Are your assets frozen in Turkey during a criminal investigation? Learn how foreign investors and company owners can challenge freezes affecting bank accounts, company shares, real estate, vehicles, receivables and other assets.

An asset freezing order in Turkey can create immediate and serious consequences for a foreign investor or company owner. A restriction may affect bank accounts, company shares, real estate, vehicles, receivables, safe-deposit-box contents or other valuable assets. In major financial investigations, several categories of property may be restricted at the same time, potentially preventing a company from paying employees, completing transactions, obtaining financing or transferring investments.

The existence of an asset freeze does not automatically mean that the investor or company owner has been found guilty of a criminal offence. Asset restrictions imposed during an investigation are protective measures designed to preserve property while authorities investigate its alleged connection with criminal activity. Whether those restrictions are lawful and whether they should continue are separate questions from ultimate criminal liability.

This distinction has major practical importance in 2026. Recent investigations demonstrate that authorities can impose simultaneous restrictions over companies, real estate, vehicles, company shares, bank accounts and digital-asset accounts. In a June 2026 investigation, for example, prosecutors publicly reported restrictions involving companies, vehicles, real estate, company shares, bank accounts and digital-asset accounts. (İSTANBUL ANADOLU ADALET SARAYI)

Foreign investors affected by such measures should therefore act quickly to identify the precise legal basis of the freeze, the assets covered, the alleged offence, the claimed connection between the property and criminal proceeds, and the available procedure for challenging or limiting the restriction.

What Is an Asset Freezing Order?

An asset freeze is a restriction preventing an owner from freely disposing of property while a criminal investigation or prosecution is pending.

Depending on the particular measure, the owner may be prevented from selling property, transferring company shares, withdrawing bank funds, disposing of a vehicle or otherwise dealing with specified assets.

The purpose is generally preventive rather than punitive.

This distinction is essential.

A temporary asset restriction during an investigation is not the same thing as permanent confiscation following criminal proceedings.

What Assets Can Be Frozen?

The criminal asset-seizure framework can potentially cover a broad range of property.

The Constitutional Court’s reproduction of the relevant statutory framework identifies categories including real estate, land and other transportation vehicles, bank and financial institution accounts, rights and receivables held by individuals or companies, negotiable instruments, company shares, safe-deposit-box contents and other assets. (Kararlar Bilgi Bankası)

This means a foreign investor may discover that the restriction is considerably broader than a simple bank-account freeze.

For example, the same investigation could potentially affect:

1. Personal bank accounts.
2. Corporate bank accounts.
3. Shares held in a company.
4. Apartments, offices, factories or land.
5. Cars and commercial vehicles.
6. Rights to receive money from third parties.
7. Financial instruments.
8. Safe-deposit-box contents.
9. Other identified assets allegedly connected with the investigated offence.

The legal position of each asset should be examined individually.

Can Company Shares Be Frozen?

Yes, potentially.

Company shares are expressly included among the categories of assets covered by the criminal asset-seizure framework. (Kararlar Bilgi Bankası)

This can be particularly disruptive for foreign investors.

A restriction over company shares may interfere with an acquisition, share transfer, financing transaction, restructuring or planned exit.

The investor should therefore determine whether the shares themselves are alleged to represent criminal proceeds or whether the restriction has been imposed simply because they belong to a person under investigation.

That distinction may become central to the challenge.

Can Real Estate Be Frozen?

Potentially.

Real estate is also within the statutory asset categories. (Kararlar Bilgi Bankası)

A restriction may prevent the property from being sold or transferred while the measure remains effective.

For foreign investors holding residential developments, commercial property, factories, hotels or investment land, this can have substantial financial consequences.

The defense should determine precisely which property is covered and why authorities believe it has a connection with the alleged offence.

Can Vehicles Be Frozen?

Potentially.

Vehicles can also fall within the relevant asset framework.

Recent 2026 investigations demonstrate the practical use of measures involving vehicles alongside companies, real estate, bank accounts and other property. (İSTANBUL ANADOLU ADALET SARAYI)

The same legal question arises: what evidence connects the particular vehicle with the investigated offence or alleged criminal proceeds?

