Foreign Account Holder Withdraws Money for Someone Else in Turkey: Fraud and Money Mule Risks (2026 Updated Guide)

A foreigner withdraws or transfers money from a Turkish bank account for another person. Learn about fraud, money mule risks, criminal liability, bank blocks and legal defense in Turkey.

A foreign national who allows another person to use their Turkish bank account, withdraws money on someone else’s instructions, or receives and transfers funds for a third party can face serious legal risks in Turkey. What may initially appear to be a simple favor—such as withdrawing cash for a friend, receiving money for a business partner, or allowing someone else to use an account—can become relevant to a fraud, money laundering, unauthorized financial transaction or money mule investigation.

The critical question is not simply whether money passed through the foreigner’s account. Investigators may examine who sent the money, where it came from, why it was transferred, what the account holder knew, what instructions they received, what benefit they obtained and what happened to the money afterward.

For a foreign account holder, the situation can become more complicated because a bank transaction may also affect the person’s banking relationship, residence status, employment or business activities in Turkey.

What Is a Money Mule?

A money mule is generally a person whose bank account or other financial channel is used to receive, withdraw or transfer funds originating from unlawful activity or connected with a fraudulent scheme.

The person may participate knowingly, or may claim that they did not know the true source of the funds.

That distinction can become extremely important in a criminal investigation.

Is Withdrawing Money for Someone Else Automatically a Crime?

No.

A person can legitimately withdraw money for another individual in many ordinary situations.

For example, a person may receive authorization to collect money, operate a company account, assist a family member or perform a legitimate commercial transaction.

The legal problem arises when the transaction is connected to criminal conduct and the account holder’s knowledge, intent or participation satisfies the elements of an offence.

Why Are Foreign Account Holders Particularly Exposed?

A foreigner may be approached because they have:

• A newly opened Turkish bank account;
• A residence permit;
• A Turkish company;
• Access to banking applications;
• A local telephone number;
• A business relationship in Turkey;
• Access to international transfers.

A third party may offer money in exchange for receiving or withdrawing funds.

The account holder may believe the arrangement is harmless, while investigators later examine the transaction as part of a larger fraud scheme.

How Does a Typical Money Mule Scheme Work?

A common pattern may look like:

Victim

→ fraudulent payment

→ bank account controlled by foreign account holder

→ cash withdrawal

→ transfer to another person

→ disappearance of funds

The account holder may have played only one role in the chain, but investigators can still question why the account was used.

What If the Foreigner Says, “I Was Only Helping a Friend”?

That explanation may be relevant, but it does not automatically resolve the investigation.

Investigators may ask:

• How did you meet the person?
• Why did they need your account?
• How much money was involved?
• How frequently did this happen?
• Did you receive a commission?
• Did you know the sender?
• What did the sender’s payment description say?
• Where did you take the money?
• Who received the cash?

The entire relationship may therefore become relevant.

What If the Account Holder Received a Commission?

A payment or commission can become important evidence concerning the person’s role.

A person who repeatedly receives money and keeps a percentage before forwarding the remainder may attract greater scrutiny than someone who performed a single unexplained transaction.

However, a commission by itself does not automatically establish criminal liability.

What If the Account Holder Did Not Know the Money Was Fraudulent?

Knowledge and intent can become central issues.

The defense should therefore examine what the person knew at the time of the transaction—not merely what became known after the police investigation began.

Evidence can include messages, contracts, invoices, explanations from the person who requested the transfer and the account holder’s ordinary banking history.

What If the Foreigner Was Deceived Too?

A foreign account holder can potentially be both:

an investigated account holder

and

a person who was himself or herself deceived.

For example, someone may falsely claim that a payment represents a legitimate property purchase, investment, loan or business transaction.

The account holder’s own evidence of deception can therefore become highly relevant.

What If the Money Came From a Fraud Victim?

This is a particularly serious situation.

If a victim reports that money was transferred after a fraudulent transaction and the funds subsequently appear in the foreigner’s account, investigators may trace the account as part of the transaction chain.

The foreigner should not delete communications or attempt to conceal the transaction.

Do Not Return Money Secretly Without Legal Advice

A foreign account holder who discovers that suspicious money has entered the account may want to send it back immediately.

That can sometimes create additional complications.

