Foreign Business Owner’s IBAN Is Used in a Fraud Scheme Without Permission: What Should They Do? (2026 Updated Guide)

A foreign business owner discovers that their Turkish IBAN was used in a fraud scheme without permission. Learn how to report the incident, protect bank accounts, preserve evidence and defend against criminal allegations.

A foreign business owner in Turkey may discover that their bank account or IBAN has been used to receive money connected with an alleged fraud without their knowledge or authorization. The account may have been used by an employee, business partner, former representative, online fraudster or another person who obtained access to banking details. In more serious situations, the account holder may learn that victims have filed criminal complaints, the bank has restricted transactions, or prosecutors are investigating the business owner as a suspected participant.

The most important distinction is whether the account holder knowingly participated in the transactions or whether their bank account was used without their authorization. Receiving suspicious funds does not, by itself, establish criminal guilt. However, the account holder must be able to explain the transactions, preserve relevant evidence and respond appropriately to any bank restriction or criminal investigation.

1. How Can a Foreign Business Owner’s IBAN Be Used in Fraud?

An IBAN identifies a bank account for payment purposes. Fraudsters may use an account to receive money from victims, transfer proceeds to other accounts or make transactions appear to be connected with a legitimate business.

Common scenarios include unauthorized access to online banking, misuse of employee credentials, forged payment instructions, deceptive commercial transactions, misuse of a power of attorney, fraudulent online sales and transactions conducted through a business account without the owner’s knowledge.

The legal consequences depend on the actual transactions, the account holder’s role, the available evidence and whether the account was used by an individual, company employee or third party.

2. Does Receiving Fraud Proceeds Automatically Make the Account Holder Guilty?

No. The fact that money entered a bank account does not automatically prove that the account holder committed fraud or knowingly assisted another person.

Investigators may examine whether the account holder authorized the transactions, communicated with the alleged perpetrators, received a commission, withdrew or transferred the funds, or knew that the money was connected with criminal activity.

A business owner whose account was compromised may have a materially different legal position from someone who knowingly allowed their account to be used to receive and transfer suspicious funds.

3. What Should You Do Immediately?

If you discover unauthorized or suspicious transactions, act promptly. Contact the bank through an official channel, report the unauthorized activity and request information about the relevant transactions. If the account is being used to receive additional suspicious payments, ask the bank what protective steps are available.

Preserve bank statements, transaction references, payment notifications, emails, messages, contracts and records showing who had access to the account. Do not delete communications or alter business records.

If the bank has already restricted the account or a criminal investigation has started, obtain legal assistance promptly so that the banking response and criminal defense can be coordinated.

4. Notify the Bank in Writing

A telephone call may be useful for urgent notification, but a written complaint helps establish when the business owner reported the suspected misuse.

The notification should identify the relevant account, disputed transactions, approximate dates and reasons for believing that the activity was unauthorized. Request a written reference number and preserve the bank’s response.

Do not make unsupported accusations against a particular employee or business partner. Describe the known facts and clearly distinguish confirmed information from suspicions.

5. Request Transaction Records

Obtain available records for each disputed transfer, including the transaction date, amount, beneficiary, payment reference and relevant account information. Where available, preserve notifications of changes to banking credentials, new devices, access attempts and payment authorizations.

These records can help establish whether the transactions correspond to the business owner’s ordinary activities or appear inconsistent with the company’s normal operations.

6. Determine Who Had Access to the Account

Investigate whether access was available to employees, accountants, directors, former employees, authorized representatives or external service providers. Review corporate banking authorizations and any powers of attorney.

If access credentials were shared or a third party had authority to make payments, establish the precise scope of that authority. Access to an account does not necessarily mean that every transaction was authorized.

7. What If an Employee Used the IBAN Without Permission?

An employee may have used banking access, payment instructions or company documents to receive or transfer money without authorization.

Preserve employment records, internal messages, payment approvals, access logs and relevant corporate policies. Establish who approved each transaction and whether the employee acted within the scope of their authority.

Do not alter internal records or create retrospective approvals. If the employee is suspected of misconduct, any internal investigation should be conducted carefully and consistently with applicable law.

8. What If a Business Partner Used the Account?

A business partner may claim that a transfer was connected with a commercial agreement, loan, investment or customer payment. The account holder should compare that explanation with the underlying contracts, invoices, accounting entries and communications.

If the transaction was unauthorized, preserve evidence showing the absence of consent. If the transfer was part of a genuine commercial arrangement, retain the documents that establish its purpose.

A business relationship does not automatically prove criminal involvement, but unexplained transfers require a clear and evidence-based response.

9. What If the IBAN Was Obtained Through Deception?

Fraudsters may impersonate a customer, supplier, employee or company representative to obtain account details or manipulate payment instructions.

Preserve the original messages, email headers where available, telephone records, invoices and any documents used to induce the transaction. If a message appears to have been sent from a compromised account, record the circumstances and notify the relevant service provider where appropriate.

The chronology can be important: how the information was obtained, who gave the payment instructions, who authorized the transfer and when the account holder first discovered the misuse.