Ownership alone should not replace that analysis.

Can Bank Accounts Be Frozen?

Yes.

Bank and other financial institution accounts are expressly included within the statutory framework. (Kararlar Bilgi Bankası)

The restriction may become particularly damaging when it affects operational company accounts.

Payroll may stop.

Supplier invoices may remain unpaid.

Tax and contractual obligations may become difficult to perform.

An investor may also lose access to personal funds required for ordinary expenses.

Counsel should determine whether the restriction applies to the entire account or only an identified amount.

Can Digital-Asset Accounts Be Frozen?

Digital assets have become increasingly significant in financial investigations.

Recent official 2026 prosecution announcements show investigations in which restrictions were applied to both conventional bank accounts and digital-asset accounts. (İSTANBUL ANADOLU ADALET SARAYI)

Foreign investors with digital-asset holdings should therefore preserve complete transaction histories and documentation demonstrating the source of funds.

Where assets moved between conventional financial accounts and digital platforms, the entire financial trail should be reconstructed.

Does an Asset Freeze Mean the Property Was Obtained From Crime?

No.

The existence of a restriction means authorities are asserting a sufficient legal basis for the protective measure at that stage.

It does not amount to a final judicial finding that the property represents criminal proceeds.

That distinction gives the affected investor an opportunity to challenge the alleged connection.

A foreign investor may be able to demonstrate, for example, that an apartment was purchased years before the alleged offence, that company shares were acquired through documented foreign investment capital or that money in a bank account came from legitimate commercial operations.

What Legal Standard Applies?

The relevant criminal asset-seizure framework refers to strong suspicion based on concrete evidence concerning both the commission of the relevant offence and the relationship between the identified property and proceeds obtained from that offence. (Kararlar Bilgi Bankası)

This connection matters enormously.

It should not be assumed that every asset owned by a suspect automatically represents criminal proceeds.

Counsel should examine whether the required evidentiary connection has actually been established for each restricted asset.

Can Assets Owned Before the Alleged Crime Be Frozen?

This can provide an important challenge point.

Suppose a foreign investor purchased an apartment five years before the conduct under investigation allegedly occurred.

The purchase contract, banking records and property-registration documents may demonstrate that the asset could not logically have been acquired using proceeds from the later alleged offence.

The exact legal analysis will depend on the basis of the restriction, but establishing a clear acquisition chronology can be highly valuable.

How Can a Foreign Investor Prove the Legitimate Source of Assets?

Documentation is critical.

Useful evidence may include international bank-transfer records, investment agreements, share-purchase agreements, property-purchase contracts, company accounting records, audited financial statements, loan agreements, tax records, dividend documentation and evidence of previously accumulated wealth.

The objective is to construct a documented chain showing:

where the money originated, when it entered Turkey, what transaction it financed and when the relevant asset was acquired.

What If the Money Came From Abroad?

International origin does not make funds unlawful.

Foreign investors routinely transfer legitimate investment capital into Turkey.

However, cross-border transactions should be documented carefully.

Bank statements from the originating jurisdiction, transfer records, investment agreements and corporate resolutions can help establish the legitimate source and purpose of the money.

The documentation should connect the foreign funds directly with the Turkish investment wherever possible.

What If the Assets Belong to a Company?

Corporate ownership must be analyzed independently.

The fact that a shareholder or director is investigated does not automatically establish that every asset owned by the company constitutes criminal proceeds.

Company accounting records, ownership documentation and financial statements may demonstrate that the assets were purchased through legitimate company revenue or independent financing.

This distinction is particularly important for businesses with multiple shareholders.

What If Other Shareholders Are Innocent?

Their interests should be identified and protected.

A broad asset restriction affecting a company can indirectly harm shareholders who have no involvement in the alleged offence.

The company structure, shareholding percentages, capital contributions and ownership of specific assets should therefore be documented.

A criminal investigation involving one investor should not automatically erase the independent legal and financial interests of unrelated investors.

What If the Company Has Foreign Shareholders?

Foreign ownership does not prevent an asset restriction where the statutory conditions are satisfied.