The correct response depends on the circumstances, the bank’s instructions, the identity of the sender and whether a judicial or investigative measure has already been imposed.

What If the Bank Freezes the Account?

A Turkish bank may restrict an account or request additional information when a transaction creates compliance or suspicious-activity concerns.

A banking restriction does not itself establish criminal guilt.

The account holder should determine:

• What transaction caused the restriction;
• Whether the bank requested documents;
• Whether an official judicial measure exists;
• Whether the account is completely blocked;
• Whether only certain transactions are restricted.

Bank Compliance and Criminal Investigation Are Different

A bank’s compliance process and a criminal investigation are separate matters.

A bank may ask questions about the source and purpose of funds without there necessarily being a criminal prosecution.

Conversely, a criminal investigation may involve banking restrictions or requests for account information.

These issues should not automatically be treated as identical.

What Documents Should the Foreigner Preserve?

Immediately preserve:

• Bank statements;
• Transfer receipts;
• Account-opening documents;
• Messages;
• Emails;
• Contracts;
• Invoices;
• Payment instructions;
• WhatsApp conversations;
• Voice messages;
• Names and contact information of the person requesting the withdrawal;
• Evidence showing why the money was received.

The original chronology can become critical.

Do Not Delete WhatsApp Messages

If another person instructed the foreigner to withdraw or transfer money, those instructions may become important evidence.

The complete conversation can demonstrate:

what was requested

when it was requested

what explanation was given

whether the foreigner questioned the transaction

what happened afterward.

Preserve the Payment Description

Bank transfer descriptions may contain important information.

A payment described as “invoice,” “loan,” “property,” “investment,” or another purpose can become relevant when investigators compare the bank records with the parties’ explanations.

What If the Account Holder Used an ATM?

ATM withdrawals can create additional evidence, including:

• Date;
• Time;
• Amount;
• Location;
• Transaction record;
• Potential camera footage.

The account holder should not assume that cash withdrawal means the transaction cannot be traced.

What If Someone Else Used the Foreigner’s Bank Card?

This can create a significant factual issue.

Determine:

• Who had the card;
• Whether the account holder gave permission;
• Whether the PIN was shared;
• Whether the transaction was authorized;
• Whether the person acted without permission.

If the card was used without authorization, that should be reported and documented promptly.

What If the Foreigner Gave Their Internet Banking Password?

Sharing banking credentials can create serious risks.

The person may become unable to distinguish transactions personally authorized by the account holder from transactions conducted by another individual.

The account holder should immediately secure the account and preserve evidence concerning how the credentials were obtained or used.

What If the Foreigner’s Phone Was Used?

Turkish investigators may examine digital evidence when investigating financial transactions.

The foreigner should preserve the device and relevant communications rather than deleting applications or resetting the phone after learning about an investigation.

Can Police Question the Foreign Account Holder?

Yes, where the person is relevant to an investigation, they may be called or otherwise questioned according to the applicable criminal-procedure framework.

The person’s procedural status should be established before giving a substantive statement.

Should a Foreigner Give a Statement Without a Lawyer?

Where the matter concerns suspected criminal conduct, obtaining legal assistance before giving a detailed statement can be particularly important.

A foreigner may have language difficulties, may misunderstand the significance of banking terminology or may unintentionally make statements that appear inconsistent with the documentary evidence.

Interpreter Rights Can Matter

If the foreigner does not sufficiently understand Turkish, the person should request appropriate interpretation so that the statement and procedural rights can be understood accurately.

A language problem should not be allowed to turn into an evidentiary misunderstanding.

What Should the Foreign Account Holder Explain?

A defense should focus on the actual facts.

Depending on the case, relevant issues may include:

• Why the account was used;
• Relationship with the other person;
• What the foreigner was told;
• Whether compensation was received;
• What the foreigner knew;
• What documents were available;
• Why the withdrawal occurred;
• Where the cash went;
• Whether the foreigner benefited.

The statement should be consistent with objective bank and communication records.

Do Not Guess During a Police Statement

If the person does not remember a transaction, it is safer to distinguish memory from certainty rather than invent an explanation.

An inaccurate statement can create problems when bank records later show a different chronology.

What If the Foreign Account Holder Is Accused of Fraud?

The investigation should distinguish between:

being the account holder

and

participating in the fraudulent conduct.

The fact that money entered an account does not by itself establish that the account holder designed or committed the underlying fraud.

