Company Fraud in Turkey: What Foreign Investors Can Do to Recover Their Money – 2026 Updated Guide

Lost money because of company fraud in Turkey? Learn how foreign investors can investigate fraudulent companies, file criminal complaints, trace payments, challenge corporate misconduct and pursue recovery of their investment.

Foreign investors entering the Turkish market may invest through a share purchase, capital contribution, joint venture, commercial partnership, startup investment, acquisition or direct financing arrangement. Most transactions proceed normally. However, serious problems can arise when an investor discovers that the company, its shareholders, directors or intermediaries allegedly provided false information or diverted the investor’s money after receiving it.

Typical warning signs include fabricated financial statements, nonexistent assets, hidden company debts, false invoices, fictitious customers, unauthorized bank transfers, related-party transactions, diverted investment capital and company assets transferred to insiders shortly after the investment.

For a foreign investor, discovering fraud creates two separate but connected objectives. The first is establishing criminal or civil responsibility. The second—and usually the investor’s primary commercial concern—is recovering the money.

A successful fraud case does not automatically mean that the investment will be recovered. The recovery strategy should therefore begin as early as the investigation itself.

Turkey’s Ministry of Trade confirms in its 2026 company guide that shareholders have mechanisms for investigating company affairs, including the possibility of requesting a special auditor and, subject to statutory conditions, applying to court if the general meeting refuses the request.

What Is Company Fraud?

Company fraud can describe different forms of intentional deception or misuse occurring through a corporate structure.

The alleged misconduct may take place before the investment. For example, the investor may be persuaded to purchase shares because company revenue, assets or contracts were deliberately misrepresented.

Fraud may also occur after the investment. Company directors or business partners may divert the investor’s capital, create false expenses, transfer company assets to related businesses or conceal income.

The correct legal remedy depends heavily on when the deception occurred and whose money or property was affected.

Is Every Failed Company Investment Fraud?

No.

Investing in a company always involves commercial risk.

A business may lose customers, experience cash-flow problems, become insolvent or fail to achieve projected revenue.

None of these circumstances automatically proves fraud.

The legal position becomes substantially different where there is evidence that false information was deliberately provided to obtain the investment or that money was intentionally diverted after it entered the company.

This distinction is fundamental when deciding whether criminal proceedings are appropriate.

Fraud Before Buying a Company in Turkey

Acquisition fraud can occur when a foreign investor purchases shares based on materially inaccurate information.

Suppose the seller claims that the company has substantial annual revenue, valuable equipment, major customers and limited debt.

After completion, the investor discovers that customer contracts were fabricated, equipment belonged to another company and substantial liabilities had been concealed.

The legal strategy may involve criminal allegations as well as commercial claims arising from the share-purchase transaction.

False Financial Statements

Financial statements are frequently central to company fraud disputes.

A foreign investor may discover that financial information provided during negotiations does not correspond with actual company records.

Potential discrepancies can involve revenue, receivables, liabilities, inventory, loans and related-party transactions.

The original financial documents presented before the investment should be preserved.

The key evidentiary question is not merely whether the figures were inaccurate, but whether they were deliberately manipulated to influence the investment decision.

Fake Customers and Contracts

A company may appear more valuable if it supposedly has long-term contracts with major customers.

Foreign investors should become concerned if important customers deny the existence of those relationships after the acquisition.

Preserve every customer list, presentation, contract and email provided during negotiations.

The difference between genuine commercial expectations and fabricated business relationships can be critical to establishing intentional deception.

Hidden Company Debts

Foreign investors sometimes discover substantial liabilities only after acquiring shares.

Not every undisclosed liability establishes criminal fraud.

The investigation should determine whether the seller knew about the debt, whether disclosure was contractually required and whether information was intentionally concealed.

Tax, employment, supplier, banking and litigation liabilities should all be examined.

Fake Company Assets

A company may be presented as owning factories, machinery, vehicles, intellectual property or valuable inventory.

After the transaction, the investor may discover that assets belong to another entity, are subject to significant restrictions or never existed.