At the same time, foreign shareholders retain the ability to assert ownership and procedural rights.

Cross-border documentation may become particularly important.

Share subscription agreements, capital-transfer records, corporate registers, financing agreements and foreign bank statements can help establish how the investment was funded.

Can Assets Belonging to Third Parties Be Affected?

Potentially.

The statutory framework reproduced by the Constitutional Court provides that identified property may be subject to seizure even when held by someone other than the suspect or defendant. (Kararlar Bilgi Bankası)

This does not mean third-party ownership is irrelevant.

On the contrary, genuine third-party ownership may become central to the challenge.

The third party should establish how and when the asset was acquired and why it has no connection with the alleged offence.

What If a Spouse Owns the Property?

Ownership and source of funds should be examined separately.

A spouse should not assume that property is automatically protected simply because registration is in their name.

Likewise, authorities should not automatically treat genuinely independent property as criminal proceeds merely because of the marital relationship.

Purchase records, bank statements, inheritance documentation and other evidence may be necessary.

What If the Asset Was Inherited?

Inheritance documentation can be extremely important.

If the foreign investor received the property through inheritance before the alleged criminal conduct, this may provide strong evidence concerning legitimate origin.

Relevant inheritance records and asset-transfer documentation should be collected immediately.

What If the Property Was Purchased With a Bank Loan?

Loan financing can also be important evidence.

The investor may demonstrate that the purchase price came from a regulated financial institution rather than alleged criminal proceeds.

The loan agreement, repayment history, mortgage documentation and bank transfers should be preserved.

Can an Asset Freeze Stop a Company Acquisition?

Yes, potentially.

A restriction affecting shares or important company assets can prevent or seriously delay an acquisition.

Foreign buyers conducting corporate acquisitions should therefore investigate whether the target company’s assets or shares are subject to criminal restrictions before closing.

Where a freeze appears after signing but before completion, the transaction documents should be reviewed immediately for termination rights, conditions precedent, representations and warranties, and risk-allocation provisions.

Can an Asset Freeze Prevent the Sale of Real Estate?

Potentially.

A restriction recorded against real estate can prevent a transfer from being completed.

This can create serious contractual problems where the owner has already signed a sale agreement.

Counsel may need to address both the criminal asset restriction and the resulting private contractual dispute.

Can the Company Continue Operating?

Sometimes yes, but practical difficulties can be severe.

The answer depends on which assets have been restricted.

A company whose shareholders’ personal assets are frozen may continue operating relatively normally.

A company whose operational bank accounts, receivables and major assets are restricted may face immediate liquidity problems.

The defense should therefore identify which restrictions are genuinely necessary and whether narrower measures could protect the investigation without destroying an otherwise legitimate business.

Can a Company Be Placed Under Court-Appointed Management?

In certain investigations, separate measures affecting company management can also arise.

This is distinct from simply freezing particular assets.

Recent official investigations illustrate that restrictions can extend beyond bank accounts and individual property to companies themselves. In June 2026, prosecutors publicly announced a major financial investigation involving court-appointed management over several companies and fuel businesses, together with restrictions over other property. (İSTANBUL ANADOLU ADALET SARAYI)

Foreign investors facing this situation require coordinated corporate and criminal defense because control of the business itself may be affected.

Can the Asset Freeze Be Challenged?

Yes.

Asset restrictions are not necessarily beyond judicial review.

The affected investor should obtain the relevant decision and determine the appropriate challenge procedure.

The application may contest the evidentiary basis, relationship between the property and alleged criminal proceeds, proportionality of the measure or continuing necessity of the restriction.

What Should an Objection Focus On?

Generic arguments are rarely enough.

A strong objection should address each major asset individually.

For example:

Property A: purchased before the alleged offence.

Bank Account B: contains documented foreign investment capital.

Vehicle C: financed through a bank loan.

Company Shares D: acquired through a documented capital contribution.

Account E: contains ordinary company revenue unrelated to the disputed transactions.

This asset-by-asset approach can be much more persuasive than simply asserting that everything is legitimate.

Can Only Part of an Asset Freeze Be Lifted?

Potentially.

