Foreign Company Discovers Fake Suppliers and Invoices in Turkey: Criminal Investigation Guide (2026 Updated Guide)

A foreign company discovers fake suppliers or invoices in its Turkish operations. Learn how to preserve evidence, investigate employees and suppliers, report suspected fraud, trace payments and protect the company during a criminal investigation.

A foreign company operating or investing in Turkey may discover that payments have been made to fake suppliers, fictitious service providers or companies issuing invoices for goods or services that were never actually supplied. The scheme may involve employees, managers, procurement personnel, accountants, intermediaries or external suppliers acting individually or together. What initially appears to be an accounting irregularity can quickly develop into a serious criminal matter involving allegations of fraud, breach of trust, document-related offenses, tax exposure, money laundering concerns and unauthorized company payments. The company should react quickly but carefully. The immediate priorities are to stop further losses, preserve evidence, identify the payment trail, protect company records and prepare a legally structured criminal complaint without contaminating the evidence through an uncontrolled internal investigation.

What Is a Fake Supplier Scheme?

A fake supplier scheme generally involves creating or using a company or individual as an apparent vendor even though the underlying commercial transaction is fictitious, inflated or substantially different from what company records suggest.

For example, an employee may arrange invoices from a controlled company for services that were never performed and approve payment from the employer’s bank account.

Fake Supplier Does Not Always Mean a Non-Existent Company

The supplier may legally exist but still be used as part of a fraudulent arrangement.

A registered company can issue invoices for fictitious transactions, inflated quantities, nonexistent consultancy services or goods that were never delivered.

The investigation should therefore focus on the economic reality of the transaction, not merely whether the supplier appears in a corporate registry.

Warning Signs Foreign Companies Should Investigate

Suspicious circumstances may include repeated payments to recently created suppliers, identical bank accounts used by supposedly unrelated vendors, invoices just below internal approval thresholds, unusually vague consultancy descriptions, duplicate invoices, unexplained price increases, suppliers sharing contact information with employees or missing delivery records.

One indicator alone does not prove criminal conduct, but several connected irregularities may justify a structured investigation.

Stop Further Payments Immediately

If credible evidence suggests that a supplier is fraudulent, the company should review pending payments and internal authorization rights immediately.

This should be done carefully so that legitimate contractual obligations are not suspended without justification.

Preserve Evidence Before Confronting Suspected Employees

One of the most common mistakes is confronting an employee before securing company records.

Once suspects realize that an investigation has begun, emails, messages, accounting records or other evidence may disappear.

Evidence preservation should therefore come first.

Preserve Corporate Emails

Relevant business emails can reveal how the supplier was introduced, who approved it, who negotiated pricing and who instructed the accounting department to make payments.

Preservation should comply with applicable employment, privacy and data-protection requirements.

Preserve Accounting Records

Secure invoices, payment vouchers, purchase orders, delivery documents, expense approvals, accounting entries and supplier registration files.

Do not rely only on screenshots where original electronic records remain available.

Preserve Bank Records

Bank transfers can provide one of the clearest timelines in a fake-supplier investigation.

Create a transaction matrix showing:

supplier name, invoice number, invoice date, payment date, amount, receiving bank account, approving employee and stated purpose of payment.

Identify the Ultimate Recipient of the Money

The invoice issuer and ultimate beneficiary may be different.

Payments may be transferred through several accounts before reaching an employee, manager or related person.

The criminal investigation may therefore require examination of the wider financial trail.

Check Supplier Ownership

Investigate shareholders, directors, managers and authorized representatives of suspicious suppliers.

Connections between the supplier and company employees can become highly significant.

Look for Family or Personal Connections

A supplier may be owned by a spouse, relative, friend or business associate of an employee involved in procurement.

Such a relationship is not automatically criminal, but undisclosed conflicts of interest combined with fictitious transactions can become important evidence.

Review How the Supplier Entered the Procurement System

Determine who first recommended the supplier, who conducted due diligence, who entered the supplier into company systems and who approved the first purchase.