Due diligence documentation should be compared with official and accounting records.

Fraudulent Capital Contributions

A foreign investor may transfer money into a company expecting it to be used for expansion, equipment purchases, construction or working capital.

Instead, the funds may immediately be transferred to shareholders or related companies.

This should trigger a detailed financial investigation.

The investor should determine exactly where the money moved after reaching the company’s account.

Investment Money Transferred to a Director

A transfer from the company to a director’s personal account is not automatically unlawful.

There may be a legitimate basis such as salary, expense reimbursement or repayment of an existing obligation.

However, substantial unexplained transfers shortly after a foreign investment can be a major warning sign.

Bank records and accounting records should be compared transaction by transaction.

Money Transferred to Related Companies

Another common concern involves payments to companies controlled by the existing shareholder or director.

The investor should determine:

Who owns the receiving company?

What service was supposedly provided?

Was there a written agreement?

Was the price commercially reasonable?

Was the transaction disclosed?

Did any service actually occur?

Related-party transactions can provide an important financial trail in suspected corporate fraud.

Fake Invoice Fraud

False invoices can make unauthorized withdrawals appear legitimate.

A company may record payments for consulting, marketing, equipment or supplies that were never actually provided.

The investor should identify the supplier, examine ownership links and verify whether the underlying goods or services existed.

A professionally prepared invoice does not itself prove that a genuine commercial transaction occurred.

Company Revenue Diverted Elsewhere

Fraud can occur even without money being removed directly from the company’s bank account.

A director may instruct customers to make payments to another business.

As a result, revenue that should have entered the foreign investor’s company never appears in its accounts.

Customer communications, invoices and payment instructions can help reconstruct the scheme.

Parallel Company Fraud

A local partner may secretly establish another company conducting essentially the same business.

Customers, employees, intellectual property or opportunities may then be transferred to the new company.

Foreign investors should investigate company ownership, management, bank transactions and commercial relationships.

Depending on the conduct, several corporate and legal remedies may arise.

Can a Foreign Investor File a Criminal Complaint?

Yes.

Foreign nationality does not prevent an investor from reporting suspected criminal conduct.

However, the complaint should be evidence-based.

A criminal complaint that merely states “I invested money and the business failed” will not explain why criminal fraud allegedly occurred.

The complaint should identify specific false statements, suspicious transactions, individuals involved and financial losses.

What Evidence Should Be Collected?

Company fraud cases are highly document-dependent.

Important evidence may include share-purchase agreements, shareholder agreements, investment agreements, financial statements, bank transfers, accounting records, invoices, corporate presentations, emails, messages, management decisions and general meeting records.

The investor should preserve the original materials provided before the transaction.

Changes between pre-investment representations and post-investment reality can become particularly important.

Bank Records Can Reveal Where the Money Went

Bank statements are often the starting point for recovery.

The investor should prepare a chronology showing:

the date of each investment payment, the receiving account, subsequent transfers, recipients and the stated purpose of those transactions.

This creates a financial map.

Where substantial amounts move immediately after an investment, each transfer should be investigated.

Can Prosecutors Investigate Bank Transfers?

Potentially.

Financial investigations can involve detailed analysis of banking and other financial records where the legal conditions are satisfied.

Recent 2026 fraud investigations demonstrate how significant financial tracing can become. In an April 2026 investigation concerning alleged fake investment websites, prosecutors reported analyzing 15 bank accounts and four digital-asset accounts associated with suspects.

The circumstances of each corporate fraud investigation are different, but the example demonstrates the practical importance of financial analysis.

Can the Investor Trace Money Through Several Companies?

Potentially.

Fraudulent funds may move through several companies before reaching the ultimate beneficiary.

The investor should not stop the analysis merely because the first recipient appears to be a legitimate company.

Ownership, directors, invoices and subsequent transfers should be investigated.

Can Company Assets Be Frozen?

Protective measures may potentially be available where the applicable statutory requirements are satisfied.

However, filing a criminal complaint does not automatically freeze a company’s assets.

The legal basis, evidence and relationship between the property and alleged criminal conduct must be established.

