

Money linked to fraud was transferred to your Turkish bank account? Learn when an account holder can be prosecuted, whether receiving money is enough for criminal liability, what evidence prosecutors examine, how frozen accounts and MASAK investigations work, and what foreigners should do.
If money linked to fraud is transferred into your bank account in Turkey, your account may become part of a criminal investigation even if you did not personally communicate with the victim or organize the fraud. This situation is increasingly encountered in investigations involving online shopping fraud, fake investment schemes, cryptocurrency transactions, social-media scams, account-rental arrangements and payments transferred through multiple bank accounts. However, the fact that fraudulent proceeds entered an account registered in your name does not automatically mean that you committed fraud. Criminal responsibility must be assessed according to your actual conduct, knowledge, intent, relationship with the other suspects and what happened to the money after it reached your account. At the same time, Turkish banks and other obliged institutions must report transactions to MASAK where there is information, suspicion or reasonable grounds to suspect that the assets were obtained illegally or are being used for unlawful purposes. (Hazine ve Maliye Bakanlığı)
From the prosecutor’s perspective, the bank account creates an identifiable link in the movement of the allegedly fraudulent money. If a victim says, “I was deceived and sent TRY 250,000 to this IBAN,” investigators can immediately identify the registered account holder. This may result in the account holder being summoned by the police or prosecutor, banking records being obtained and other accounts or transactions being examined. The critical issue, however, is what the account holder actually did and knew.
Suppose a person commits an online investment scam and tells the victim to transfer money to your bank account. If you knowingly provided your account for the scheme and transferred the money to the organizer in exchange for a commission, the circumstances may create serious criminal exposure. But suppose someone legitimately owed you money and unknowingly paid you using funds that had originated from an unrelated fraud. Those situations cannot properly be treated as identical.
Prosecutors generally need to reconstruct the relationship between the account holder and the underlying fraudulent transaction. Relevant questions can include whether you knew the victim, whether you communicated with the victim, whether you knew why the payment was being made, whether you provided your IBAN to another person, whether you received a commission, whether you immediately forwarded the money and whether similar transactions had occurred previously.
A friend tells you: “My bank account isn’t working. Give me your IBAN. Someone will send me money and you can transfer it to me.”
TRY 300,000 arrives.
You immediately transfer TRY 285,000 to another account and keep TRY 15,000.
Several weeks later, police inform you that the original sender was the victim of fraud.
The investigation will likely focus heavily on why your account was used, why you transferred the money onward and why you retained TRY 15,000.
A commission for allowing money to pass through your account can be particularly problematic because prosecutors may ask what legitimate service justified the payment. The existence of a commission does not automatically prove participation in fraud, but it can make an innocent explanation more difficult depending on the surrounding evidence.
That fact can be relevant but is not automatically decisive. Investigators may still examine whether you knowingly assisted another person by providing access to your banking facilities.
The prosecution should not stop at the fact that the IBAN belongs to you. A proper investigation should examine the complete financial and digital evidence surrounding the transaction.
A useful way to understand these investigations is:
Victim → Your Bank Account → Second Account → Cryptocurrency Exchange → Wallet / Cash Withdrawal / Final Recipient
Your position in that chain can materially affect the case.
If the disputed money remained untouched because you did not recognize the sender, that can create a different factual picture from immediately withdrawing or forwarding the funds.
Preserve the bank records showing the return. The timing and recipient of the repayment can be important evidence.
Investigators will want to know why.
The strongest explanation is usually supported by evidence existing before the investigation began.
Suppose another person instructed you through WhatsApp:
“I’m sending customer money to you. Transfer it to this account.”
Those messages can be extremely important to understanding what you knew.
Do not delete them.
A person who genuinely did not understand the fraudulent origin of the money may need those conversations to demonstrate how the transaction was presented to them.
Do not preserve only favorable screenshots. The complete conversation may provide important context.
In serious investigations, digital evidence can become important in determining whether the account holder communicated with the alleged fraud organizer or victim.
Banking records may also help determine which device or connection was used to execute relevant transactions.
This can fundamentally change the factual analysis.
Investigators should determine who actually controlled the account.
Giving another person your mobile banking password, authentication information or telephone access can expose you to significant criminal and financial risk.
Merely saying that another person controlled the account may not be persuasive without supporting evidence.
Relevant evidence can include messages, device information, bank login records and other contemporaneous records.
Unauthorized access should be documented immediately.
Contact the bank and preserve:
login alerts, security notifications, password-change records, unauthorized transfer reports and correspondence with the bank.
