What should foreigners do if accused of money laundering in Turkey? Learn about MASAK investigations, frozen bank accounts, asset seizure, cryptocurrency tracing, prosecutor investigations, defense strategies, travel restrictions and immigration risks.

A foreigner accused of money laundering in Turkey can face a financial and criminal investigation extending far beyond a single suspicious bank transfer. Prosecutors may investigate Turkish and foreign bank accounts, cryptocurrency transactions, company payments, real estate, vehicles, company shares, receivables and other assets while attempting to establish whether particular property originated from criminal activity and whether the suspect knowingly participated in laundering those proceeds. Turkish anti-money-laundering legislation also requires banks and other obliged institutions to report transactions where there is information, suspicion or reasonable grounds to suspect that the assets involved were illegally obtained or are being used for illegal purposes. (Hazine ve Maliye Bakanlığı) However, a MASAK report, unusual international transfer, frozen bank account or possession of unexplained assets does not by itself establish the criminal offense of money laundering. The prosecution must establish the elements of the alleged offense and the individual foreign national’s involvement. For that reason, the defense should focus on the origin of the assets, the underlying transaction, the alleged predicate criminal activity, the suspect’s knowledge and intent, and the documentary trail demonstrating how the money was earned, transferred and used.

What Is Money Laundering Under Turkish Law?

The principal criminal provision concerning laundering criminal proceeds is Article 282 of Turkish Criminal Code No. 5237. Turkey’s AML legislation expressly refers to Article 282 when defining the laundering offense. (Hazine ve Maliye Bakanlığı) In practical terms, a money-laundering investigation generally concerns assets allegedly originating from criminal activity and subsequent conduct intended to place those assets into apparently legitimate economic circulation or otherwise deal with them in circumstances covered by the criminal provision.

The Alleged Criminal Source of the Money Matters

A prosecutor cannot properly analyze a laundering allegation in isolation from the alleged source of the assets. Investigators may therefore seek to establish whether the disputed funds originated from fraud, cybercrime, drug trafficking, smuggling, corruption, illegal betting, organized crime or another qualifying underlying criminal activity.

Example

A foreign investor receives EUR 500,000 from the sale of a company abroad and transfers the money into Turkey to purchase property. The size of the transaction may generate compliance questions, but a large international transfer is not automatically criminal proceeds. If the investor can demonstrate the company sale, ownership, purchase price, foreign tax or corporate records and banking trail, the transaction has a potentially verifiable lawful explanation.

A Different Example

Suppose TRY 5 million obtained from multiple fraud victims moves through several intermediary accounts, enters a foreign national’s account, is immediately converted into cryptocurrency and is subsequently transferred to wallets controlled by the fraud organizers. If evidence shows that the account holder knowingly participated in the arrangement, the criminal exposure can be substantially more serious.

MASAK’s Role in Money Laundering Investigations

MASAK is Turkey’s Financial Crimes Investigation Board. It operates within Turkey’s anti-money-laundering framework and receives suspicious transaction reports from obliged institutions.

Banks Must Report Suspicious Transactions

Article 4 of Law No. 5549 requires obliged parties to report transactions where there is information, suspicion or reasonable grounds for suspicion that the assets involved were obtained illegally or are being used for unlawful purposes. (Hazine ve Maliye Bakanlığı)

A Suspicious Transaction Report Is Not a Conviction

This distinction is extremely important. The reporting threshold is based on suspicion, not proof beyond reasonable doubt.

The Bank Generally Cannot Tell You It Filed an STR

Law No. 5549 restricts disclosure of suspicious transaction reporting to transaction parties. A foreign customer may therefore receive limited information when asking the bank whether MASAK has been notified. (Hazine ve Maliye Bakanlığı)

2026 MASAK Compliance Environment

MASAK updated its suspicious transaction reporting guidance in September 2025 based on sector-specific risks and the updated 2025 National Risk Assessment. Those updated standards remain relevant to financial-sector monitoring and reporting during 2026. (Hazine ve Maliye Bakanlığı)

What Transactions Can Attract Attention?