The defense strategy does not always have to demand complete removal of every restriction.

Where some assets remain genuinely relevant to the investigation while others do not, partial release may be appropriate.

Likewise, if only a particular amount of money is allegedly connected with the offence, counsel can examine whether restricting substantially larger legitimate assets is proportionate.

Can Company Operating Funds Be Released?

This may be requested depending on the legal basis and circumstances.

Payroll, taxes, suppliers and other operating expenses can become important considerations.

However, business necessity alone does not automatically override a lawful criminal restriction.

The stronger argument may be that identifiable operating funds have a legitimate and independently documented source and no sufficient connection with the alleged offence.

How Long Can Assets Remain Frozen?

There is no useful universal period applicable to every case.

The duration depends on the legal basis, procedural stage, investigation and continuing justification.

Foreign investors should not simply assume that the restriction must remain until a final criminal judgment.

The continuing necessity and proportionality of the measure should be reviewed throughout the proceedings.

Can Assets Be Released During the Investigation?

Potentially.

If the original justification disappears or evidence demonstrates that particular property is unrelated to the alleged offence, an application for release can be considered before the investigation ends.

This can be particularly important where a long investigation is causing serious commercial harm.

What Happens If the Investigation Ends Without Prosecution?

The basis for continuing criminal asset restrictions should be reviewed immediately.

A decision not to proceed with criminal prosecution can materially affect the justification for retaining restrictions.

However, foreign investors should not assume that every registration or banking restriction will disappear instantly without procedural follow-up.

Counsel should verify actual implementation.

What Happens After an Acquittal?

An acquittal can similarly affect the basis for asset restrictions.

The final judgment should nevertheless be reviewed for any separate decision concerning property or confiscation.

The defense should track each asset until the relevant restriction is actually removed from the banking, company, vehicle or property-registration system.

Is Asset Freezing the Same as Permanent Confiscation?

No.

This distinction is fundamental.

An investigative asset restriction is generally temporary.

Permanent confiscation is a substantive consequence requiring its own legal basis and judicial determination.

A foreign investor should therefore never assume:

“The government froze my property, so I have permanently lost ownership.”

That conclusion does not follow merely from the existence of an investigative freeze.

Can Criminal Proceeds Ultimately Be Confiscated?

Potentially, where the statutory requirements are established.

This is why proving legitimate origin matters so much.

The defense should establish that the restricted property derives from legitimate investment, business revenue, salary, inheritance, loans or other lawful sources.

The stronger the financial documentation, the more effectively the alleged connection with criminal proceeds can be tested.

What Role Does Financial Analysis Play?

Financial analysis can be central to complex asset investigations.

Recent 2026 prosecution announcements demonstrate the significant role of financial-analysis work in investigations involving alleged money laundering, illegal betting and investment fraud. (İSTANBUL ANADOLU ADALET SARAYI)

Foreign investors should therefore expect authorities to examine transaction histories rather than merely account balances.

The defense may need its own forensic accounting analysis to explain legitimate transaction patterns.

Should Foreign Investors Hire a Forensic Accountant?

In complex cases, this can be valuable.

A criminal lawyer addresses the legal basis and procedural challenge.

A forensic accountant can help reconstruct the movement of funds and distinguish legitimate commercial transactions from transfers authorities consider suspicious.

This combination can be particularly effective where hundreds or thousands of transactions are involved.

What If Authorities Misunderstand an International Transaction?

This occurs frequently in cross-border business.

A payment that appears unusual without context may actually represent a shareholder loan, capital contribution, intercompany payment, licensing fee, acquisition payment or ordinary trade transaction.

The defense should not merely state that the transaction was legitimate.

It should demonstrate the legal and commercial basis using contracts, invoices, banking records and accounting entries.

What About Related-Party Transactions?

Related-party transactions may receive increased scrutiny because funds move between connected companies or shareholders.

The commercial purpose should therefore be documented carefully.

Intercompany agreements, invoices, transfer records and accounting treatment can help explain why money moved between related entities.

What If the Investigation Concerns Money Laundering?

Asset restrictions are especially important in investigations involving alleged laundering of criminal proceeds.

