

Can you be prosecuted for allowing someone else to use your bank account in Turkey? Learn about IBAN fraud, money mule schemes, fraud-linked transfers, MASAK investigations, frozen accounts and criminal liability for foreigners.
Allowing another person to use your bank account, IBAN or mobile banking facilities in Turkey may appear harmless, particularly when the request comes from a friend, relative, employer, business partner or someone claiming that their own account is temporarily unavailable. In criminal investigations, however, this type of arrangement can create substantial legal risk. If money obtained through online fraud, fake investment schemes, illegal betting, cryptocurrency fraud or another alleged offense is transferred into your account, banking records will initially identify you as the account holder who received the funds. This does not automatically prove that you committed fraud or knowingly participated in criminal activity. Criminal responsibility must be assessed according to the alleged offense, your knowledge and intent, why the account was provided, what you were told about the incoming payment, what happened to the money afterward and whether you received any financial benefit. Nevertheless, allowing an account to function as an intermediary account can expose both Turkish citizens and foreigners to police questioning, prosecutor investigations, MASAK-related financial scrutiny, account restrictions and potentially serious criminal allegations.
There is an important distinction between an ordinary legitimate transaction carried out for another person and knowingly making your bank account available as part of unlawful financial activity. Criminal liability does not automatically arise merely because you received money connected with someone else. However, the circumstances can become significantly more serious if you knew that the account would be used to receive fraudulent or criminal proceeds, deliberately assisted the movement of those funds, received payment for providing the account or continued allowing suspicious transactions after becoming aware of their nature.
An IBAN directly identifies the account receiving the money. If a fraud victim tells the prosecutor, “I was deceived and transferred TRY 300,000 to this account,” investigators can quickly identify the registered account holder. Even where another person actually organized the fraud, the account holder may become one of the first identifiable individuals in the financial chain.
Someone tells you: “My account is temporarily blocked. Give me your IBAN. A customer will send TRY 200,000. When it arrives, transfer it to another account.”
The money arrives and you follow the instructions.
Several days later, you discover that the sender was allegedly deceived through an online investment scheme.
The investigation may then reconstruct the transaction as Fraud Victim → Your Bank Account → Third-Party Account → Cryptocurrency/Cash/Another Account. Your explanation of why you became part of that chain can become critical.
No. Bank-account ownership is important evidence, but it does not automatically establish participation in the underlying fraud. Investigators should examine your actual role rather than assuming that every account holder in the transaction chain committed the same offense.
This is often one of the most important questions. Messages, emails and conversations existing before the transfer may demonstrate what the person requesting your account told you.
Investigators may ask why someone conducting a legitimate transaction could not receive the money into their own account. Explanations such as “their banking limit was reached,” “their account was blocked,” or “they did not have a Turkish bank account” may require further examination.
If you had no relationship with the sender, investigators may ask why a stranger was transferring a substantial amount into your account.
A legitimate explanation should generally correspond with the surrounding evidence.
Rapid onward transfers can attract particular attention because they may make an account appear to function merely as a pass-through account.
This can materially increase criminal risk. Suppose TRY 500,000 enters your account, you transfer TRY 475,000 to another person and retain TRY 25,000. Investigators will likely ask what legitimate service justified the TRY 25,000 payment.
Nevertheless, receiving money merely for allowing funds to pass through your bank account can be highly problematic, particularly where there is no genuine commercial explanation.
A “money mule” is commonly understood as a person whose account is used to receive and transfer funds connected with unlawful activity. Some participants knowingly assist criminal schemes, while others are recruited through fake employment, investment or payment-processing opportunities without initially understanding the true purpose.
Foreign students, employees, temporary residents and newcomers to Turkey may be approached because they possess Turkish bank accounts but may be unfamiliar with local banking and criminal procedures.
A person may receive an online employment offer stating: “You will work as our payment representative. Customers will send money to your account. Transfer 90% to our company and keep 10% as your salary.”
If those “customers” are actually fraud victims, the supposed employee may quickly become a suspect.
If you genuinely believed that you were performing legitimate employment, preserve the advertisement, application, employment documents and recruitment communications.
These communications may help establish what you were told before the transactions occurred.
Deleting the conversation can eliminate evidence that might otherwise support your explanation.
Preserve original communications wherever possible rather than creating selected or altered screenshots.
