Foreign Company Pays the Wrong Turkish Bank Account After Receiving a Fake Invoice: Who Bears the Loss? 2026 Updated Guide

A foreign company transfers money to the wrong Turkish bank account after receiving a fake invoice. Learn about payment fraud, bank recovery, criminal complaints, account freezing, supplier disputes and compensation claims in Turkey.

A foreign company doing business in Turkey may receive what appears to be a legitimate invoice or payment instruction containing a Turkish bank account number. The document may use the real supplier’s name, logo, invoice format and transaction details, but the bank account may actually belong to a fraudster or an unrelated third party. Once the payment is transferred, the foreign buyer may discover that its genuine Turkish supplier never received the money.

These cases commonly involve business email compromise, hacked email accounts, fake invoices, altered bank details, impersonation of suppliers and fraudulent payment instructions. The immediate questions are whether the money can be frozen or recovered, whether the buyer must pay the genuine supplier again, whether the receiving account holder is liable, and whether a bank, employee or commercial counterparty contributed to the loss.

How Does Fake Invoice Fraud Usually Occur?

The fraudster may obtain access to an email account belonging to the buyer, seller, employee, accountant or intermediary. The fraudster then monitors genuine correspondence and waits for a payment to become due.

A false message may subsequently be sent stating that the supplier’s bank details have changed.

In more sophisticated cases, the fraudulent email closely resembles the genuine correspondence and may contain authentic transaction information. The foreign company therefore believes it is paying a legitimate commercial invoice.

The First Hours After Discovering the Fraud Are Critical

A foreign company should act immediately after discovering that payment was sent to a fraudulent Turkish bank account.

The most important objective is to prevent the money from being transferred onward, withdrawn in cash, converted into another asset or distributed through multiple accounts.

Delay can significantly reduce the possibility of practical recovery.

Contact the Sending Bank Immediately

The foreign company should notify its bank that the transfer was induced by fraud and request immediate recall or recovery procedures.

The payment reference, amount, date, beneficiary information, account details and relevant correspondence should be preserved.

If the transfer has not yet been finally processed or the funds remain accessible within the banking chain, rapid action can be particularly important.

The Turkish Receiving Bank Should Also Be Identified

Where the destination is a Turkish bank account, information concerning the receiving bank should be collected immediately.

Legal and criminal procedures in Turkey may become necessary to identify the account holder, trace subsequent transfers and seek preservation of the remaining funds.

A Bank Transfer Cannot Always Simply Be Reversed

Businesses sometimes assume that a fraudulent payment can automatically be cancelled once the bank is informed.

That is not necessarily the case.

If the payment was technically authorized by the company but authorization was obtained through deception, recovery can involve substantially different issues from an entirely unauthorized electronic transaction.

Criminal Complaint in Turkey

Fake invoice schemes can potentially involve fraud, unlawful access to information systems, misuse of banking systems, document-related offenses or other criminal conduct depending on the facts.

A criminal complaint may allow the circumstances surrounding the Turkish beneficiary account and movement of funds to be investigated.

Requesting Urgent Preservation of Funds

Where money may still be in the receiving account, urgent action is particularly important.

The appropriate criminal and civil mechanisms should be evaluated according to the available evidence and procedural circumstances. The objective is to prevent dissipation while the ownership and fraudulent transaction are investigated.

Preserve the Original Fake Invoice

Do not delete or modify the fraudulent invoice.

Preserve the original electronic file together with any available metadata. A printed copy alone may omit information useful in reconstructing how the document was created or transmitted.

Preserve the Entire Email Chain

Keep the genuine correspondence before the fraud, the fraudulent message, subsequent responses and discovery communications.

Do not preserve only screenshots where the original electronic records remain available.

Examine the Email Addresses Carefully

Fraudsters frequently use addresses differing from genuine addresses by a single letter, character or domain variation.

In other cases, however, the real email account may have been compromised. The fact that a message came from the genuine address therefore does not automatically prove that the supplier actually sent it.

Determine Which Email Account Was Compromised

This question can become central to the later allocation of loss.

Was the foreign buyer’s account compromised? Was the Turkish supplier’s email compromised? Was an accountant, freight forwarder or intermediary compromised?

Technical investigation may be required.

Preserve Technical Evidence

Relevant evidence can include login histories, security alerts, forwarding rules, email headers, access logs and authentication records where available.

Companies should avoid resetting or deleting systems in a way that destroys relevant evidence before necessary records have been preserved.

Was the Invoice Entirely Fake or Merely Altered?

There is an important difference between a completely fabricated invoice and a genuine invoice in which only the beneficiary bank account has been changed.

The second scenario can indicate that the fraudster had access to genuine commercial information.

Who Bears the Loss Between Buyer and Supplier?