Official 2026 prosecution announcements demonstrate active investigations involving financial networks, bank accounts, digital-asset accounts, companies and real estate. (İSTANBUL ANADOLU ADALET SARAYI)

The defense should reconstruct both the origin and destination of funds and identify the legitimate commercial purpose of each significant transaction.

What If the Investigation Concerns Investment Fraud?

Foreign company owners may become involved where an investment business is alleged to have collected money through fraudulent representations.

A June 2026 prosecution announcement concerning alleged fraudulent investment operations reported restrictions over companies, fuel businesses, real estate, vehicles, company shares, bank accounts and digital-asset accounts. (İSTANBUL ANADOLU ADALET SARAYI)

This illustrates how broad the financial consequences of an investment-related criminal investigation can become before final criminal responsibility has been determined.

Can Foreign Investors Leave Turkey While Their Assets Are Frozen?

An asset freeze and an international travel restriction are different legal measures.

The existence of one does not automatically establish the other.

However, a foreign investor involved in a criminal investigation should determine whether any separate travel restriction, judicial-control measure, summons or arrest warrant exists before leaving the country.

Can the Investor Sell Assets Abroad?

The answer depends on the jurisdiction and scope of the investigation.

A Turkish asset order does not automatically operate identically in every foreign jurisdiction.

However, international criminal cooperation can become relevant in major financial investigations.

Moving assets after learning of an investigation may also create serious evidentiary concerns.

Foreign investors should obtain legal advice before making unusual asset transfers once an investigation is known.

Should Assets Be Transferred to Family Members?

Attempting to avoid a criminal restriction by transferring assets to relatives can create significant additional problems.

The defense should rely on lawful challenges, legitimate ownership evidence and financial documentation.

Artificial transactions designed to conceal ownership can seriously damage credibility and may create additional legal exposure.

Should Company Records Be Deleted or Changed?

No.

Accounting records, invoices, contracts, emails and corporate documentation should be preserved.

Do not create retrospective agreements to explain transactions.

Do not alter invoices.

Do not manipulate accounting records.

A legitimate asset-freeze challenge should be based on authentic evidence.

What Documents Should Foreign Investors Collect Immediately?

The investor should gather bank statements, international transfer records, company accounts, tax documentation, share-acquisition documents, capital-contribution records, property-purchase contracts, vehicle documents, loan agreements, inheritance documents, audited financial statements and any contracts explaining significant transactions.

The documents should then be organized chronologically.

A well-structured source-of-funds file can become one of the most important components of the defense.

What Should a Foreign Company Owner Do in the First 48 Hours?

The first priority is identifying exactly what has been restricted.

Obtain the relevant decisions and determine whether bank accounts, company shares, real estate, vehicles, receivables or other property are affected.

Next, preserve financial records and prevent unauthorized alteration or destruction of company data.

Then reconstruct the source of funds for major assets.

Finally, counsel should determine the deadline and procedural route for challenging the restriction.

Can Compensation Be Claimed for an Unlawful Asset Freeze?

Potentially, depending on the applicable statutory requirements and circumstances.

This issue should be evaluated separately from the application seeking release.

A foreign investor claiming financial loss should preserve evidence from the beginning.

Relevant evidence may include lost contracts, financing costs, penalties, cancelled transactions, loss of rental income and other measurable losses directly connected with the restriction.

What If the Asset Freeze Causes the Company to Collapse?

This raises particularly serious proportionality and damages issues.

The company should document the commercial consequences in real time.

Financial statements, missed payments, cancelled contracts and financing difficulties can become important later.

At the same time, management should take lawful steps to reduce losses rather than allowing damage to accumulate unnecessarily.

Practical Example: Foreign Investor’s Company Shares Are Frozen

A foreign investor acquired shares in a Turkish company three years before the alleged criminal conduct.

During an investigation involving another shareholder, the investor’s shares become restricted.

The investor can produce the original share-purchase agreement, foreign bank transfer, company records and evidence showing that the shares were acquired before the alleged offence.

The challenge should focus on the absence of a sufficient connection between those shares and alleged criminal proceeds.