Where banking access was obtained through a stolen telephone or compromised SIM card, telecommunications and device evidence may become highly important.
Another common scenario involves allegedly fraudulent sales.
A victim believes they are purchasing a phone, vehicle, machinery or another product and transfers money to your account.
Investigators may examine whether you posted the advertisement, communicated with the buyer, controlled the relevant social-media account and received the economic benefit.
Investment fraud cases frequently involve several intermediary accounts.
Victims may be instructed to transfer funds to different individuals described as “investment representatives,” “payment officers” or “company accountants.”
Account holders can subsequently become suspects.
Money may enter a bank account and then be transferred to a cryptocurrency platform.
That does not automatically establish laundering or fraud, but investigators may attempt to trace the assets further.
Keep exchange account records, transaction history, wallet addresses and transaction identifiers.
Blockchain and exchange records may allow significant portions of the transaction chain to be reconstructed.
Where fraud proceeds are transferred through several accounts or converted into other assets, prosecutors may also investigate whether subsequent transactions create money-laundering issues.
The legal analysis of fraud and laundering should nevertheless remain separate. A person should not automatically be treated as a money launderer merely because criminal proceeds temporarily passed through an account.
MASAK is Turkey’s Financial Crimes Investigation Board. Under Law No. 5549, obliged institutions must report transactions where there is information, suspicion or reasonable grounds to suspect that the relevant assets were illegally obtained or are being used for unlawful purposes. (Hazine ve Maliye Bakanlığı)
Banks report suspicious activity based on a risk and suspicion framework. The reporting mechanism itself is not a criminal conviction.
Law No. 5549 prohibits obliged institutions from disclosing suspicious transaction reporting to the parties to the transaction, subject to the statutory exceptions. (Hazine ve Maliye Bakanlığı)
MASAK updated its suspicious transaction reporting guides in September 2025 based on sector-specific risks and the updated 2025 National Risk Assessment. These updated reporting standards remain relevant to financial institutions assessing transactions in 2026. (Hazine ve Maliye Bakanlığı)
This question must be answered carefully because not every restriction is legally the same.
Your account may be affected by an internal bank compliance measure, a temporary AML-related transaction suspension or a judicial measure connected with a criminal investigation.
Article 19/A of Law No. 5549 permits qualifying transactions suspected of links with money laundering or terrorism financing to be suspended or prevented from being completed for up to seven working days so that the suspicion can be analyzed and, where necessary, transmitted to competent authorities. (Hazine ve Maliye Bakanlığı)
A separate judicial measure may subsequently exist. Therefore, someone whose account remains inaccessible should determine the actual legal basis for the restriction rather than assuming every freeze is governed by the same seven-working-day period.
Where the transfer has been connected with an alleged fraud offense, the public prosecutor may investigate the banking chain and the individuals involved.
Yes. Investigators may examine related transactions to determine whether the disputed transfer was isolated or part of a broader pattern.
Imagine that one fraud victim’s money entered your account once. Compare that with 40 unrelated individuals sending money over several months, followed by immediate transfers to the same third party.
The evidentiary picture is substantially different.
MASAK’s framework specifically requires obliged institutions to assess suspicious transactions, and financial institutions are expected to apply customer due diligence and risk-based controls. (Hazine ve Maliye Bakanlığı)
Potentially, depending on the evidence and the alleged method of fraud.
The prosecution must establish the elements of the offense and your individual involvement. Merely appearing somewhere in the banking chain should not substitute for proving the required criminal conduct.
This can be particularly important.
If you never called, messaged or contacted the victim, that fact may support the defense depending on the overall evidence.
But it is not automatically decisive if prosecutors allege that you knowingly provided financial infrastructure to others committing the fraud.
Investigators may determine how the fraudster obtained your account information.
This can be one of the most important questions.
Commission, fees or unexplained payments may be examined.
The timing can matter.
Identifying the next recipient can help establish your actual role.
Account holders can themselves be victims.
For example, someone may recruit a foreign national for an alleged remote job and say:
“Customers will pay invoices into your account. Transfer the payments to our company and keep 5% as your salary.”
The supposed employer may actually be operating a fraud scheme.
But evidence showing how you were recruited and what you were told can be critical to the defense.
Keep the original advertisement, website, emails and recruitment messages.
Even fraudulent employment documents can show what representations were made to you.
Phone numbers, usernames and email addresses may help investigators identify the actual organizers.
Foreign students, employees, investors and newcomers may be approached because they have Turkish bank accounts but limited knowledge of local banking practices.
