serious evidentiary problems. Emails, internal messaging applications, accounting records, invoices, banking instructions, board resolutions and WhatsApp conversations may actually demonstrate that another director or employee was responsible for the questioned conduct.

Do Not Alter Accounting Records

Do not retrospectively change descriptions, invoices or bookkeeping entries merely because an investigation has started.

Never Create Backdated Documents

A director facing questions about a transaction should not attempt to manufacture a board resolution, contract, invoice or authorization that did not exist at the relevant time.

Determine the Exact Transactions Under Investigation

A financial investigation may cover years of company activity, but only particular transactions may be relevant to the alleged offense.

Prepare a chronology such as Date → Transaction → Amount → Counterparty → Commercial Purpose → Person Requesting Payment → Person Approving Payment → Person Executing Transfer → Supporting Documents.

Who Controlled the Company Bank Account?

This can become one of the most important questions in financial-crime investigations.

A company may have three directors while only the finance director has practical access to internet banking. Alternatively, several directors may have individual authorization limits. The defense should establish the real banking structure rather than relying only on titles.

Identify Internet Banking Authority

Determine who had usernames, passwords, mobile devices, tokens or other authentication methods.

Identify Payment Approval Rules

Was one signature sufficient? Were two directors required? Did payments above a particular amount require board approval?

Identify Who Actually Executed the Disputed Transfer

The person legally authorized to operate the account and the person who actually executed a particular transaction may not always be the same.

Example: Three Directors, One Disputed Transfer

Assume Company X has three directors. Director A manages sales, Director B manages operations and Director C manages finance. A customer transfers TRY 5 million to the company and later alleges fraud. Director C transfers most of the money to another company.

The mere fact that Directors A and B were registered directors does not establish that they knew about or participated in the disputed transfer.

Corporate Organizational Charts Can Become Evidence

An organizational chart, job descriptions, board resolutions and internal delegation documents may help establish the actual responsibilities of each director.

Who Communicated With the Alleged Victim?

Where fraud is alleged, this question is critical.

The investigation should determine who made the allegedly false representation that caused the victim to transfer money.

Did the Director Speak With the Customer?

Preserve emails, telephone records and messaging histories.

Did an Employee Handle the Transaction?

Identify that employee and their authority.

Did an External Agent or Consultant Handle It?

Preserve the agency or consultancy agreement and related communications.

Follow the Money After It Entered the Company

Receiving money into a corporate account is only one part of the investigation.

The defense should reconstruct:

Customer → Company Account → Supplier / Related Company / Individual / Crypto Platform → Ultimate Beneficiary.

The Ultimate Beneficiary Can Be Crucial

If the questioned money was immediately transferred to another director’s personal account, that fact can significantly affect the assessment of individual responsibility.

What If the Director Did Not Receive Any Financial Benefit?

Absence of personal benefit can be relevant, although it does not automatically eliminate potential criminal responsibility. The complete evidence concerning knowledge and participation must still be assessed.

Company Director Accused of Fraud

Fraud investigations often involve allegations that customers or investors transferred money because of false representations made on behalf of a company.

The defense should distinguish the company’s commercial failure from intentional deception.

Business Failure Is Not Automatically Fraud

A company can fail to perform a contract because of liquidity problems, supply-chain disruption, market conditions or genuine commercial disputes.

Examine the Situation When the Contract Was Made

One important issue is whether there was allegedly fraudulent intent from the beginning or whether a legitimate commercial relationship subsequently failed.

Preserve Performance Evidence

Contracts, delivery documents, invoices, emails, production records and partial performance may help establish the commercial nature of the dispute.

Company Director Accused of Money Laundering

Money-laundering allegations require detailed examination of the origin and movement of funds.

A director should not respond simply by saying, “The company’s money was legitimate.”

The lawful origin should be demonstrated.

Build the Source-of-Funds Chain

For example:

Export Sale → Customer Contract → Invoice → Foreign Customer Payment → Company Bank Account → Commercial Expenditure.

International Transfers

Foreign company directors may be questioned about substantial transfers entering or leaving Turkey.