One disputed transfer is different from an account receiving money from 30 unrelated individuals over several months.
Investigators may examine whether money repeatedly entered the account and was transferred onward according to the same pattern.
During three months, 22 unrelated people transfer money into your account. Almost every payment is transferred within 30 minutes to the same third party. You retain approximately 5% of each payment.
Even if you never personally communicated with the original senders, prosecutors may investigate whether you knowingly provided your account as part of an organized payment mechanism.
Bank accounts are frequently investigated where victims believe they are paying for products advertised online but the goods are never delivered.
Investigators may examine who controlled the website or social-media account.
Telephone and digital communications may become important.
Following the money after it entered your account can help identify who actually benefited.
Investment schemes can involve numerous intermediary bank accounts. Victims may be told that the accounts belong to “investment consultants,” “financial departments” or “authorized payment representatives.”
Funds received into a personal account may subsequently be converted into cryptocurrency and transferred to another wallet.
However, the financial chain should be reconstructed carefully.
Relevant records may include exchange transaction histories, wallet addresses, transaction identifiers and records connecting bank deposits with cryptocurrency purchases.
The evidence should ideally show Bank Transfer → Cryptocurrency Exchange → Purchase → Wallet → Subsequent Transfer → Final Known Destination.
Bank accounts can also become involved in investigations concerning alleged illegal betting payment networks. Allowing an account to receive and distribute money for other persons can create substantial risk where the account is allegedly part of a payment structure.
The investigation may concern the use of the bank account to process or transfer funds rather than personal betting activity.
Where prosecutors believe funds originated from criminal activity and were subsequently transferred, converted or moved through intermediary accounts, the investigation may also examine possible money-laundering issues under Article 282 of the Turkish Criminal Code.
The legal requirements of the alleged offense must still be established. The fact that criminal proceeds temporarily passed through an account does not, without more, prove every element of a laundering offense.
Investigators may attempt to identify whether the money originated from fraud, cybercrime, illegal betting, smuggling or another alleged criminal activity.
Banks and other obliged institutions in Turkey operate under anti-money-laundering rules requiring suspicious transactions to be reported when the statutory suspicion criteria are satisfied. Consequently, an account repeatedly receiving unexplained third-party transfers can become subject to enhanced financial scrutiny.
Suspicious transaction reporting operates on the basis of suspicion. It is not equivalent to a criminal conviction.
Generally, account holders should not expect the bank to disclose whether a suspicious transaction report was submitted because the AML framework restricts disclosure of such reporting.
Potentially. However, it is important to distinguish several different situations.
A bank may restrict transactions while conducting compliance and customer due diligence procedures.
Turkey’s AML legislation provides a specific mechanism for temporary suspension of qualifying transactions where the statutory requirements are satisfied.
A prosecutor investigation can separately result in judicial measures affecting bank accounts where the applicable criminal-procedure requirements are met.
The legal remedy depends on who imposed the restriction and under which legal provision.
If your account becomes inaccessible, identify whether the restriction originates from the bank or from a prosecutor or judicial decision.
Where criminal proceedings exist, determining the investigation file and the questioned transactions is an important part of preparing the defense.
Giving someone an IBAN does not automatically establish criminal responsibility. The investigation should determine why it was provided and what you knew about the intended transaction.
This creates considerably greater risk because the other person may be able to execute transactions in your name.
Giving another person passwords, authentication codes or unrestricted mobile banking access can make it substantially more difficult to establish who actually executed particular transactions.
Objective evidence becomes critical.
Device and access records may help establish who conducted transactions.
Mobile approvals and security records can become relevant.
These may establish that another person requested and controlled the transactions.
Unauthorized access presents a different factual situation. The account holder should preserve evidence showing when the unauthorized activity was discovered and what was reported to the bank.
A contemporaneous objection can be considerably more persuasive than claiming unauthorized access only after a criminal investigation begins.
Turkey’s AML legislation also contains specific rules concerning a person who conducts transactions in their own name but for the benefit of another person in circumstances subject to customer-identification requirements. This means that deliberately concealing the person for whose benefit a transaction is actually being conducted can create additional legal risk.
The precise circumstances must be analyzed. Why did the friend require another person’s account? What was the economic transaction? Who owned the money? Who ultimately received it?