There is no single transaction automatically proving money laundering. Investigators and compliance departments generally examine the complete financial pattern.

Large International Transfers

A large international payment can be entirely legitimate. The important issue is whether its origin and purpose can be demonstrated.

Multiple Unrelated Senders

Receiving repeated transfers from people with no apparent commercial relationship to the account holder may generate additional questions.

Rapid Movement of Funds

Money entering one account and immediately leaving for several other accounts can cause the account to appear to function as a pass-through account.

Cash Withdrawals

Large cash withdrawals shortly after receiving disputed funds can make the final destination of the money harder to establish.

Cryptocurrency Conversions

Rapid conversion of incoming funds into cryptocurrency may lead investigators to examine exchanges, wallets and subsequent blockchain transactions.

Third-Party Accounts

Using relatives, employees or business associates to receive or transfer money can attract particular scrutiny where the commercial explanation is unclear.

Company Accounts

A foreign shareholder may be investigated where disputed transactions move through a Turkish company that they own or manage.

Property Purchases

Real estate may become relevant where prosecutors suspect that criminal proceeds were converted into property.

Luxury Assets

Vehicles, jewellery, investment products and other valuable assets may similarly become part of the financial analysis.

Does Being Wealthy Create a Money Laundering Risk?

No. Wealth itself is not criminal evidence. The relevant issue is whether prosecutors claim particular assets have an unlawful origin and whether the statutory requirements of the alleged offense are satisfied.

Source of Funds Is Often the Most Important Defense

Foreign nationals should be prepared to document how substantial assets were acquired.

Employment Income

Preserve employment contracts, salary statements, tax records and bank statements.

Business Income

Preserve company records, financial statements, invoices, contracts and dividend documentation.

Company Sale

Preserve the share purchase agreement, corporate records and payment documentation.

Property Sale Abroad

Preserve the sale agreement, ownership records and bank transfer trail.

Inheritance

Preserve probate or inheritance documentation and corresponding banking records.

Investment Income

Brokerage and investment statements may establish the origin of funds.

Loans

Produce the original loan agreement and evidence that the lender actually transferred the funds.

Historical Savings

Long-term bank statements can demonstrate accumulation over several years.

Foreign Documents Can Be Critical

A foreigner’s legitimate wealth may have been accumulated entirely outside Turkey. Foreign banking, corporate, tax and property documents can therefore become central evidence.

Do Not Wait Until the Indictment

Obtaining historical records from foreign banks and companies can take time. Evidence collection should begin as early as possible.

Build a Source-of-Wealth File

For substantial assets, the defense can reconstruct: Original Income/Asset → Acquisition → Sale/Transfer → Foreign Bank Account → International Transfer → Turkish Account → Investment or Purchase.

Example

2019–2024: Business profits accumulated in Germany. 2025: Company shares sold. Sale proceeds: EUR 1.2 million. 2026: EUR 700,000 transferred from the seller’s German account to their Turkish account. Purpose: property and company investment.

Documentary Continuity Matters

The stronger the connection between each stage, the easier it is to distinguish legitimate wealth from unexplained funds.

What Is Asset Seizure in a Money Laundering Investigation?

This is one of the most serious consequences because property can become unavailable before the criminal proceedings have concluded.

Law No. 5549 Article 17

Where there is strong suspicion that money laundering or terrorism financing has been committed, Article 17 of Law No. 5549 permits asset seizure according to the procedure under Article 128 of Criminal Procedure Law No. 5271. (Hazine ve Maliye Bakanlığı)

What Assets Can Potentially Be Affected?

CMK Article 128 covers a broad range of property, including real estate, land/sea/air vehicles, accounts at banks and other financial institutions, rights and receivables, negotiable instruments, company shares, safe-deposit-box contents and other assets where the statutory requirements are satisfied. (Rayp Adalet)

Bank Accounts

This is frequently the first asset noticed by the suspect.

Real Estate

Apartments, land and commercial properties can become subject to seizure measures.