Practical Example: Company Bank Accounts Are Frozen

A manufacturing company has thousands of ordinary transactions each year.

Investigators identify several disputed transfers and the company’s operating accounts become restricted.

The defense should separate the questioned transactions from legitimate customer revenue, financing and shareholder capital.

A forensic accounting report may help demonstrate which funds have no connection with the alleged offence.

Practical Example: Real Estate Purchased With Foreign Investment Capital

A foreign investor transfers money from a long-established overseas bank account and purchases commercial property in Turkey.

Years later, the investor becomes involved in an unrelated criminal investigation and the property is restricted.

The defense can reconstruct the original international transfer and purchase documentation to demonstrate the property’s legitimate source.

Frequently Asked Questions

1. Can foreign investors’ assets be frozen in Turkey?

Yes, where the applicable statutory conditions are satisfied. Foreign nationality does not prevent criminal asset restrictions.

2. Can company shares be frozen?

Potentially. Company shares are among the asset categories covered by the criminal asset-seizure framework. (Kararlar Bilgi Bankası)

3. Can real estate be frozen?

Potentially. Real estate is also included within the relevant statutory framework. (Kararlar Bilgi Bankası)

4. Can bank accounts be frozen?

Yes, where the legal requirements are satisfied. Bank and financial institution accounts are expressly covered. (Kararlar Bilgi Bankası)

5. Does an asset freeze mean I am guilty?

No. A protective asset measure during an investigation is not a criminal conviction.

6. Can I challenge an asset freeze?

Potentially, yes. The legal and evidentiary basis of the restriction can be reviewed through the applicable procedural remedies.

7. Can assets purchased before the alleged offence be released?

Potentially. Evidence showing that the asset was acquired before the alleged conduct may be highly relevant to challenging the claimed connection with criminal proceeds.

8. Can company assets be frozen because a shareholder is investigated?

Potentially, depending on the circumstances. However, company ownership and the legitimate source of corporate assets should be analyzed independently.

9. Can only part of the restriction be removed?

Potentially. Where some assets or funds are demonstrably unrelated to the alleged offence, a narrower or partial release may be sought depending on the applicable measure.

10. Should foreign investors provide source-of-funds evidence?

Yes. Bank records, investment agreements, company accounts, purchase contracts and other documents establishing legitimate origin can be central to challenging an asset restriction.

Legal Assistance for Foreign Investors Facing Asset Freezing Orders in Turkey

An asset freezing order affecting a foreign investor or company owner in Turkey can have consequences far beyond the criminal investigation itself. Restrictions may prevent the investor from accessing capital, transferring shares, selling property, completing an acquisition or continuing ordinary company operations.

Recent 2026 investigations demonstrate that financial measures can simultaneously affect companies, real estate, vehicles, company shares, bank accounts and digital-asset accounts. (İSTANBUL ANADOLU ADALET SARAYI) This makes early and asset-specific legal review particularly important.

The defense should determine which assets are restricted, the precise legal basis of each restriction, the alleged offence, the claimed connection with criminal proceeds, whether the investor or company actually owns the affected property, and whether continued freezing remains necessary and proportionate.

Fırat Fesih Kaya Law Office provides legal assistance to foreign investors, international companies, shareholders and company directors concerning asset freezing orders, frozen bank accounts, company share restrictions, real estate restrictions, vehicle seizures, financial investigations, money laundering allegations, investment fraud investigations and applications for release of assets in Turkey.

Legal assistance may include reviewing asset-freezing decisions, preparing objections and release applications, documenting legitimate sources of funds, coordinating forensic accounting analysis, protecting third-party and shareholder interests and representing foreign investors throughout related criminal proceedings.

Phone: +90 312 434 22 22
Mobile / WhatsApp: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Office: Mevlana Boulevard No:221, Yildirim Tower, Balgat, Cankaya, Ankara, Turkey

For foreign investors, the most important response to an asset freeze is usually not simply to wait for the criminal investigation to end. Establishing the legitimate source of each asset, challenging unsupported connections with alleged criminal proceeds and seeking partial or complete release at the appropriate procedural stage can be central to protecting both the investment and the underlying business.