This can reveal whether internal controls were deliberately bypassed.

Examine Approval Thresholds

Fraud schemes sometimes divide payments into smaller amounts to avoid higher-level approval.

Review whether multiple invoices were issued for what should commercially have been a single transaction.

Compare Invoices With Actual Deliveries

For physical goods, determine whether the products actually entered the company’s warehouse or facility.

Review delivery notes, warehouse records, inventory movements, vehicle entries and employee confirmations.

Check Serial Numbers and Inventory

Where invoices concern machinery, electronics or other identifiable assets, verify whether the listed items physically exist.

Missing serial numbers or duplicated asset entries can expose fictitious purchases.

Consultancy and Service Invoices Require Different Evidence

For services, ask what was actually delivered.

A genuine consulting project should normally leave some commercial evidence such as reports, correspondence, presentations, meeting records or work product.

A vague invoice stating “consultancy services” without supporting evidence deserves closer examination.

Inflated Invoices Can Also Create Criminal Exposure

The transaction does not have to be completely fictitious.

A genuine supplier may invoice significantly above the agreed or market price while secretly sharing the excess with an employee.

This can require analysis of both the legitimate and allegedly fraudulent parts of the transaction.

Duplicate Invoice Fraud Should Be Checked

Search accounting systems for identical invoice numbers, amounts, descriptions and dates.

Also check whether the same commercial transaction was paid through more than one legal entity within the corporate group.

Can Employees Be Criminally Liable?

Potentially. Criminal responsibility depends on the conduct and evidence concerning each individual.

An employee who deliberately creates fictitious transactions, causes unauthorized payments or participates in deception may face criminal allegations depending on the circumstances.

Can Company Managers Be Investigated?

Yes, particularly where approval records indicate managerial involvement.

However, managerial position alone should not automatically establish criminal liability. Investigators should distinguish between deliberate participation, negligent supervision and legitimate reliance on employees or accounting systems.

External Suppliers Can Also Be Investigated

If the supplier knowingly participated in fictitious invoicing or fraudulent payment arrangements, its owners, managers or representatives may also become subjects of the criminal investigation.

Fraud May Be Relevant

Where deceptive conduct causes the company to transfer money or suffer financial loss, fraud-related criminal allegations may arise depending on the facts.

The exact legal characterization should be based on how the scheme actually operated.

Breach of Trust May Also Be Relevant

Where an employee or manager misuses company property or authority entrusted to them, breach-of-trust issues may require examination.

The distinction between different offenses can depend heavily on the method used to obtain or control the money.

Document-Related Offenses May Arise

Fake invoices, fabricated delivery records, false approval documents or altered company records can create separate document-related criminal issues.

Preserve original documents and metadata wherever possible.

Tax Consequences Must Be Reviewed Separately

Invoices lacking a genuine underlying transaction can also create tax exposure for the Turkish company.

The criminal fraud investigation and the company’s tax position should therefore be coordinated, but they should not be treated as the same legal proceeding.

Money Laundering Concerns Can Develop

If proceeds of suspected crime are transferred through multiple companies or accounts, financial-investigation issues may arise.

The company should preserve payment records and avoid making unsupported accusations concerning money laundering before the financial trail has been examined.

Should the Foreign Company Conduct an Internal Investigation?

Usually, a carefully structured internal investigation can be valuable.

Its purpose should be to establish facts, preserve evidence, identify losses and determine which matters require criminal, employment, corporate, tax or civil action.

Internal Investigations Must Be Controlled

Giving broad access to sensitive evidence or allowing numerous employees to interview witnesses informally can contaminate the investigation.

A small investigation team with clearly defined responsibilities is generally preferable.

Employee Interviews Should Be Planned

Interview witnesses separately where appropriate and record accurately what information was obtained.

Questions should seek facts rather than pressure employees into confirming a predetermined theory.