Vehicles

Cars and other vehicles may potentially be included.

Company Shares

A foreign investor’s ownership interest in a Turkish company can potentially fall within the scope of an asset-seizure measure.

Receivables

The statutory framework is not limited to physical property.

Safe Deposit Boxes

Safe-deposit-box contents are expressly among the categories identified under CMK Article 128. (Rayp Adalet)

Cryptocurrency

Where digital assets are allegedly connected with criminal proceeds, cryptocurrency holdings and related accounts can become important targets of financial investigation.

Property Held by Another Person

CMK Article 128 also contemplates seizure of qualifying assets even where the specifically identified property is possessed by someone other than the suspect or accused. (Rayp Adalet)

This Makes Transfers to Relatives Particularly Sensitive

Moving assets into a spouse’s, friend’s or relative’s name after learning of an investigation can create additional suspicion rather than protecting the property.

Do Not Transfer Assets to Avoid Seizure

Attempting to hide property after learning of a financial-crime investigation can seriously complicate the defense.

Emergency Prosecutor Seizure

Law No. 5549 contains a special rule for urgent cases. A public prosecutor may order seizure, but a seizure implemented without a judicial decision must be submitted to the competent judge within 24 hours, and the judge must decide on approval within a further 24 hours. (Hazine ve Maliye Bakanlığı)

The Three-Month Report Requirement

Where the judge approves the prosecutor’s urgent seizure, Law No. 5549 provides that the report concerning the value specified under CMK Article 128 must be obtained within three months and submitted again for judicial approval. If approval is refused or the report is not obtained within the statutory period, the prosecutor’s decision becomes ineffective under the provision. (Hazine ve Maliye Bakanlığı)

This Should Be Checked Carefully in Every Asset-Seizure File

The defense should examine the chronology rather than merely accepting that “MASAK froze everything.”

Who Actually Froze the Account?

This question is fundamental because several different mechanisms can produce what the client experiences as a frozen account.

Internal Bank Compliance Measure

The bank may restrict transactions as part of its compliance process.

AML Transaction Suspension

Law No. 5549 Article 19/A permits qualifying transactions suspected of being linked to laundering or terrorism financing to be suspended or prevented for up to seven working days so that MASAK can verify the suspicion, analyze the transaction and transmit its findings to competent authorities where necessary. (Hazine ve Maliye Bakanlığı)

Judicial Asset Seizure

A prosecutor or court-related measure arising from a criminal investigation is legally different.

Seven Working Days Does Not Mean Every Account Freeze Must End After Seven Days

The Article 19/A mechanism concerns transaction postponement. A separate judicial seizure can operate under a different legal framework.

Therefore Obtain the Actual Decision

The defense should identify the authority, date, legal provision, accounts and assets covered by the measure.

Can All of a Foreigner’s Assets Be Frozen?

The answer depends on the specific order and evidence. The relationship between the alleged criminal proceeds and the property affected by the measure should be carefully examined.

Legitimate Assets Should Be Documented

Suppose prosecutors question TRY 2 million allegedly connected with fraud, while the foreign investor owns property purchased years earlier from documented salary and business income. The lawful origin of the earlier assets should be demonstrated clearly rather than allowing all wealth to be treated as one unexplained pool.

Asset-by-Asset Analysis

Prepare a separate evidence file for every major asset.

Property A

Purchase date, purchase price, payment source and title documentation.

Vehicle B

Purchase invoice and banking records.

Company Shares

Capital contribution records and source of investment.

Bank Account C

Historical statements demonstrating accumulated savings.

Crypto Portfolio

Exchange deposits, purchase history and wallet transactions.

What Is the Difference Between Seizure and Confiscation?

Seizure is generally a protective procedural measure during an investigation or prosecution. Confiscation is a substantive consequence governed by different legal requirements.

Do Not Treat a Frozen Asset as Already Lost

A seizure order does not itself amount to a final criminal conviction.

Challenge the Evidentiary Connection

Where an asset has a demonstrably lawful origin unrelated to the alleged offense, that evidence can be central to seeking modification or lifting of the measure.