Offers such as “Give us your IBAN and earn commission on every transfer” create substantial criminal risk.
Never provide another person with your mobile banking credentials, SIM card or banking authentication.
Do not automatically spend or transfer it.
Contact the bank and document the situation.
Someone may contact you immediately afterward claiming the transfer was accidental and ask you to send the money to a completely different account.
That can place you in the middle of a fraud chain.
Where there is uncertainty about the source of funds, coordination through the bank can create a clearer record than independently transferring the money to an unrelated third-party account.
The strongest defense is usually built from contemporaneous objective evidence: bank statements, transaction descriptions, contracts, invoices, WhatsApp messages, emails, call records where lawfully available, employment documents, cryptocurrency exchange records, accounting records, IP/device evidence and proof showing who ultimately received the money.
For each disputed payment, identify:
Date → Victim/Sender → Amount → Why You Believed It Was Sent → What You Did With It → Next Recipient → Amount You Retained → Supporting Evidence
This can turn a confusing banking file into a comprehensible defense.
8 March 2026: TRY 175,000 received from Person A. You were told it was payment for Company X. 8 March 2026: TRY 175,000 transferred to Company X’s corporate account. Amount retained: TRY 0. Evidence: WhatsApp instructions, employment agreement and bank receipts.
That factual picture is different from retaining a substantial unexplained commission.
Never backdate a loan agreement, invoice or consultancy contract to explain suspicious funds.
A weak but truthful explanation is safer than fabricated evidence.
Produce the original loan agreement, messages and payment history.
Show the original debt and previous transaction records.
Provide the invoice, order, shipping and delivery documentation.
Provide the contract, correspondence and actual work product.
Provide exchange and blockchain records connecting the bank transfer with the actual transaction.
Preserve the purchase agreement, title-related documents and banking records.
Where allegedly fraudulent money entered a Turkish company’s bank account, investigators should determine which person actually controlled the transaction.
A foreign shareholder should not automatically be treated as personally responsible for every transfer through the company account.
Actual authority and conduct matter.
Determine which directors or employees had authority to execute transfers.
Identify who created and approved the transaction.
If a foreign shareholder discovers that a local partner used company accounts for fraudulent transactions, corporate evidence should be secured immediately.
These can show who actually controlled the company’s accounts.
If you are summoned by police after receiving allegedly fraudulent money, first determine whether you are being questioned as a suspect, complainant or witness.
If you do not remember a transfer, review the records rather than inventing an explanation.
A detailed and document-supported chronology can be substantially more useful than simply saying:
“I did nothing wrong.”
A foreign national who does not sufficiently understand Turkish should ensure that criminal proceedings are understood accurately through the applicable interpretation mechanisms.
Statements concerning knowledge of the sender, purpose of payment or onward transfer can become important evidence.
Potentially. Assets allegedly connected with a criminal investigation can become subject to judicial measures where the statutory conditions are satisfied.
This requires examination of the specific order. The scope and legal basis of the restriction should be identified rather than assumed.
Depending on the type of judicial measure and procedural circumstances, legal remedies may be available. The decision itself should be obtained and examined.
Potentially. Restitution and compensation issues can arise separately from the question of your criminal responsibility.
If an offense was committed, repayment does not necessarily erase it.
Depending on the alleged offense and procedural circumstances, restitution can have legal significance and should be assessed strategically rather than undertaken without understanding its consequences.
If dozens of victims sent money into the same account, the investigation becomes substantially more complex.
Do not try to explain 50 transactions through one generic statement.
If all funds were transferred onward to one organizer, demonstrate the pattern with banking records.
Calculate precisely how much money, if any, you retained.
Investigators may also become interested in foreign accounts if money was transferred outside Turkey.
Do not wait until the prosecutor asks.
The commercial purpose and ultimate beneficiary should be documented.
Being investigated does not automatically cancel a foreign national’s residence permit.
Criminal proceedings and immigration measures involve separate legal assessments, although serious criminal allegations or resulting decisions can create immigration consequences depending on the circumstances.
The existence of a disputed bank transfer should not simply be equated with an automatic deportation decision.
A criminal investigation does not itself automatically prevent departure from Turkey.
However, a competent court may impose a prohibition on leaving the country as part of judicial control where statutory conditions are satisfied.
Foreign suspects should determine whether any judicial-control measure exists rather than relying solely on possession of their passport.
Preserve the bank statement, identify the disputed transfer, do not delete messages, determine whether the funds remain in the account and identify any account restriction.