For recovery purposes, identifying assets early can be extremely important.

Can Personal Assets of Directors Be Restricted?

Potentially, but corporate personality and individual responsibility must be respected.

A director is not automatically personally responsible for every company debt.

Where evidence indicates personal participation in fraudulent conduct, however, individual criminal and civil responsibility may need to be investigated.

Why Asset Tracing Should Start Immediately

Winning a case and recovering money are not the same thing.

Imagine that a foreign investor eventually obtains a favorable judgment but discovers that the responsible company owns no recoverable assets.

The legal victory may have limited commercial value.

For that reason, investors should identify real estate, bank accounts, company shares, receivables and other potentially relevant assets as early as legally possible.

Can a Foreign Investor Recover Money Through Criminal Proceedings Alone?

Not necessarily.

This is one of the most important points for foreign investors.

A criminal investigation focuses primarily on criminal responsibility.

The investor may need separate commercial, contractual, compensation or enforcement remedies to maximize financial recovery.

The appropriate combination depends on the transaction.

Criminal Complaint and Commercial Lawsuit Together

These proceedings can potentially operate in parallel.

Suppose a foreign investor purchased a company based on allegedly fraudulent financial statements.

The investor may seek criminal investigation concerning deliberate deception while simultaneously evaluating contractual remedies under the share-purchase agreement.

Waiting until the criminal case completely finishes before considering financial recovery can sometimes create unnecessary risks.

Can the Share Purchase Be Challenged?

Potentially.

Where shares were acquired because of alleged fraudulent representations, the underlying transaction should be reviewed carefully.

The available remedies depend on the agreement, representations, warranties, applicable law and circumstances surrounding the transaction.

The investor should preserve the complete negotiation record.

Can Compensation Be Claimed?

Potentially.

A foreign investor who proves legally recoverable losses may seek compensation through the appropriate proceedings.

The loss calculation may include the principal investment and, depending on the legal basis, other provable damages.

Projected profits should not automatically be assumed to be recoverable.

Can Interest Be Claimed?

Potentially, depending on the nature of the claim and applicable rules.

Interest can become financially significant where millions are involved and litigation continues for several years.

The relevant starting date and calculation method should be assessed for the specific claim.

Can Shareholders Investigate the Company’s Records?

Shareholder information and investigation rights can become extremely valuable where fraud is suspected.

Turkey’s Ministry of Trade explains in its 2026 company guide that shareholders have been given a mechanism to request appointment of a special auditor for clarification of particular events.

This can help investors investigate transactions that management refuses to explain.

What Is a Special Audit?

A special audit is a corporate mechanism that can be used to clarify specific company matters.

According to the Ministry of Trade’s 2026 guide, a shareholder can request appointment of a special auditor from the general meeting. If the request is rejected, shareholders representing at least one-tenth of the capital, or one-twentieth in publicly held companies, may request court appointment within three months, subject to the applicable statutory requirements.

For foreign shareholders, this can be an important investigative tool.

Special Audit or Criminal Complaint?

Potentially both.

A special audit is not a substitute for criminal investigation.

Likewise, a criminal complaint does not necessarily replace corporate mechanisms allowing shareholders to investigate company affairs.

The strongest strategy may coordinate corporate information rights, special audit procedures, criminal proceedings and recovery claims.

What If the Foreign Investor Is a Minority Shareholder?

Minority ownership does not mean that the investor has no legal options.

Corporate rights depend on company type and ownership percentage.

The Ministry of Trade’s 2026 guide specifically recognizes qualifying minority shareholders’ ability to seek court appointment of a special auditor after rejection by the general meeting.

The investor’s exact percentage should therefore be identified immediately.

What If the Majority Shareholder Controls Everything?

Practical control does not provide unlimited legal authority.

A majority shareholder cannot necessarily treat company assets as personal property or disregard corporate obligations.

Where the majority shareholder also controls management and banking, independent examination of transactions becomes particularly important.

Fraudulent General Meeting Decisions

Corporate fraud may involve allegedly fabricated or manipulated shareholder decisions.