Prosecutor’s Investigation

A money-laundering investigation can involve extensive financial evidence.

Bank Records

Authorities may examine incoming and outgoing transfers over an extended period.

Foreign Transfers

Cross-border transfers may be analyzed to determine the original sender and ultimate beneficiary.

Company Records

Invoices, ledgers, contracts and accounting entries may be examined.

Property Records

Investigators may compare declared income with asset purchases.

Cryptocurrency Records

Exchange accounts and blockchain transfers may become important.

Digital Communications

Messages can be used to establish the alleged purpose of transfers and relationships among suspects.

Telephone and Device Evidence

Depending on the investigation and lawful procedural measures, digital evidence can assist in determining who actually controlled particular financial transactions.

Underlying Fraud Investigations

Many laundering allegations arise from fraud investigations.

Example

Victims send money to several intermediary accounts. The money is consolidated in one account and transferred abroad.

The Final Recipient Is Not Automatically the Only Person Investigated

Prosecutors may investigate every significant participant in the transfer chain.

But Every Participant Does Not Automatically Have the Same Criminal Responsibility

The person who organized the fraud, the person who knowingly moved proceeds and the person who unknowingly received one transfer may occupy fundamentally different legal positions.

Knowledge Must Be Examined Individually

This is particularly important in cases involving foreign investors, employees and company directors.

Foreign Company Directors

A foreign director may become a suspect because suspicious transactions passed through the company’s bank account.

Director Status Is Not Automatic Proof

Investigators should establish who actually ordered, approved and executed the transactions.

Internet Banking Access

Identify every person who had banking authority.

Corporate Authorization

Board resolutions, signature circulars and internal authorization rules can be important.

Accounting Department

Determine who prepared the transfers.

Local Business Partner

A foreign investor may have delegated daily financial management to a Turkish partner.

Preserve Evidence of Delegation

Emails, corporate resolutions, banking authority and internal correspondence can help establish the actual division of responsibilities.

Beneficial Ownership

Authorities may investigate whether companies or nominees were used to conceal the person ultimately controlling the assets.

Shell Company Allegations

A company with little genuine commercial activity but substantial financial flows can attract scrutiny.

Prove Real Commercial Activity

Produce employees, premises, contracts, invoices, customers, tax records, delivery documents and operational evidence.

Fake Invoice Allegations

Authorities may suspect that invoices were created merely to provide a commercial explanation for transfers.

Invoice Alone Is Not Enough

Demonstrate the underlying transaction.

Goods

Provide orders, transportation documents, customs declarations and delivery evidence.

Services

Provide work product, reports, correspondence and evidence of actual performance.

Cryptocurrency and Money Laundering

Cryptocurrency frequently appears in modern financial investigations because assets can move rapidly across platforms and wallets.

Cryptocurrency Is Not Automatically Criminal

The use of cryptocurrency does not itself establish money laundering.

Preserve Exchange Records

Export transaction history while access remains available.

Preserve Wallet Addresses

Record the relevant addresses and transaction identifiers.

Connect Fiat and Crypto Transactions

Build the chain: Bank Deposit → Exchange → Cryptocurrency Purchase → Wallet Transfer → Subsequent Transaction.

Blockchain Evidence Can Help the Defense

If prosecutors assume that cryptocurrency disappeared into an unknown destination, transaction records may demonstrate where it actually went.

Foreign Cryptocurrency Exchanges

Account records from foreign platforms may also become important.

Cash-Based Businesses

Cash-intensive businesses can face difficulties proving the origin of funds if accounting records are weak.

Accounting Consistency Matters

Bank deposits, invoices, tax declarations and business records should broadly correspond.

Do Not Manufacture Records Afterward

Backdated invoices or contracts can create significantly greater criminal exposure.

False Consultancy Agreements

Creating a fictitious consulting contract to explain an unexplained transfer is particularly dangerous.

Use the Real Explanation

If the money was a family loan, prove the family loan. If it was investment capital, prove the investment. If it was a property-sale payment, prove the property transaction.