Do Not Force a Confession

Threatening employees or attempting to obtain involuntary statements can create additional legal problems and undermine the credibility of the investigation.

Evidence should be collected lawfully.

Can the Company Search an Employee’s Computer?

The answer depends on the ownership of the device, company policies, reasonable privacy expectations and applicable employment and data-protection rules.

Corporate ownership of a laptop does not mean every type of monitoring is automatically lawful.

Personal Phones Require Particular Caution

A company should not simply seize or search an employee’s private phone without considering the legal basis.

Where important evidence may exist on personal devices, criminal-procedure mechanisms may become relevant.

Preserve Digital Evidence Properly

Relevant emails, access logs, accounting-system records and electronic documents should be preserved in a manner that protects their integrity.

For important digital evidence, metadata and original files may become important later.

WhatsApp Messages Can Become Evidence

Business communications conducted through messaging applications may become relevant if lawfully obtained and connected with the alleged scheme.

Screenshots should be evaluated together with the underlying context and authenticity.

CCTV Footage May Be Relevant

Warehouse or office footage may show deliveries that did—or did not—occur.

Because surveillance systems often overwrite data automatically, potentially relevant recordings should be preserved quickly where legally permitted.

Should the Company File a Criminal Complaint?

Where evidence indicates potential criminal conduct, the company may consider submitting a criminal complaint to the competent authorities.

The complaint should explain the factual scheme clearly and attach organized supporting evidence.

Avoid Filing an Unstructured Document Dump

Submitting thousands of invoices without explaining the suspected mechanism can make a complex financial case harder to understand.

A strong complaint should provide a chronology, identify suspects where supported, explain the suspected transactions and connect each allegation to evidence.

Create a Fraud Transaction Table

A useful investigation table may identify:

date, supplier, invoice, description, amount, approver, receiving account, supporting document and suspected irregularity.

This can make a complex scheme substantially easier for investigators to follow.

Can Bank Accounts Be Frozen?

Depending on the criminal investigation and applicable legal requirements, authorities may consider measures affecting suspected proceeds or assets.

If rapid dissipation of funds is a concern, the timing and evidentiary basis of any requested protective measure can become important.

Can the Company Recover the Money?

Potentially. Recovery strategy may involve criminal proceedings, civil claims, enforcement measures or other asset-protection mechanisms depending on where the funds went and which persons are responsible.

The existence of a criminal investigation does not necessarily mean the company should ignore civil recovery options.

Trace Assets Early

Fraud proceeds can be transferred, spent or converted into other assets.

Bank accounts, vehicles, real estate, company shares and other assets may therefore become relevant to recovery planning where supported by evidence.

Consider Precautionary Measures

Where the legal requirements are satisfied, appropriate interim civil measures may need to be considered to prevent dissipation of assets while the underlying dispute proceeds.

Employment Measures Should Be Coordinated

If employees are implicated, disciplinary and termination decisions should be coordinated with evidence preservation.

Immediately terminating access can protect company systems, but premature action may also alert other participants.

Protect the Company’s Own Position

A foreign parent company should determine whether the suspicious conduct occurred solely through rogue employees or whether weaknesses in management, accounting or tax processes expose the company itself to separate regulatory questions.

An internal remediation plan should begin alongside the criminal case.

Review Directors’ Knowledge

Determine when managers became aware of suspicious transactions and what they did afterward.

Documenting the company’s response can be important in demonstrating that management took reasonable corrective action after discovering the problem.

Notify Auditors Where Appropriate

Material fraudulent payments can affect financial statements and audit processes.

The company should evaluate its obligations concerning internal and external auditors.

Review Insurance Coverage

Crime, fidelity or other relevant insurance policies may potentially cover certain employee or third-party fraud losses depending on policy wording.

Notification deadlines should be checked immediately.

Notify the Foreign Parent Company Carefully

International groups may have internal investigation, compliance and reporting requirements.

Information should be shared through appropriate corporate and legal channels while protecting the integrity of the investigation.