10. What If Victims Have Already Filed Criminal Complaints?

The account holder may learn about the allegations through a police summons, prosecutor’s communication, bank notification or account restriction. Do not ignore official notices.

Identify the authority handling the matter, any case or investigation reference, the alleged transactions and the person’s procedural status. A witness, complainant and suspect have different procedural positions, and the appropriate response depends on that status.

A foreign business owner should avoid making informal explanations that contradict bank records or the company’s own documents. Prepare a factual chronology and obtain legal advice before providing a detailed statement where criminal liability may be at issue.

11. Can the Business Owner File a Criminal Complaint?

Potentially, yes. If the account was used through unauthorized access, deception, forged documents or another suspected offence, the account holder may report the facts to the competent authorities.

Under Turkish criminal procedure, reports or complaints concerning suspected offences may be made to a public prosecutor or law-enforcement authorities. The complaint should explain the suspected misuse and identify supporting evidence.

A report should not claim that a particular person committed a crime unless the available facts reasonably support that allegation. It is appropriate to identify a suspected person while making clear which details remain unverified.

12. Should the Account Holder Report the Matter Even if the Bank Has Already Blocked the Account?

A bank restriction and a criminal complaint serve different purposes. The bank may restrict transactions under its own legal or compliance obligations, while criminal authorities investigate whether an offence occurred.

If the account holder believes the account was used without permission, reporting the incident can help document their position. The timing and content of the report may become relevant when investigators assess when the account holder learned about the transactions and what steps followed.

13. What If the Bank Freezes the Account?

A bank may restrict an account for various reasons, including suspected fraud, security concerns, compliance checks or instructions from a competent authority. The legal basis for the restriction must be identified before choosing a remedy.

Ask the bank what information it can lawfully disclose, whether the restriction applies to all transactions or only specific funds, and what documents may be submitted for review. If the restriction results from a formal judicial or prosecutorial measure, a routine customer-service request may not be sufficient to secure release.

14. Can the Business Owner Recover Frozen Money?

Potentially, but the process depends on the nature of the restriction and the source of the funds. Money belonging to the business owner may be mixed with funds suspected of originating from fraud, creating a need to distinguish legitimate business receipts from disputed transactions.

Prepare invoices, contracts, delivery records, accounting entries and evidence of the commercial source of the money. If the restriction was imposed by a judicial or prosecutorial decision, the appropriate application or objection must be assessed under the applicable procedural rules.

A bank restriction should not be assumed to disappear automatically because the account holder denies wrongdoing.

15. What If the Account Was Used to Transfer Money to Another IBAN?

Investigators may examine the full transaction chain, including incoming payments, outgoing transfers, withdrawals and transfers to related companies or individuals.

Preserve records identifying who instructed each transfer, who benefited from it and why it was made. If the business owner transferred money after receiving suspicious funds, the circumstances and timing should be explained accurately.

Do not move funds in an attempt to avoid a restriction or conceal their location. Such actions can complicate the investigation and create additional legal exposure.

16. Can a Foreign Business Owner Be Accused of Money Laundering?

Potentially, depending on the evidence and the applicable legal elements. Turkish Criminal Code provisions concerning laundering proceeds of crime may become relevant where the required conditions are established.

However, an unusual transfer or receipt of money does not, by itself, establish money laundering. Investigators must examine the source of the funds, the transactions, the person’s knowledge and conduct, and the applicable statutory requirements.

A defense should distinguish the allegation of fraud from any separate allegation concerning the handling or concealment of criminal proceeds.

17. Does Lack of Turkish Language Skills Affect the Investigation?

A foreign national who does not adequately understand Turkish may require an interpreter during relevant criminal proceedings. The person’s procedural status and the nature of the proceeding affect the applicable rights and arrangements.

Do not sign a statement that you cannot understand. Request interpretation and make sure that the recorded statement accurately reflects what you said. If a translation error occurs, identify the specific error and request that it be addressed through the appropriate procedure.

18. Should You Sign a Police Statement Immediately?

Do not sign a statement that contains inaccurate information, omissions or words you did not use. Read the document carefully in a language you understand, with appropriate interpretation where necessary.

If the record does not reflect your account, request correction before signing and ensure that any objection is properly recorded. If you are being questioned as a suspect, obtain legal assistance and clarify your procedural rights before making a substantive statement.

19. What Evidence Can Show That the IBAN Was Used Without Permission?

Potentially useful evidence includes bank transaction records, access logs, login notifications, correspondence, forged payment instructions, company authorization records, contracts, invoices, witness statements and evidence of when the account holder first reported the activity.

The evidence should establish both the disputed transactions and the account holder’s actual role. A statement that “I did not know” may be less persuasive without supporting records explaining how the transactions occurred and who had access.

20. What If the Account Holder Received a Commission?

A commission or fee may become relevant when investigators assess the account holder’s role. Its significance depends on the purpose of the payment, the underlying agreement, the account holder’s knowledge and the surrounding circumstances.

If the payment was a legitimate business fee, preserve the contract, invoice, accounting treatment and evidence of the service provided. If it was unexplained, do not invent a commercial justification after the event.