Allowing a spouse, sibling or parent to receive a legitimate payment through your account does not automatically constitute a crime. Nevertheless, substantial or unusual transactions should have a clear and provable explanation.
Business partners should generally avoid mixing personal and company accounts.
Receiving corporate customer payments into a director’s or shareholder’s personal account can create accounting, tax, corporate and potentially criminal complications depending on the circumstances.
The reverse arrangement can create similar evidentiary problems.
Contracts, invoices, accounting records and bank transfers should correspond with the actual parties to the transaction wherever possible.
A foreign resident in Turkey may be asked to receive money because another foreigner does not have a Turkish bank account.
Before becoming an intermediary, consider why the sender cannot pay the actual beneficiary directly.
A legitimate international transfer should have a genuine economic explanation supported by banking and contractual evidence where appropriate.
Informal arrangements where one person receives money in Turkey while another settles the equivalent amount abroad can create significant source-of-funds and beneficiary-identification problems.
If the transaction was genuinely a personal loan, explain and document the loan. If it was payment for goods, document the sale. If it was family support, establish that relationship.
Producing a fictitious commercial document to explain suspicious money can make the legal situation considerably worse.
Contemporaneous evidence is much stronger than documents produced after police contact.
Bank statements, messages, emails, contracts, invoices, employment records, cryptocurrency transaction histories, device information and evidence identifying the actual beneficiary may all become important depending on the facts.
What you were told before receiving the money can help establish your actual knowledge.
For each questioned payment establish Date → Sender → Amount → Why Money Entered Your Account → What You Were Told → What You Did → Next Recipient → Amount Retained → Supporting Evidence.
If you transferred the money onward, establish who ultimately received it.
A useful defense analysis may reconstruct Alleged Victim → Your Account → Second Account → Third Account/Crypto Exchange → Final Beneficiary.
The person organizing the underlying fraud may have a very different role from an intermediary who genuinely did not understand what was happening.
Investigators may examine whether you retained any money.
Receiving no benefit does not automatically eliminate criminal exposure, but it can form part of the overall factual analysis.
Preserve the banking evidence showing when, how and to whom the money was returned.
If an unknown sender says, “I transferred accidentally; send it to my friend’s account instead,” following those instructions can create additional problems. Where the source is uncertain, dealing with the matter through the bank can provide a clearer documentary record.
Do not move it merely because you are worried about an investigation. The circumstances should first be assessed carefully.
A sudden international transfer after learning of a criminal complaint can create additional suspicion.
Attempting to make funds harder to trace can significantly worsen the evidentiary position.
Cash withdrawals can make the ultimate destination harder to establish.
If police contact you regarding money transferred through your account, determine whether you are being questioned as a witness or suspect and identify the relevant transaction before preparing a detailed explanation.
Banking investigations can concern transactions from months or years earlier. Review the records.
A structured explanation supported by documents can be substantially stronger than merely stating, “The money was not mine.”
A foreigner who cannot adequately understand Turkish should ensure that the proceedings and any statement are properly understood.
Precise statements about why you provided the account, what you knew and where the money went can become important evidence.
Potentially. Where investigators believe the questioned transaction forms part of a wider financial network, other banking activity may become relevant.
Investigators may search for recurring patterns demonstrating whether the questioned transfer was isolated or part of ongoing activity.
Where a criminal investigation develops and the statutory requirements are satisfied, judicial measures can potentially affect assets connected with the investigation.
A procedural seizure or restriction does not itself mean that ownership has been permanently lost.
Potentially. The available remedy depends on the legal basis, authority issuing the decision and procedural stage. The actual decision should therefore be obtained and examined rather than relying solely on what a bank employee says.
Restitution and compensation issues can arise independently from the account holder’s criminal responsibility.
Where criminal conduct is alleged, repayment does not automatically terminate the investigation. Nevertheless, restitution may have legal significance depending on the alleged offense and procedural circumstances.
For foreigners, a banking investigation and immigration status should be treated as separate legal issues. The mere fact that another person’s money entered your account does not automatically cancel a residence permit.
Where the matter develops into significant criminal allegations, immigration consequences may need to be assessed independently.
No. A bank-account investigation should not be equated with an automatic deportation decision.
The existence of an investigation does not automatically create a travel ban.
A competent court may impose a prohibition on leaving Turkey where the applicable requirements for judicial control are satisfied.