There is no universal answer.

The allocation of loss may depend on the contract, payment obligations, how the fraudulent instruction arose, the parties’ conduct, whether the creditor actually received payment, previous payment practices and whether either party negligently contributed to the fraud.

Does Payment to the Fraudster Discharge the Buyer’s Debt?

A buyer should not assume that transferring money to an account controlled by a fraudster automatically discharges its contractual debt to the genuine supplier.

If payment was not made to the creditor or a person legally authorized to receive it, the supplier may argue that the invoice remains unpaid.

This can create the commercially difficult possibility that the foreign company faces both the fraud loss and a second payment demand.

The Contract Should Be Reviewed Immediately

Examine the governing law, payment provisions, agreed beneficiary account, notice requirements, bank-detail-change procedures and risk-allocation clauses.

The contract may materially affect the dispute between buyer and supplier.

Previous Payment Practice Can Be Important

If all previous invoices were paid to the same Turkish account and a sudden email instructed the buyer to pay an entirely different account, the circumstances surrounding verification may become relevant.

Conversely, if the supplier routinely changed accounts or gave payment instructions through informal channels, the factual assessment may differ.

Was the Change in Bank Details Verified?

Determine whether the foreign company independently confirmed the new bank account through a known telephone number, separate communication channel or established internal verification procedure.

This is particularly important in high-value business email compromise cases.

Supplier Cybersecurity May Become Relevant

If the Turkish supplier’s systems were compromised and the fraudster obtained genuine invoices and customer information from those systems, the foreign buyer may investigate whether the supplier’s conduct contributed to the loss.

However, the existence of a cybersecurity breach does not automatically determine civil liability. Causation, contractual duties and the specific conduct of both parties must be analyzed.

Buyer-Side Negligence May Also Be Examined

If the buyer ignored obvious inconsistencies, bypassed internal controls or accepted a major bank-account change without verification, these facts may become relevant to the commercial dispute.

The investigation should therefore examine both sides objectively.

What If an Employee Changed the Bank Details?

Determine whether the employee acted innocently after being deceived, deliberately participated in the scheme or failed to follow mandatory payment controls.

Internal disciplinary or civil issues should remain separate from unsupported accusations of criminal involvement.

What If the Turkish Account Belongs to a Money Mule?

Fraudulent funds are often received through accounts belonging to individuals or businesses who are not the ultimate organizer of the scheme.

The account holder’s knowledge, conduct and relationship with the transferred money should be investigated.

Funds May Be Transferred Through Multiple Accounts

The initial beneficiary account may only be the first stage.

Money can be distributed through several accounts shortly after receipt. Transaction tracing can therefore become central to recovery efforts.

Cryptocurrency Conversion Can Complicate Recovery

Fraudsters may attempt to convert proceeds into digital assets or move value through additional channels.

This makes immediate preservation and tracing efforts particularly important.

Can the Turkish Bank Be Liable?

Bank liability should not be assumed merely because a fraudulent account was maintained at that bank.

The specific transaction, account-opening circumstances, fraud indicators, notifications received by the bank and applicable banking obligations should be examined before asserting liability.

What If the Bank Was Warned but Allowed the Money to Leave?

The timing and content of the warning may become particularly important.

Preserve records showing exactly when the bank was notified, what information was provided and what occurred afterward.

Civil Recovery Against the Recipient

Depending on the facts, civil-law claims against the recipient or other responsible parties may need to be evaluated alongside the criminal investigation.

The appropriate claim depends on how the money was received and the recipient’s legal position.

Precautionary Measures May Be Important

Where the identity of a responsible party and assets are known, available interim civil remedies should be considered quickly.

The objective is to avoid obtaining a favorable judgment only after recoverable assets have disappeared.

Foreign Companies Can Pursue Claims in Turkey

The fact that the victim company is incorporated abroad does not by itself prevent it from pursuing appropriate criminal or civil remedies in Turkey.

Representation, corporate documents and authority documentation should be prepared correctly for the particular proceeding.

Power of Attorney Should Be Prepared Promptly

International corporate structures can make authorization time-consuming.

If Turkish proceedings are required urgently, the foreign company’s signatory and corporate documentation should be organized without unnecessary delay.

Preserve Proof of the Original Debt

Keep the underlying sales agreement, purchase order, genuine invoice, delivery documents and communications.

These records establish the legitimate commercial transaction against which the fraudulent payment occurred.

Preserve Proof of Payment

Bank statements, SWIFT information, payment confirmations and transfer references should be retained.

The exact route of the payment can be important for tracing the funds.

Notify the Genuine Supplier Carefully

The genuine supplier should be informed promptly, but early communications should avoid unnecessary admissions regarding legal responsibility.