The prosecution must establish the relevant elements of the alleged offence against the specific person.

What If the Foreigner Was Only a Cash Withdrawer?

The exact role matters.

Investigators may examine whether the person merely performed a transaction at another person’s request or knowingly facilitated the movement of criminal proceeds.

Frequency, amount, instructions, compensation and surrounding circumstances can all become relevant.

Repeated Transactions Create Greater Risk

One isolated transaction and dozens of transfers are factually different.

A pattern involving multiple unrelated senders, rapid withdrawals and transfers to different individuals may cause investigators to examine the account holder’s role much more closely.

What If Multiple People Sent Money to the Same Account?

This may be a significant warning sign.

The account holder should prepare an explanation for every material transaction and preserve the documents supporting legitimate purposes.

What If the Foreign Company Account Was Used?

The situation may become more complicated if the account belongs to a Turkish company owned or managed by a foreign national.

Investigators may examine:

• Company purpose;
• Invoices;
• Accounting records;
• Shareholders;
• Managers;
• Customers;
• Contracts;
• Tax records;
• Source of funds.

The company’s transactions should be separated from the manager’s personal transactions.

What If the Foreign Account Holder Is a Company Manager?

A manager is not automatically criminally liable for every transaction conducted through a company account.

Personal criminal responsibility generally requires an individual legal basis and evidence connecting the manager to the alleged conduct.

The company’s records and the manager’s actual authority should therefore be reviewed carefully.

What If the Money Was Connected to Cryptocurrency?

Cryptocurrency transactions can also form part of a financial investigation.

Preserve:

• Wallet addresses;
• Transaction hashes;
• Exchange records;
• Bank transfers;
• Messages concerning the transaction.

Do not attempt to conceal or move suspicious assets after learning of an investigation.

What If the Foreigner Already Withdrew the Cash?

The withdrawal does not necessarily end the evidentiary trail.

Investigators may examine ATM records, bank records, communications, witnesses and subsequent movements of the money.

The person should document exactly what happened to the cash.

What If the Foreigner Gave the Cash to Another Person?

Identify that person and preserve evidence concerning the handover.

If possible, identify:

• Date;
• Location;
• Amount;
• Purpose;
• Instructions;
• Messages;
• Witnesses.

Do not create documents retroactively to make a transaction appear legitimate.

What If the Account Was Used Without Permission?

If the account holder genuinely did not authorize the transaction, immediately preserve evidence supporting that position.

This may include:

• Unauthorized-access notifications;
• Bank messages;
• Login records;
• Device information;
• Police reports;
• Communications with the bank.

What If the Foreigner Is Arrested?

The person should establish their procedural status and obtain legal assistance immediately.

A foreign suspect should not assume that the matter is merely a banking dispute if investigators are alleging criminal participation.

Can the Bank Freeze the Account Permanently?

A bank restriction and a judicial seizure are different issues.

The legal basis and authority for the restriction should be identified. If a formal judicial measure exists, the applicable procedural route must be examined separately.

Can Seized Money Be Returned?

Potentially, depending on the legal basis for the seizure, ownership of the funds, evidence and procedural stage.

If the money belongs legitimately to the foreigner, documents proving the source and purpose of the funds may be important.

What If the Foreigner’s Residence Permit Is at Risk?

A criminal investigation and immigration consequences are legally distinct questions, although serious criminal proceedings can create additional immigration concerns depending on the circumstances.

The foreigner should therefore consider both criminal defense and immigration consequences where relevant.

Do Not Leave Turkey Without Understanding the Case

A foreigner who learns that a criminal investigation may exist should determine whether there is:

• A summons;
• A judicial control measure;
• An arrest warrant;
• An international alert;
• A travel restriction;
• Another procedural measure.

Leaving Turkey without understanding the person’s legal status can create practical complications.

What If the Foreigner Is Outside Turkey?

The strategy may involve obtaining information about the proceeding, identifying the person’s procedural status and determining whether legal representation can be arranged.

The person should not rely on informal information from the account holder’s contacts.

How Should a Defense Be Built?

A strong defense should reconstruct the entire financial chronology:

Source of money

→ reason for payment

→ account receipt

→ instruction received

→ withdrawal or transfer

→ final recipient

→ benefit, if any

The objective is to distinguish innocent banking assistance from knowing participation in criminal activity.