The amount alone does not establish criminal activity. The commercial purpose and source should be documented.

Shareholder Loans

If the company received money from a foreign shareholder, preserve the loan agreement, banking records, accounting treatment and corporate authorization.

Capital Contributions

Preserve documents demonstrating the investment structure and source of the capital.

Related-Party Transactions

Payments to companies controlled by shareholders or directors can attract particular scrutiny.

The defense should establish whether genuine goods, services, licensing, financing or another legitimate commercial relationship existed.

An Invoice Alone May Not Be Enough

If the prosecutor suspects a fictitious transaction, evidence of actual performance becomes important.

For Goods

Purchase orders, delivery records, warehouse entries, transportation documents and customs records may be relevant.

For Services

Emails, reports, project documents, deliverables, meeting records and correspondence may help establish actual performance.

Company Bank Account Used for Internet Fraud

A company may become involved because fraud victims were instructed to send money to a corporate IBAN.

Recent 2026 investigations illustrate the seriousness of this risk. In June 2026, the Istanbul Anadolu Chief Public Prosecutor’s Office announced an investigation involving alleged sham “investment” and “finance” companies. According to the official announcement, investigators relied on victim statements and MASAK financial analysis, while company interests, bank and crypto accounts and other assets were subjected to measures and numerous suspects were detained. (İstanbul Anadolu Adliyesi)

A Company Name Does Not Make the Transaction Legitimate

Fraud networks may use incorporated entities to create an appearance of commercial legitimacy.

But Company Involvement Does Not Automatically Implicate Every Director

The investigation should identify who created the alleged scheme, who communicated with victims, who controlled company banking and who ultimately obtained the funds.

What If Another Director Controlled Everything?

Document it objectively.

Do not merely say, “My partner handled the finances.”

Show the corporate structure, banking authority, emails, instructions and transaction records.

What If the Accountant Made the Payment?

An accountant executing a payment according to instructions may not necessarily be the person who made the underlying decision. Identify who instructed the accountant.

Preserve Accounting Communications

Emails and internal messages can establish the instruction chain.

Company Credit Cards

If the investigation concerns personal expenditure using company funds, identify who possessed each card and which expenses are disputed.

Cash Withdrawals

Large cash withdrawals can create evidentiary difficulties because subsequent movement is harder to trace.

Identify who made the withdrawal, why it was made and whether supporting company documentation exists.

Fake Invoice Allegations

Where invoices are alleged to be fictitious, the prosecutor may investigate whether the underlying commercial transaction actually occurred.

Do Not Create Missing Documentation After the Fact

Instead, locate contemporaneous evidence demonstrating delivery or performance.

Customs and Import Transactions

Company directors can also be questioned concerning customs declarations, import values, invoices, origin documentation or allegedly prohibited goods.

The defense should identify who prepared the customs documentation and whether an external customs broker was involved.

Delegation Does Not Automatically Eliminate Responsibility

But it can be relevant when determining who actually knew of or performed the disputed conduct.

Cryptocurrency Transactions

A company director may be summoned because company money was transferred to a cryptocurrency platform or crypto assets entered a company-related account.

Cryptocurrency Is Not Automatically Evidence of Crime

The transaction purpose and money trail must be examined.

Preserve Exchange Histories

Identify the company or individual account used.

Preserve Wallet Addresses

Transaction hashes can help reconstruct the movement of assets.

Connect Banking and Blockchain Evidence

Prepare:

Company Bank Account → Crypto Platform → Asset Purchase → Wallet → Subsequent Destination.

MASAK Financial Analysis

In complex financial investigations, prosecutors may rely on banking information and MASAK financial analysis. The June 2026 investment-company investigation publicly described by the Istanbul Anadolu Chief Public Prosecutor’s Office expressly referred to MASAK data in identifying financial movements. (İstanbul Anadolu Adliyesi)

A Financial Analysis Is Not a Substitute for Individual Criminal Responsibility

The defense should examine whether the transactions attributed to the director were actually controlled, authorized or known by that person.