The immediate objective should be to preserve evidence, coordinate fraud investigation and prevent additional fraudulent instructions.

Check Whether Other Invoices Were Manipulated

A discovered fake invoice may not be an isolated event.

Review recent and pending payments involving the same supplier and inspect whether any other beneficiary details were changed.

Warn the Finance Department

Suspend payment of suspicious invoices until beneficiary information is independently verified.

Fraudsters sometimes send multiple altered invoices once they determine that a company has accepted the first fraudulent instruction.

Review Insurance Coverage

Cyber, crime, fidelity or other insurance policies may potentially be relevant depending on their wording and the circumstances of the fraud.

Notification periods and cooperation requirements should be checked promptly.

Cross-Border Issues Can Be Significant

The foreign buyer, Turkish supplier, email infrastructure, sending bank and receiving bank may all be located in different jurisdictions.

A coordinated strategy may therefore be required rather than treating the incident solely as a Turkish bank dispute.

Criminal Investigation and Commercial Litigation Can Proceed Separately

A criminal investigation into the fraud does not necessarily resolve whether the foreign buyer still owes the genuine supplier.

The contractual payment dispute and criminal recovery process should therefore be analyzed separately.

Do Not Wait for the Criminal Case Before Reviewing the Contract

Commercial deadlines may continue while the criminal investigation is pending.

The foreign company should protect its contractual and civil rights independently where necessary.

Evidence of Fraud Should Be Organized Chronologically

Prepare a timeline showing the genuine commercial relationship, invoice issuance, fraudulent communication, bank-detail change, transfer, discovery of fraud, bank notifications and subsequent movement of funds if known.

A clear chronology can substantially improve both criminal and civil submissions.

Internal Controls Should Be Changed After the Incident

Companies making international payments should consider requiring independent verification of every beneficiary-account change.

High-value payments may also justify dual approval and verification through a previously established communication channel.

Never Verify New Bank Details Through the Suspicious Email Chain

If an email says that payment instructions have changed, verification should occur through independently obtained contact information rather than simply replying to the same message.

A compromised email account may allow the fraudster to confirm their own fraudulent instructions.

Immediate Action Plan

When a foreign company sends money to a fraudulent Turkish bank account after receiving a fake invoice, it should immediately notify the sending bank, identify the Turkish receiving bank, seek available preservation and tracing measures, preserve the original invoice and electronic correspondence, investigate which account was compromised, collect technical evidence, prepare a Turkish criminal complaint where appropriate, review civil recovery options, examine whether the genuine supplier can still demand payment, notify insurers and review all other pending payments involving the compromised relationship.

Frequently Asked Questions

Can a fraudulent bank transfer to Turkey be reversed?

Potentially, particularly where action is taken before the funds are withdrawn or transferred onward. Recovery is not automatic and speed can be decisive.

Should the foreign company file a criminal complaint in Turkey?

Where the fraudulent payment was received or transferred through Turkey, Turkish criminal procedures may become highly relevant depending on the circumstances.

Does paying the fake invoice mean the genuine supplier has been paid?

Not necessarily. Whether the buyer’s original payment obligation has been discharged requires separate contractual and legal analysis.

Can the genuine supplier demand payment again?

Potentially. If the genuine creditor never received the money, it may claim that the contractual debt remains outstanding. Responsibility for the fraud must then be examined separately.

Is the Turkish bank automatically responsible?

No. Bank liability requires analysis of the specific facts, applicable obligations and the bank’s conduct.

Can the account holder be sued?

Potentially, depending on the account holder’s involvement, receipt of the funds and other circumstances.

What if the supplier’s email was hacked?

That fact may be highly relevant, but it does not automatically determine which party ultimately bears the loss.

Can the bank account be frozen?

Urgent preservation measures may potentially be available depending on the evidence, procedural route and status of the funds.

Should the company pay the genuine supplier a second time?

The contractual position, urgency of the commercial relationship and recovery strategy should be reviewed before making a second payment or refusing the supplier’s demand.

What should the company do first?

Act immediately to trace and preserve the money. At the same time, secure the electronic evidence and determine whether the fraudulent instruction originated from the buyer’s systems, the supplier’s systems or another compromised participant.

Client-Focused Legal Support for Fake Invoice and Bank Transfer Fraud in Turkey

Fake invoice fraud involving a Turkish bank account can create simultaneous criminal, banking, commercial and cross-border recovery disputes. Fırat Fesih Kaya Law Office assists foreign companies, international buyers and businesses facing fraudulent payment incidents connected with Turkey. Lawyer Fırat Fesih Kaya provides legal assistance in urgent fund-recovery strategy, criminal complaints, evidence preservation, Turkish bank-account tracing issues, civil recovery claims and disputes concerning whether the genuine commercial debt remains payable.

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