Create a Transaction Table

For every suspicious transaction, record:

Date	Sender	Amount	Purpose	Withdrawal/Transfer	Final Recipient	Supporting Evidence
Date	Person/company	Amount	Stated purpose	Cash/bank	Person/company	Contract/message/invoice

This can reveal whether the transactions form a legitimate commercial pattern or an unexplained movement of funds.

Foreigners Should Not Ignore a Police Summons

Ignoring an official summons can create additional procedural problems.

If the person cannot attend for a legitimate reason, the appropriate legal procedure should be followed rather than simply ignoring the notice.

Criminal and Civil Issues May Overlap

The victim of the underlying fraud may seek recovery of the transferred money.

At the same time, the account holder may be investigated for their role in receiving or moving the funds.

These positions can create conflicting interests and require careful legal strategy.

What If the Foreigner Is Actually an Innocent Intermediary?

The defense should focus on objective evidence demonstrating lack of knowledge or participation.

Relevant evidence may include the legitimate relationship with the person giving instructions, genuine contracts, ordinary transaction history, lack of financial benefit and immediate cooperation after discovering the problem.

Immediate Legal Defense Checklist

A foreign account holder who has withdrawn or transferred money for another person should:

1. Stop participating in further suspicious transactions.
2. Preserve complete bank records.
3. Preserve all messages and payment instructions.
4. Identify every sender and recipient.
5. Document the reason for each transaction.
6. Secure online banking credentials.
7. Do not delete or alter digital evidence.
8. Determine whether the bank has imposed a restriction.
9. Determine whether a criminal investigation exists.
10. Establish the person’s procedural status.
11. Obtain an interpreter if necessary.
12. Obtain a criminal defense lawyer before giving a detailed statement where appropriate.
13. Prepare a transaction chronology.
14. Preserve evidence showing lack of knowledge or authorization.
15. Address any related immigration or travel consequences.

Frequently Asked Questions

Is it illegal for a foreigner to withdraw money for another person in Turkey?

Not automatically. The legality depends on the purpose, circumstances and the person’s knowledge and involvement.

What is a money mule?

A money mule is a person whose account or financial channel is used to receive, withdraw or transfer funds connected with unlawful activity. Criminal liability depends on the person’s actual conduct and the applicable legal elements.

Can a foreign account holder be investigated even if they did not commit the original fraud?

Yes. Investigators may examine the role of anyone whose account was used in the movement of suspected criminal proceeds.

Does receiving a commission prove criminal liability?

No. A commission may be relevant evidence, but criminal liability depends on the complete facts and applicable offence.

What if the foreigner did not know the money was fraudulent?

Lack of knowledge can be an important defense issue. The person’s communications, transaction history and surrounding circumstances should be examined.

Can a Turkish bank freeze a foreigner’s account?

A bank may impose restrictions for compliance or other legal reasons, while a separate judicial measure may also affect an account. The precise legal basis should be established.

What if someone else used the foreigner’s bank account?

The foreigner should immediately document whether the use was authorized and preserve evidence concerning access, instructions and transactions.

Should a foreigner speak to police without a lawyer?

Where the person is being investigated for suspected criminal conduct, obtaining legal assistance before giving a detailed statement can help protect procedural rights and prevent misunderstandings.

Can seized money be recovered?

Potentially, depending on why it was seized, who legally owns it, the evidence concerning its source and the procedural stage of the investigation.

What is the most important defense issue?

The central question is often not merely whether money passed through the foreigner’s account, but what the account holder knew, why the transaction occurred, what role the person actually played and whether the evidence proves knowing participation in the alleged criminal conduct.

Client-Focused Legal Support for Foreign Account Holders and Money Mule Investigations

A foreigner whose Turkish bank account has been used to receive, withdraw or transfer money for another person may face fraud allegations, money mule allegations, bank restrictions, seizure of funds and criminal investigation risks. Fırat Fesih Kaya Law Office assists foreign nationals facing criminal investigations involving bank accounts, suspicious transfers, fraud allegations and financial transactions in Turkey. Lawyer Fırat Fesih Kaya provides legal assistance in reviewing bank records, reconstructing transaction histories, preparing criminal defenses, protecting procedural rights, addressing seized funds and coordinating related immigration or business issues where necessary.

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