Learn how compliance investigations by Turkish prosecutors affect foreign companies. Understand criminal procedures, corporate liability, evidence collection, executive risks, and compliance strategies in Turkey under the 2026 legal framework.

Foreign investors and multinational corporations increasingly conduct business in Turkey, making regulatory compliance more important than ever. Corporate investigations initiated by Turkish Public Prosecutors may arise from allegations involving customs violations, corruption, money laundering, tax offences, sanctions compliance, fraud, competition issues, environmental crimes, workplace accidents, or other corporate misconduct.

Although many compliance failures initially appear administrative, prosecutors may open criminal investigations where evidence suggests that a criminal offence has been committed. Recent developments continue to highlight greater scrutiny of corporate governance, compliance systems, and executive accountability. International organizations have also called for stronger corporate enforcement and anti-bribery mechanisms in Türkiye.

This guide explains what foreign companies should expect during criminal compliance investigations in Turkey and how businesses can minimize legal risks.

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What Is a Compliance Investigation?

A compliance investigation is a criminal inquiry conducted by prosecutors to determine whether individuals or companies have violated Turkish criminal legislation.

Investigations commonly involve:

• Corporate fraud
• Customs offences
• Money laundering
• Commercial bribery
• False accounting
• Tax-related offences
• Environmental crimes
• Workplace fatalities
• Data protection violations
• Export control issues

Not every compliance failure results in criminal prosecution, but serious violations may trigger extensive investigations.

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How Do Turkish Prosecutors Start an Investigation?

Investigations may begin through:

• Complaints filed by individuals
• Police reports
• Customs inspections
• Financial intelligence reports
• Banking notifications
• Tax authority findings
• Competition authority referrals
• Regulatory inspections
• International cooperation requests
• Whistleblower reports

Once sufficient suspicion exists, prosecutors may formally initiate criminal proceedings.

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Industries Frequently Investigated

Foreign businesses operating in Turkey commonly face compliance risks in sectors such as:

• Manufacturing
• International trade
• Energy
• Construction
• Pharmaceuticals
• Banking
• Financial technology
• Logistics
• Mining
• Healthcare
• Defense
• Technology

Higher-risk industries generally receive increased regulatory scrutiny.

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Corporate Documents Prosecutors May Request

During investigations, authorities may obtain:

• Commercial contracts
• Accounting records
• Bank statements
• Customs declarations
• Import and export documentation
• Internal emails
• Board resolutions
• Compliance manuals
• Employee communications
• Supplier agreements
• Customer files
• Digital records

Failure to preserve records may complicate a company’s legal position.

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Digital Evidence

Modern investigations rely heavily on electronic evidence.

Authorities may examine:

• Email servers
• Cloud storage
• Company laptops
• Mobile phones
• ERP systems
• Accounting software
• Messaging applications
• Digital signatures
• CCTV footage
• Internal databases

Digital evidence often becomes central to corporate criminal investigations.

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Interviews of Employees

Prosecutors may question:

• Directors
• Senior managers
• Finance officers
• Compliance officers
• Customs specialists
• Human resources personnel
• Operational managers
• External consultants

Witnesses and suspects have different procedural rights under Turkish criminal procedure.

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Can Foreign Directors Be Investigated?

Yes.

Foreign nationals serving as directors, board members, shareholders, or executives may become subjects of criminal investigations if prosecutors believe they participated in or authorized unlawful activities.

Personal liability depends upon:

• Decision-making authority
• Knowledge
• Intent
• Actual involvement
• Documentary evidence

Corporate position alone does not automatically establish criminal responsibility.

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Search and Seizure Measures

Where authorized under Turkish law, investigators may conduct:

• Office searches
• Warehouse inspections
• Factory searches
• Computer examinations
• Document seizures
• Electronic data imaging
• Asset preservation measures

Searches generally require compliance with procedural safeguards established under Turkish criminal procedure.

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Asset Freezing and Confiscation

Depending on the allegations, prosecutors may request protective measures involving:

• Corporate bank accounts
• Real estate
• Vehicles
• Machinery
• Commercial inventory
• Company shares
• Financial assets

These measures are usually temporary while investigations continue.