21. Can the Business Owner Be Held Liable for Failing to Protect the Account?

The legal consequences depend on the facts, the relevant contractual and regulatory obligations, and whether the person committed or facilitated any unlawful conduct. Negligent security practices do not automatically establish criminal guilt.

However, weak access controls, shared credentials and missing payment approvals may complicate the factual analysis. Review the company’s banking procedures, access permissions and internal controls while preserving the original records.

22. What If the IBAN Belongs to the Company Rather Than the Individual?

A company account and a personal account are legally distinct. Investigators should determine who controlled the account, who authorized the transactions and whether the company or an individual received or benefited from the funds.

A director is not automatically criminally liable for every transaction made through a company account. Conversely, using a company account does not prevent individual liability where evidence establishes personal participation in an offence.

23. Can the Business Owner Claim Compensation?

Depending on the facts, possible claims may arise against a person who unlawfully accessed the account, misappropriated funds or caused compensable loss. The availability of a claim against a bank or another service provider depends on the relevant duties, authorization records, security circumstances and applicable law.

Document direct financial losses, business interruption, bank charges and other claimed damage. Compensation is not automatic merely because an account was misused or temporarily restricted.

24. What Should the Business Do to Prevent Further Misuse?

Review authorized users, revoke access that is no longer required, change compromised credentials through secure official procedures and strengthen payment approvals. Confirm that contact details and banking notifications are accurate.

Introduce dual approval for significant transfers where appropriate, independently verify changes to supplier bank details and maintain a clear record of who authorized each payment. These steps should be taken without destroying or altering evidence relevant to the investigation.

25. Immediate Legal Response Checklist

1. Notify the bank of suspected unauthorized transactions.
2. Obtain transaction records and preserve account statements.
3. Record when and how the misuse was discovered.
4. Identify employees, representatives and other persons with account access.
5. Preserve emails, messages, invoices, contracts and authorization documents.
6. Determine whether the account holder is a witness, complainant or suspect.
7. Obtain the relevant investigation or restriction details where available.
8. Seek legal assistance before a substantive suspect statement where criminal exposure exists.
9. Request an interpreter if you cannot adequately understand Turkish.
10. Identify the source and destination of each disputed transfer.
11. Prepare evidence supporting the legitimate origin of business funds.
12. Assess the appropriate route to challenge any account restriction.
13. Avoid moving or concealing funds connected with the investigation.
14. Review corporate banking controls to prevent further unauthorized transactions.

Frequently Asked Questions

1. Can a foreign business owner be arrested because their IBAN was used in fraud?

An investigation or arrest cannot lawfully be justified solely by the fact that money entered an account. The applicable legal conditions and evidence must be assessed individually, including the person’s role and any indication of knowing participation.

2. Does receiving money from a fraud victim prove criminal involvement?

No. The source of the money is relevant, but investigators must examine authorization, knowledge, communications, subsequent transfers and other circumstances.

3. Can the bank freeze a business account?

A bank may impose restrictions where legally justified, and competent authorities may also order measures affecting accounts. The precise legal basis determines how the restriction can be challenged.

4. Should the account holder file a criminal complaint?

If the account was used without authorization and the facts suggest an offence, reporting the incident may be appropriate. Preserve supporting evidence and distinguish established facts from suspicions.

5. What if an employee used the company account without permission?

Preserve banking authorizations, access records, internal communications and payment approvals. The employee’s conduct and the company’s response should be assessed using the available evidence.

6. Can a foreign national give a statement in English?

Where the person does not adequately understand Turkish, applicable interpretation rights should be addressed. The statement must accurately reflect the person’s account, and the person should not sign a record they cannot understand.

7. Can the account holder recover legitimate funds that have been frozen?

Potentially. Recovery depends on the legal basis of the restriction, the source of the money and the available procedural remedies. Supporting commercial records can be essential.

8. Can a company director be held personally liable?

Not automatically. Individual liability depends on the person’s own conduct and the applicable legal requirements, rather than simply their position as director.

9. What if the money was transferred onward before the account holder discovered the fraud?

Preserve all transaction records and identify who initiated each transfer. The timing of discovery, the person’s authority and the reasons for the transfers may be important to the investigation.

10. What is the most important first step?

Secure the bank records, report suspected unauthorized activity, preserve evidence and establish exactly who authorized and controlled the disputed transactions. If a criminal investigation has begun, coordinate the bank response with a legally informed defense.

Client-Focused Legal Support for IBAN Fraud Investigations in Turkey

Foreign business owners facing suspected IBAN misuse may need to address criminal allegations, bank-account restrictions, suspicious transfers, company records, employee misconduct and recovery of legitimate funds at the same time. Fırat Fesih Kaya Law Office assists foreign nationals, entrepreneurs and international businesses dealing with fraud allegations and unauthorized banking transactions in Turkey. Lawyer Fırat Fesih Kaya provides legal assistance in organizing transaction evidence, preparing criminal complaints and defense submissions, evaluating account restrictions, coordinating with relevant authorities and assessing potential financial recovery claims.

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