Review Other Suppliers

Discovery of one fake supplier should trigger a targeted review of vendors introduced or approved by the same employees.

Look for common addresses, phone numbers, bank accounts, directors or invoice patterns.

Review Historical Payments

The fraudulent relationship may have existed for years before detection.

Analyze the earliest supplier registration and all subsequent payments rather than limiting the investigation to the most recent invoice.

Determine the Total Loss

Separate genuinely received goods or services from fictitious amounts.

An accurate loss calculation is important for both criminal proceedings and recovery claims.

Foreign Executives May Need to Give Statements

If foreign managers possess relevant knowledge, prosecutors or police may seek their statements.

They should understand whether they are participating as complainants, witnesses or suspects and should obtain appropriate legal assistance before providing formal statements.

Interpreter Rights May Become Relevant

A foreign executive who cannot adequately understand Turkish criminal proceedings should ensure that interpretation is available where required and should not sign a statement they do not understand.

Do Not Destroy Potentially Embarrassing Records

Once fraud is discovered, companies sometimes attempt to “clean up” weak internal controls.

Remediation is appropriate, but historical evidence should be preserved. Deleting problematic records can seriously complicate the company’s legal position.

Immediate Action Plan

When a foreign company discovers fake suppliers or invoices in Turkey, it should immediately secure relevant company systems, preserve emails and accounting records, suspend suspicious payments where legally justified, map the payment trail, identify supplier ownership, compare invoices with actual deliveries, preserve digital evidence, conduct a controlled internal investigation, calculate the loss, evaluate criminal complaint and asset-preservation options, coordinate employment and tax issues, review insurance coverage and strengthen procurement controls.

Frequently Asked Questions

Is an invoice fake simply because the supplier did not deliver the goods?

Not automatically. The complete commercial circumstances must be investigated. However, an invoice intentionally issued for a nonexistent transaction can create serious criminal and tax issues.

Can a legally registered company be a fake supplier?

Yes. The company may legally exist while being used for fictitious or fraudulent transactions.

Should suspected employees be confronted immediately?

Usually evidence should first be secured so that relevant records are not lost or destroyed.

Can company emails be used in a criminal investigation?

Potentially, depending on how the evidence was obtained and the circumstances. Evidence preservation should comply with applicable legal requirements.

Can managers be criminally liable?

Potentially, if evidence establishes their personal participation in criminal conduct. A managerial title alone does not automatically establish criminal responsibility.

Can the company’s lost money be recovered?

Potentially. Criminal proceedings can be combined with an appropriate civil and asset-recovery strategy depending on the circumstances.

Can suspicious bank accounts be frozen?

Protective measures may be available where statutory requirements are satisfied. The evidentiary basis and urgency should be evaluated immediately.

Should the company investigate other suppliers?

Yes. Suppliers connected with the same employees, bank accounts, addresses or approval patterns should be reviewed.

Can foreign directors be questioned in Turkey?

Potentially, where they possess relevant information or become involved in the investigation. Their procedural status should be identified before a formal statement is given.

What should the company do first?

Preserve the evidence before confronting suspected participants. Secure accounting, banking, email, procurement and digital records, reconstruct the payment trail and then build the criminal complaint around verifiable transactions rather than assumptions.

Client-Focused Legal Support for Corporate Fraud Investigations in Turkey

Foreign companies discovering fake suppliers, fictitious invoices or unauthorized payments in Turkey may need coordinated criminal investigation, evidence preservation, asset tracing, interim measures, employment action and financial recovery. Fırat Fesih Kaya Law Office assists foreign investors and international companies in investigating suspected internal and supplier fraud and protecting their interests before Turkish criminal authorities. Lawyer Fırat Fesih Kaya provides legal assistance in preparing criminal complaints, organizing financial and digital evidence, representing foreign executives during criminal proceedings, coordinating asset-recovery measures and pursuing claims against employees, managers, suppliers and other responsible parties.

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