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International Cooperation

Cross-border investigations have become increasingly common.

Turkish prosecutors may cooperate with:

• Foreign prosecutors
• Customs administrations
• Financial intelligence units
• International law enforcement agencies
• Mutual legal assistance authorities

Cross-border evidence sharing is increasingly important in multinational corporate investigations.

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Internal Corporate Investigations

Foreign companies should immediately conduct privileged internal reviews after learning of potential compliance concerns.

Internal investigations typically include:

• Document preservation
• Employee interviews
• Risk assessments
• Digital evidence review
• Transaction analysis
• Compliance testing

Early legal assessment frequently prevents additional legal exposure.

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Importance of Compliance Programs

A well-designed compliance program demonstrates corporate diligence.

Essential elements include:

• Anti-corruption policies
• Export control procedures
• Anti-money laundering controls
• Third-party due diligence
• Employee training
• Reporting channels
• Internal audits
• Periodic compliance reviews
• Record retention policies

Strong compliance systems significantly reduce enforcement risks.

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Common Mistakes Made by Foreign Companies

Businesses often increase their legal exposure by:

• Destroying documents
• Delaying legal advice
• Conducting informal interviews
• Ignoring whistleblower complaints
• Failing to preserve electronic evidence
• Making inaccurate public statements
• Overlooking customs compliance
• Inadequate third-party screening

Prompt legal guidance is essential.

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What Should a Company Do Immediately?

A company should:

• Preserve all documents
• Suspend document destruction policies
• Engage experienced legal counsel
• Protect digital evidence
• Review compliance procedures
• Identify key decision-makers
• Assess reporting obligations
• Cooperate appropriately with lawful requests

Early preparation often improves the outcome of investigations.

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Why Experienced Legal Representation Matters

Compliance investigations often involve criminal law, customs law, tax law, corporate governance, financial regulations, and international cooperation simultaneously.

An experienced Turkish criminal lawyer can assist with:

• Prosecutor interviews
• Corporate defence
• Internal investigations
• Search warrant challenges
• Asset seizure proceedings
• Executive representation
• Compliance audits
• Cross-border investigations
• Crisis management

Professional legal representation helps protect both corporate and individual interests throughout the investigation.

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Frequently Asked Questions (FAQ)

1. Can a foreign company be investigated by Turkish prosecutors?

Yes. Foreign companies operating or conducting business in Turkey may become subject to criminal investigations where Turkish jurisdiction exists.

2. Are company directors personally liable?

Potentially. Directors and senior managers may face personal investigations if evidence indicates individual involvement.

3. Can prosecutors seize company computers?

Yes. Subject to applicable legal procedures, investigators may examine and copy electronic evidence during authorized searches.

4. Must companies cooperate with investigations?

Companies should comply with lawful procedural requirements while protecting their legal rights through qualified legal counsel.

5. Can bank accounts be frozen?

Yes. Courts may authorize temporary protective measures over assets during criminal investigations where legal conditions are satisfied.

6. Are compliance failures always criminal offences?

No. Many compliance violations remain administrative, while more serious conduct may lead to criminal investigations.

7. Can foreign evidence be used in Turkish investigations?

Yes. Turkish prosecutors may obtain evidence through international legal cooperation mechanisms where permitted by law.

8. How can companies reduce investigation risks?

Implementing effective compliance programs, conducting regular audits, maintaining accurate records, and obtaining legal advice before high-risk transactions are among the most effective preventive measures.

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Client-Focused Legal Support

If your company is facing a compliance investigation, criminal inquiry, customs inspection, financial crime allegation, or prosecutor-led corporate investigation in Turkey, obtaining tailored legal advice at the earliest stage is essential. Early legal representation helps protect your business, executives, reputation, and commercial operations while reducing potential criminal exposure.

Fırat Fesih Kaya Law Office provides strategic legal representation for multinational corporations, foreign investors, international companies, board members, compliance officers, and senior executives involved in corporate criminal investigations in Turkey.

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