Can Company Bank Accounts Be Frozen?

Potentially, depending on the investigation and applicable legal requirements.

Can Personal Accounts Also Become Relevant?

Yes. Investigators may examine whether corporate funds were transferred into personal accounts or whether personal accounts were used for company transactions.

Separate Personal and Corporate Finances

A director who repeatedly uses personal accounts to receive company payments may face a more complicated evidentiary situation.

If Funds Were Already Mixed

Reconstruct every transfer rather than attempting to conceal the commingling.

Can Company Shares or Other Assets Be Restricted?

Financial-crime investigations can extend beyond bank accounts. The June 2026 prosecutor announcement concerning alleged investment-company fraud reported measures affecting companies, company shares, bank accounts, crypto accounts, real estate and vehicles. (İstanbul Anadolu Adliyesi)

Protective Measures Are Not the Same as Final Confiscation

An investigative restriction should not automatically be treated as a final determination that the property represents criminal proceeds.

Obtain the Actual Decision

Do not rely solely on a bank employee saying that “the prosecutor froze everything.”

Identify the Scope

Determine precisely which accounts, assets or company interests are affected.

Can the Director Review the Investigation File?

Defense access to investigation materials is an important part of preparing the defense, although statutory restrictions can apply in particular circumstances. Ministry of Justice training materials discuss the defense lawyer’s file-inspection right under CMK Article 153 and its relationship with the right to learn the accusation and prepare the defense. (Rayp Adalet)

What Happens During the Prosecutor Statement?

The director’s identity is established, the accusation should be explained and applicable procedural rights are communicated before the substantive statement. Ministry of Justice materials concerning CMK Article 147 confirm that the accusation and rights are explained before the statement and that the statement is formally recorded. (Mağdur hizmetleri)

Do Not Give Speculative Answers

A director may be questioned about a payment made three years earlier.

If you genuinely do not remember its purpose, guessing can be dangerous.

Review the Records

Financial cases should be defended from documents whenever possible.

Right to Legal Assistance

A suspect has rights concerning legal assistance during the statement procedure. Ministry of Justice materials addressing criminal procedure also describe circumstances in which mandatory defense counsel applies and the role of counsel during statements. (OLTU ADLİYESİ)

Do Not Sign an Inaccurate Statement

Read the statement carefully before signing it.

Check Numbers

A mistake between TRY 500,000 and TRY 5 million can materially change the record.

Check Names

Make sure the statement correctly identifies the people who controlled accounts or gave instructions.

Check Corporate Roles

Do not allow “shareholder,” “director,” “finance manager” and “accountant” to be used interchangeably if they describe different people.

What Happens After the Statement?

Several outcomes are possible. The prosecutor may continue the investigation without an immediate restrictive measure, seek additional evidence, order further investigative steps or, where the statutory conditions are considered satisfied, pursue measures such as judicial control or detention-related procedures.

A Prosecutor Summons Does Not Mean Arrest Is Automatic

Being called to give a statement and being detained or arrested are legally different matters.

Judicial Control

Depending on the case, judicial-control measures may become relevant.

Travel Ban

A prohibition on leaving Turkey can potentially be imposed as a judicial-control measure where the legal requirements are satisfied.

Foreign Directors

A foreign company director may be particularly concerned about whether appearing before the prosecutor will prevent departure from Turkey.

A pending investigation alone should not be confused with an existing judicial travel ban.

Foreign Nationality Does Not Establish Guilt

The defense should focus on concrete evidence concerning the person’s conduct.

Interpreter Issues

A foreign director who cannot adequately understand Turkish should ensure that the statement and questions are properly understood before answering.

Never Sign Something You Do Not Understand

This is particularly important where technical accounting and financial terminology is involved.

Can the Investigation Affect a Foreign Director’s Residence Permit?

A criminal investigation does not automatically mean cancellation of a Turkish residence permit.

Criminal and Immigration Proceedings Should Be Assessed Separately

However, depending on the seriousness and development of the criminal proceedings, separate immigration consequences may require attention.