Foreign Family Transfers

Foreign nationals often receive substantial support from relatives abroad.

Document the Sender’s Source

For significant amounts, evidence concerning the family member’s ability to make the transfer can strengthen the explanation.

Informal Hawala-Type Arrangements

Informal settlement systems can create significant evidentiary difficulties because the banking record may not reflect the actual economic relationship between sender and beneficiary.

Do Not Give a Simplified False Explanation

Reconstruct the genuine transaction carefully.

Money Received for Another Person

Law No. 5549 also contains a specific provision concerning persons acting in their own name but for another person’s benefit in transactions requiring customer identification. Failure to make the required written disclosure can itself have criminal consequences under Article 15. (Hazine ve Maliye Bakanlığı)

“I Was Only Helping a Friend” Is Therefore Not a Risk-Free Arrangement

Foreigners should avoid allowing other persons to use their bank accounts to conceal the actual beneficiary.

Can the Police Search a Foreigner’s Home or Office?

Financial investigations can involve searches where the procedural requirements are satisfied.

Computers and Phones

Digital devices can contain important financial and communications evidence.

Do Not Delete Evidence

Deleting financial records or communications after learning of the investigation can undermine the defense.

Preserve Original Files

Original emails, spreadsheets, contracts and transaction exports are generally more useful than newly created summaries.

Police or Prosecutor Statement

Foreign suspects should determine the precise allegation before giving a detailed explanation.

Do Not Guess

If you do not remember the purpose of a five-year-old transaction, review the records before giving an inaccurate explanation.

Interpreter

A foreign national who cannot adequately understand Turkish should ensure that the proceedings and statement are properly understood.

Defense Counsel

Complex laundering investigations often involve thousands of financial transactions. The defense should therefore be based on a structured financial analysis rather than only a verbal denial.

Build a Transaction Matrix

For each questioned transfer record: Date → Sender → Amount → Source → Commercial/Personal Purpose → Recipient → Supporting Evidence → Ultimate Destination.

Then Build an Asset Matrix

For each seized asset record: Asset → Acquisition Date → Purchase Price → Funding Source → Supporting Documents → Alleged Connection to Crime.

This Separates Legitimate Wealth From Disputed Funds

Without this structure, a complex financial file can incorrectly make all of a foreign national’s wealth appear suspicious.

International Cooperation

Money-laundering investigations can involve transactions and evidence located outside Turkey. Foreign bank records, corporate registries and other international evidence may therefore become relevant.

Do Not Assume Foreign Assets Are Invisible

International financial investigations can extend beyond Turkish accounts.

Likewise, Foreign Evidence Can Help the Defense

The same cross-border documentation that investigators use can demonstrate lawful wealth.

Travel Restrictions

A money-laundering investigation does not automatically mean that a foreign suspect cannot leave Turkey.

Judicial Control

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

Check Before Traveling

Do not assume that possession of a passport means no restriction exists.

Residence Permit and Deportation

A money-laundering investigation does not automatically cancel every foreigner’s residence permit or automatically result in deportation. Criminal proceedings and immigration measures require separate legal analysis.

But Immigration Risk Should Not Be Ignored

Serious criminal allegations can potentially intersect with public-order and immigration assessments.

Criminal and Immigration Strategies Should Be Coordinated

A foreign suspect should therefore monitor both proceedings where relevant.

What If the Foreigner Is Innocent but Their Business Partner Laundered Money?

Immediately preserve evidence showing the actual division of responsibilities.

Banking Authority

Who controlled the account?

Payment Instructions

Who ordered the transfers?

Commercial Communications

Who negotiated the suspicious transactions?

Financial Benefit

Who ultimately received the money?

Corporate Governance

Did the foreign shareholder object when the transactions were discovered?

Do Not Secretly Remove Company Assets

That can complicate both the shareholder dispute and criminal investigation.

What If the Account Was Used Without Permission?

Report unauthorized access promptly and preserve bank security records.

IP and Device Records

These can help identify who executed transactions.