Reconstruct:
Victim → Your Account → Your Action → Next Recipient → Final Known Destination
Collect the evidence explaining each stage.
Determine who provided your IBAN, why you expected the payment, who instructed you to move the funds, whether you retained money and whether similar transfers previously occurred.
Identify the investigation and procedural status before preparing a substantive explanation.
Determine whether the restriction comes from the bank, an AML-related process or a judicial decision.
Secure evidence of that access immediately.
Preserve the advertisement, profile, username and complete conversation.
Export transaction records before access to the account becomes unavailable.
Do not delete their account details simply because they blocked you.
Do not move it around merely to make the banking problem disappear. The legal and factual consequences should first be assessed.
The key question is often not:
“Did fraud money enter my account?”
That may already be established by bank records.
The more important questions are:
Why did it enter your account, what did you believe the transaction was, what did you know about its origin, what did you do with the money and what evidence supports your explanation?
If money connected with fraud enters your bank account in Turkey, the defense should begin with the complete transaction chain rather than a generic denial. Identify the alleged victim, exact amount, transfer date, reason you believed the payment was being made, person who provided your IBAN, person who instructed you regarding the money, subsequent recipient and any amount you retained. Preserve bank statements, messages, contracts, invoices, cryptocurrency records and device-related evidence before anything is deleted or becomes inaccessible. If another person controlled your account, prove the circumstances of that access. If you were yourself deceived into acting as an intermediary, preserve the recruitment messages and representations made to you. A suspicious transaction report or the mere receipt of criminal proceeds does not itself establish that you knowingly participated in fraud. Conversely, knowingly allowing an account to be used to receive and move fraudulent funds can create serious exposure. The practical roadmap is therefore: identify the disputed transfer → preserve the entire bank history → determine why your IBAN was used → establish what you knew before receiving the money → identify who instructed the onward transfer → trace the final recipient → calculate whether you received any benefit → preserve digital communications → document any legitimate underlying transaction → obtain cryptocurrency records where relevant → establish who controlled online banking → determine whether the account is frozen → identify the legal basis of any restriction → prepare a transaction-by-transaction chronology → respond to police or prosecutor proceedings with documentary evidence → evaluate restitution issues carefully → assess immigration and travel consequences separately where relevant.
You can become part of the investigation because the bank account creates a direct financial link to the disputed transaction. However, receipt of the money alone does not automatically establish that you personally committed fraud. Your knowledge, conduct and involvement must be assessed.
That can be central to your defense. Investigators should examine what you believed the payment represented, why your account was used and what evidence supports your explanation.
This can create significant risk. Investigators may examine why the friend could not use their own account, what you were told about the incoming money, where you transferred it and whether you received a commission.
Not automatically, but an unexplained commission can substantially increase suspicion. Prosecutors may examine what legitimate service justified the payment and whether you knew the account was being used as part of a fraudulent scheme.
Different legal mechanisms can affect banking transactions and accounts. Law No. 5549 provides for temporary suspension of qualifying transactions for up to seven working days in specified AML circumstances, while separate judicial measures may also arise in a criminal investigation. (Hazine ve Maliye Bakanlığı)
No. Those messages may be some of the most important evidence showing what you were told and what you knew at the time.
Preserve evidence concerning devices, login information, messages and authorization. The question of who actually controlled and executed the transactions can be critical.
They can make the financial investigation more complex, but cryptocurrency use does not itself prove criminal conduct. Preserve exchange statements, wallet addresses and transaction identifiers so the money trail can be reconstructed.
No. A criminal investigation and immigration status involve separate legal assessments. However, serious criminal proceedings can create separate immigration issues depending on the circumstances.
Identify the exact transaction and your procedural status, preserve your bank and digital records, reconstruct where the money came from and where it went, and avoid deleting communications or creating retrospective documents to explain the transaction.
If money connected with an alleged fraud has entered your Turkish bank account, the investigation may involve fraud allegations, MASAK scrutiny, frozen bank accounts, prosecutor proceedings, cryptocurrency tracing, asset seizure and potentially immigration-related consequences.
Fırat Fesih Kaya Law Office provides legal assistance to foreign nationals, investors, company shareholders and directors whose Turkish bank accounts become involved in fraud and financial-crime investigations.
Fırat Fesih Kaya can assist with police and prosecutor statements, fraud investigations, MASAK-related proceedings, frozen bank accounts, judicial seizure objections, cryptocurrency transaction investigations and related immigration issues.
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