Can the Director Be Deported?

A prosecutor summons itself does not constitute a deportation decision. Any immigration measure requires its own legal basis and assessment.

What If the Director Lives Abroad?

Do not assume that the summons can simply be ignored.

The procedural status and method of responding should be examined before the director makes travel decisions.

What If the Director Plans to Enter Turkey?

The status of the investigation and any relevant judicial measures should be determined beforehand where possible.

Search and Seizure of Company Premises

Depending on the investigation and legal requirements, company records and digital devices may become subject to investigative measures.

Preserve the Chain of Custody Internally

Record which employee used which computer, telephone or company account.

Do Not Wipe Company Computers

Potentially exculpatory evidence may be destroyed.

Do Not Replace Phones Solely Because of the Investigation

Historical devices can contain communications establishing actual responsibility.

Cloud Records

Corporate email and cloud-storage records can become significant evidence.

Accounting Software

ERP and accounting-system logs may show which user created or approved transactions.

Electronic Signatures

Determine who controlled company electronic-signature credentials.

IP and Device Records

In cases involving disputed digital access, technical records may assist in identifying the person who actually performed an action.

What If an Employee Committed the Alleged Crime Without the Director’s Knowledge?

The defense should establish the employee’s role, authority, access and conduct.

But “I Did Not Know” Should Be Supported

Corporate records, access logs, reporting lines and communications can help establish whether the director was genuinely uninvolved.

What If the Director Ordered the Transaction but Believed It Was Lawful?

Then the underlying information available to the director at the time becomes important.

Preserve Advice and Due-Diligence Materials

Contracts, compliance reports and internal correspondence may show why the transaction was considered legitimate.

Do Not Manufacture Compliance Evidence

Only contemporaneous records should be relied upon as genuine historical evidence.

What If Another Director Blames You?

Multi-suspect corporate investigations frequently involve conflicting statements.

The defense should not become a competition in unsupported accusations.

Objective Evidence Is Stronger

Bank authorizations, emails, access records, board minutes and financial movements can determine which account is accurate.

Do Not Coordinate Statements With Co-Suspects

Attempting to create a shared false narrative can create additional difficulties.

What Should Be Done in the First 24 Hours?

Secure the summons, identify the prosecutor and investigation number where available, preserve corporate records, determine whether the director is being called as a suspect or witness and identify any immediately known disputed transactions.

What Should Be Done in the First 48 Hours?

Map corporate authority. Determine who controlled bank accounts, accounting systems, electronic signatures, company email, cryptocurrency accounts and disputed customer relationships.

What Should Be Done in the First 72 Hours?

Prepare the transaction chronology, collect contracts and invoices, preserve banking evidence, identify actual beneficiaries and assemble the documents necessary to explain the commercial purpose of questioned transactions.

Prepare a Director Responsibility Matrix

A useful structure is:

Director/Employee → Corporate Role → Banking Authority → Operational Responsibility → Disputed Transaction Involvement → Supporting Evidence.

Prepare a Transaction Matrix

Use:

Date → Amount → Sender → Recipient → Purpose → Contract/Invoice → Authorization → Actual Executor → Ultimate Destination.

Prepare an Evidence Matrix

Use:

Prosecution Allegation → Existing Evidence → Director’s Explanation → Supporting Document → Missing Evidence to Obtain.

What Should a Company Director Never Do After Receiving a Prosecutor Summons?

Do not delete emails or messages, alter accounting records, manufacture contracts, create fake invoices, backdate board resolutions, move disputed assets to relatives, hide company property, coordinate false statements with employees or transfer funds merely to place them beyond the investigation.