Preserve complete bank statements, identify the disputed transaction, save all communications with the person who requested use of the account and determine whether the funds remain in your account.
Reconstruct the complete financial chain and identify who ultimately received the money.
Collect messages, contracts, invoices, employment documents, cryptocurrency records and evidence showing who controlled mobile banking.
Determine whether the restriction originates from bank compliance procedures or a criminal-procedure decision.
Identify the relevant investigation and your procedural status.
Preserve everything showing how that person represented the transaction to you.
Identify exactly why it was paid and whether there was any genuine underlying service.
Prepare a separate explanation and documentary record for every transaction rather than relying on one general statement.
Preserve technical and communications evidence capable of demonstrating actual control.
Immediately preserve exchange histories, wallet addresses and transaction identifiers.
A person whose Turkish bank account has been used to receive or transfer money for someone else should build the defense around knowledge, control, purpose and financial benefit. The investigation should establish why the account was provided, what the account holder was told before the transfer, whether the sender was known, who instructed the onward movement of money, who actually controlled mobile banking and who ultimately received the economic benefit. Where the account holder was recruited through a fake job or deceived by a friend or business partner, contemporaneous messages can be essential evidence. Where fraud-linked funds entered the account, the entire transaction chain should be reconstructed rather than treating account ownership as automatic proof of participation. Cryptocurrency transactions should be supported with exchange and blockchain records. Repeated transactions, commissions and rapid onward transfers require particularly careful analysis because they can create a stronger appearance that the account was deliberately being used as a financial intermediary. The practical roadmap is therefore: identify every disputed transfer → establish why your account was used → preserve pre-transfer communications → identify what you knew about the money → establish who controlled the account → trace the funds to the next recipient → identify the ultimate beneficiary → calculate any commission or financial benefit → preserve banking and cryptocurrency records → document any legitimate underlying transaction → determine whether an STR or criminal investigation exists → identify the legal basis of any account restriction → prepare a transaction-by-transaction defense → challenge unsupported assumptions concerning knowledge and intent → evaluate restitution issues → monitor any judicial travel restriction → assess immigration consequences separately where necessary.
Potentially, depending on what the account was used for and what you knew. Simply providing an IBAN does not automatically establish criminal liability, but knowingly allowing the account to receive or transfer criminal proceeds can create serious exposure.
Your knowledge can be central to the defense. Messages, transaction history and evidence showing what you were told before receiving the money may help establish your actual understanding of the transaction.
The fact that the money entered your account is important evidence, but it does not by itself answer whether you knowingly participated in the underlying offense. Your individual conduct and the requirements of the alleged offense must be established.
Providing an IBAN alone does not automatically constitute a crime. However, if the account is subsequently used for suspicious transactions, investigators may examine why you provided it and what you knew about its intended use.
A commission can materially increase suspicion because investigators may ask what legitimate service justified the payment. It does not automatically establish guilt, but it can become important evidence.
Potentially. A bank compliance restriction or a judicial measure may affect the account depending on the circumstances. The precise legal basis of the restriction should be identified.
Preserve banking security records, device information, messages and evidence showing when you discovered and reported the unauthorized activity. Actual control of the account can be highly important.
No. Those communications may be crucial evidence showing what you were told, what you knew and who actually directed the transactions.
A criminal investigation does not automatically result in deportation. Criminal and immigration proceedings involve separate legal assessments, although serious criminal allegations can potentially create immigration consequences.
Identify the questioned transaction and your procedural status, preserve all banking and communication records, reconstruct the complete movement of the funds and avoid deleting evidence or creating retrospective documents to explain the transaction.
Allowing another person to use a Turkish bank account can result in fraud allegations, money-mule investigations, MASAK scrutiny, frozen bank accounts, money-laundering allegations, cryptocurrency tracing and prosecutor proceedings, particularly where the funds originate from alleged fraud victims.
Fırat Fesih Kaya Law Office provides legal assistance to foreign nationals, investors, company directors and other account holders whose Turkish bank accounts or IBANs have become involved in criminal investigations.
Fırat Fesih Kaya can assist with fraud and money-laundering investigations, MASAK-related proceedings, frozen bank accounts, police and prosecutor statements, account-use allegations, cryptocurrency transactions, judicial seizure objections and related immigration matters.
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