Authentication Records

SMS, mobile approval and device records may also become relevant.

What If the Foreign National Was Used as a Money Mule?

People can be recruited through fake employment, cryptocurrency trading, investment or payment-processing opportunities.

Typical Scenario

“You will receive client money. Forward 95% and keep 5% as your commission.”

This Is Extremely High Risk

The arrangement can place the account holder directly in the flow of criminal proceeds.

Preserve Recruitment Evidence

If you were deceived, keep advertisements, messages, contracts, usernames and payment instructions.

First 24 Hours After Learning of the Investigation

Determine the investigation number and procedural status, identify which accounts or assets have been restricted, obtain available decisions, preserve bank and cryptocurrency records and stop deleting or modifying relevant financial information.

First 48 Hours

Prepare two maps: money flow and asset ownership.

Money Flow

Original Source → Intermediary → Your Account → Subsequent Recipient → Final Known Beneficiary

Asset Ownership

Asset → Purchase Date → Purchase Funds → Current Status → Seizure Decision

First 72 Hours

Collect foreign and Turkish bank statements, contracts, invoices, company records, tax documentation, property records, cryptocurrency history and relevant communications.

If Assets Have Already Been Seized

Identify the legal basis, authority, decision date and exact scope.

Check the 24-Hour Judicial Approval Requirement Where Applicable

For an urgent prosecutor seizure under Article 17 of Law No. 5549, the statutory judicial approval chronology should be examined carefully. (Hazine ve Maliye Bakanlığı)

Check the Report Requirement

Where applicable under that procedure, examine whether the required CMK Article 128 valuation report and subsequent approval requirements were satisfied. (Hazine ve Maliye Bakanlığı)

Challenge Assets With Demonstrably Lawful Origins

Do not treat all seized property as one category.

If the Account Contains Mixed Funds

Separate documented salary, business income or other lawful funds from the transactions alleged to constitute criminal proceeds.

If Company Operations Are Paralyzed

Document salaries, taxes, suppliers and ordinary business obligations affected by the restriction. The proportionality and scope of the measure may require examination in the specific proceeding.

Do Not Transfer Remaining Assets to Relatives

This can create additional suspicion.

Do Not Create New Contracts

Use contemporaneous evidence.

Do Not Coordinate False Statements With Other Suspects

Independent and truthful reconstruction is essential.

Do Not Contact Alleged Victims to Influence Their Statements

This can create separate procedural problems.

Do Not Assume MASAK Is the Prosecutor

Identify which institution took each action.

Do Not Assume Every Freeze Is Permanent

Determine the precise legal measure.

Do Not Assume Seizure Equals Confiscation

A protective measure is not the same as a final judgment.

2026 Defense Strategy for Foreigners Accused of Money Laundering in Turkey

A foreign national facing a money-laundering investigation in Turkey should build the defense around the origin, movement and ultimate destination of the disputed assets. The alleged predicate crime should first be identified because suspicious wealth alone does not explain what criminal proceeds the prosecution says were laundered. Every significant transaction should then be reconstructed using Turkish and foreign bank statements, corporate records, contracts, invoices, tax documentation, cryptocurrency records and contemporaneous communications. Where assets have been seized, each asset should be analyzed separately according to its acquisition date, purchase price, source of funds and alleged connection with the offense. The defense should distinguish a temporary transaction suspension under Law No. 5549 from a judicial asset-seizure measure and examine whether the applicable procedural requirements were satisfied. Company directors and foreign shareholders should establish who actually controlled banking operations rather than allowing corporate title alone to substitute for proof of individual involvement. Where cryptocurrency is involved, the fiat-to-crypto transaction chain should be reconstructed rather than treated as untraceable. Where legitimate wealth originated abroad, foreign banking, corporate and tax documentation should be collected immediately. The practical roadmap is therefore: identify the alleged predicate crime → determine the exact laundering allegation → obtain the investigation and seizure decisions → identify who imposed each restriction → reconstruct the source of funds → trace every disputed transfer → identify ultimate beneficiaries → document legitimate foreign wealth → map cryptocurrency transactions → determine actual control of company accounts → separate legitimate assets from disputed proceeds → examine the scope and proportionality of seizure → verify statutory approval requirements → challenge unsupported asset restrictions → preserve digital evidence → prepare transaction and asset matrices → address police and prosecutor statements carefully → monitor travel restrictions → evaluate immigration consequences separately → maintain the evidence file until the criminal proceedings are finally resolved.