2026 Defense Strategy for a Company Director Summoned by a Turkish Prosecutor

The strongest defense begins by separating corporate responsibility from individual criminal responsibility. The director should determine the procedural status, alleged offense and specific transactions under investigation before giving a detailed substantive statement. The company’s formal organizational structure should then be compared with actual operational control. Banking authorizations should identify who could initiate and approve transfers. Internal records should show who communicated with customers, who negotiated contracts and who instructed accountants. Each disputed payment should be traced from its original source to its ultimate beneficiary. Where fraud is alleged, the defense should identify who made the alleged false representation and whether the dispute was actually a failed commercial transaction. Where money laundering is alleged, the lawful source and commercial purpose of funds should be documented. Where cryptocurrency is involved, banking records should be connected with exchange histories and blockchain transactions. Where corporate or personal assets have been restricted, the precise judicial or administrative basis and scope should be identified. The practical roadmap is therefore: review the summons → determine suspect or witness status → identify the prosecutor file → understand the allegation → preserve all evidence → identify the questioned transactions → map corporate authority → identify banking access → determine who authorized payments → determine who executed payments → identify customer communications → follow the money → identify ultimate beneficiaries → collect contracts and invoices → prove actual performance → preserve accounting and digital records → separate corporate and personal assets → reconstruct cryptocurrency transactions where relevant → examine any asset restrictions → prepare the statement from documents rather than memory → correct inaccuracies before signing → assess judicial-control risk → assess travel restrictions separately → protect company operations while the investigation continues.

Frequently Asked Questions

1. Is a company director automatically criminally responsible for offenses committed through the company?

No. The director’s individual conduct, knowledge, authority and participation must be examined. A corporate title alone does not prove personal commission of an offense.

2. What should I do if a Turkish prosecutor summons me?

Determine your procedural status and the investigation concerned, preserve relevant evidence and identify the transactions likely to be questioned before giving a detailed statement.

3. Can I have a lawyer during my prosecutor statement?

A suspect has rights concerning legal assistance during the criminal statement procedure. The precise procedural position should be evaluated before the statement. (Mağdur hizmetleri)

4. Can I refuse to answer questions that may incriminate me?

Turkish criminal procedure contains protections relating to the suspect’s defense and statement rights. The appropriate use of those rights should be considered according to the circumstances of the investigation.

5. Can I be arrested immediately after giving a prosecutor statement?

A prosecutor summons does not automatically mean arrest. Depending on the evidence and applicable procedural requirements, the investigation may continue without a restrictive measure or further judicial procedures may be requested.

6. Can company bank accounts be frozen during the investigation?

Potentially, where the applicable legal requirements are satisfied. Recent 2026 financial-crime investigations have included restrictions concerning company interests, bank accounts, cryptocurrency accounts and other assets. (İstanbul Anadolu Adliyesi)

7. What if another director actually controlled the company bank account?

Bank authorization records, authentication evidence, internal communications and corporate documents should be preserved to establish actual control.

8. Can a foreign company director be prohibited from leaving Turkey?

Potentially, a prohibition on leaving Turkey may be imposed as a judicial-control measure where the statutory conditions are satisfied. Merely being summoned by a prosecutor does not itself establish that such a restriction exists.

9. Can a criminal investigation affect a foreign director’s residence permit?

Not automatically. Criminal and immigration proceedings are legally distinct, although developments in a serious criminal case may require a separate immigration assessment.

10. What evidence is most important for a company director’s defense?

Banking authorizations, board resolutions, contracts, invoices, accounting records, emails, internal messages, payment instructions, electronic-access records and evidence showing who ultimately benefited from disputed transactions can be particularly important.

Legal Support for Company Directors Summoned by Turkish Prosecutors

Company directors, foreign shareholders and international executives summoned during a Turkish criminal investigation may face fraud allegations, money-laundering investigations, suspicious company transfers, MASAK financial analysis, frozen corporate accounts, cryptocurrency investigations, asset restrictions, judicial-control measures and potential travel restrictions.

Fırat Fesih Kaya Law Office provides legal assistance to company directors, foreign investors, shareholders and international businesses involved in criminal investigations in Turkey.

Fırat Fesih Kaya can assist with prosecutor statements, preparation of corporate and financial evidence, fraud and money-laundering allegations, company bank-account investigations, asset-seizure objections, cryptocurrency transactions, director-liability analysis and related proceedings affecting foreign executives in Turkey.

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