Frequently Asked Questions

1. Can a foreigner be prosecuted for money laundering in Turkey because of a suspicious bank transfer?

Potentially, but a suspicious or unusually large transfer alone does not establish money laundering. Prosecutors must examine the alleged criminal origin of the assets and the foreign national’s individual conduct under the applicable criminal-law requirements.

2. Does a MASAK report mean I am guilty of money laundering?

No. Law No. 5549 requires obliged institutions to report transactions where the statutory suspicion threshold is met. Suspicious transaction reporting is a preventive AML mechanism, not a criminal conviction. (Hazine ve Maliye Bakanlığı)

3. Can my Turkish bank accounts be seized during a money-laundering investigation?

Potentially. Law No. 5549 Article 17 permits asset seizure in qualifying money-laundering cases through the procedure connected with CMK Article 128. Bank accounts are among the categories of assets covered by Article 128. (Hazine ve Maliye Bakanlığı)

4. Can Turkish authorities seize real estate and company shares?

Potentially, where the statutory conditions are satisfied. CMK Article 128 covers real estate, vehicles, financial accounts, rights and receivables, company shares, safe-deposit-box contents and other specified assets. (Rayp Adalet)

5. Can a prosecutor freeze assets without first obtaining a judge’s decision?

Law No. 5549 Article 17 permits a prosecutor to order seizure in urgent circumstances, subject to statutory judicial approval requirements. A seizure implemented without a prior judicial decision must be submitted to the competent judge within 24 hours, and the judge must rule within a further 24 hours. (Hazine ve Maliye Bakanlığı)

6. Is every “MASAK freeze” limited to seven working days?

No. Article 19/A provides a specific transaction-postponement mechanism of up to seven working days. A separate judicial seizure measure can have a different legal basis and duration. (Hazine ve Maliye Bakanlığı)

7. Can cryptocurrency be investigated in a Turkish money-laundering case?

Yes. Cryptocurrency transactions can form part of the financial investigation. Exchange histories, wallet addresses, transaction identifiers and the corresponding bank transfers should be preserved.

8. Can a foreign company director be prosecuted because suspicious money passed through the company account?

Potentially, but director status alone should not substitute for proof of personal criminal involvement. Banking authority, payment instructions, knowledge, communications and the individual’s actual role should be examined.

9. Does a money-laundering investigation automatically lead to deportation from Turkey?

No. Criminal proceedings and immigration measures require separate legal analysis. However, serious criminal allegations can potentially create immigration consequences depending on the individual circumstances.

10. What is the most important evidence for defending a money-laundering allegation?

Evidence establishing the lawful source and actual movement of funds is often crucial. This can include Turkish and foreign bank statements, tax records, contracts, invoices, company-sale documents, inheritance records, property-sale documents, corporate records, cryptocurrency histories and contemporaneous communications.

Legal Support for Foreigners Accused of Money Laundering in Turkey

Foreign nationals facing money-laundering allegations in Turkey may simultaneously confront MASAK scrutiny, frozen bank accounts, seizure of real estate and company shares, cryptocurrency investigations, prosecutor proceedings, travel restrictions and potential immigration consequences.

Fırat Fesih Kaya Law Office provides legal assistance to foreign nationals, foreign investors, shareholders, company directors and international businesses facing financial-crime investigations in Turkey.

Fırat Fesih Kaya can assist with money-laundering investigations, MASAK-related proceedings, bank-account freezes, asset-seizure objections, cryptocurrency investigations, source-of-funds evidence, police and prosecutor statements and related immigration proceedings.

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