A foreign shareholder living abroad may discover that a meeting supposedly occurred without their knowledge or that documents contain a disputed signature.

These issues may require urgent corporate litigation in addition to criminal investigation.

Forged Shareholder Signatures

If a foreign investor suspects that their signature has been forged, original documents should be preserved wherever possible.

The investor should identify every corporate transaction completed using the disputed signature.

Forensic examination may become necessary.

Unauthorized Share Transfers

A foreign investor may discover an unexpected change in corporate ownership.

Company registry information, share-transfer documentation and relevant corporate resolutions should be examined immediately.

Where falsified documents or unauthorized representation are suspected, both corporate and criminal remedies may need to be considered.

What If the Fraudulent Company Becomes Insolvent?

Recovery becomes more difficult but not necessarily impossible.

The investor should determine where company assets went before insolvency.

Suspicious transfers to shareholders, directors, relatives or related companies may require separate investigation.

Timing can be particularly important.

What If the Company Enters Restructuring or Bankruptcy Proceedings?

The investor should not assume that a criminal complaint alone protects its financial claim.

Claims may need to be asserted through the appropriate insolvency or restructuring procedures.

At the same time, suspicious pre-insolvency asset transfers may require separate examination.

What If the Directors Leave Turkey?

The investigation can become more complicated, particularly if suspects and assets move abroad.

Foreign investors should identify all jurisdictions involved.

Cross-border evidence, company records and asset recovery may require international legal cooperation.

Can Foreign Investors Pursue the Case From Abroad?

Potentially.

Foreign investors do not necessarily need to remain physically in Turkey throughout every stage of the proceedings.

Appropriate legal representation can allow many procedural steps to be handled while the investor remains abroad, although personal participation may sometimes be necessary.

Should the Investor Confront the Directors?

Not before considering evidence preservation and asset risk.

Immediate confrontation may cause records to disappear or assets to be moved.

Before announcing legal action, the investor should understand what evidence is available and whether urgent protective measures should be considered.

Should the Investor Accept a Repayment Offer?

A genuine repayment proposal may be commercially sensible.

However, investors should be cautious about withdrawing proceedings based solely on another unsecured promise.

Any settlement should address the amount, payment dates, security, default consequences and treatment of existing claims.

Recovery Fraud: A Second Scam After the First Fraud

Foreign investors who have already lost money can become targets again.

A person may claim to have located the stolen funds and demand an advance “release fee,” “tax,” “court fee” or “recovery commission.”

This can be another fraud.

Anyone claiming to have recovered assets should be independently verified before additional money is transferred.

What Should Foreign Investors Do in the First 24 Hours?

Preserve evidence.

Download bank records.

Save accounting information that is lawfully accessible.

Preserve emails, messages and investment documents.

Identify suspicious transactions.

Check the company’s current ownership and management.

Do not delete digital evidence.

Do not transfer additional money simply because the company promises that another payment will save the investment.

What Should Be Done During the First Week?

Prepare a complete investment chronology.

Identify every payment.

Compare representations made before investment with actual company information.

Investigate related companies and recipients of suspicious transfers.

Calculate the preliminary loss.

Determine which assets may still exist.

Then evaluate criminal, corporate and financial recovery remedies together.

2026 Warning for Foreign Investors

Financial and corporate fraud investigations continue to involve sophisticated structures and extensive financial tracing.

In April 2026, prosecutors reported a fake-investment investigation involving sponsored online advertisements, multiple bank and digital-asset accounts and 27 suspects. Nineteen suspects were ordered detained and eight were released under judicial control.

In June 2026, another major financial investigation involved allegations concerning corporate structures, false invoicing and fictitious exports; the Ministry of Justice reported seizure measures affecting six companies and appointment of trustees to ten companies.

These examples do not determine the outcome of an individual private-company dispute, but they illustrate the increasingly important role of financial analysis, corporate records and asset-related measures in complex fraud investigations.

How Foreign Investors Can Prevent Company Fraud

Pre-investment due diligence remains one of the strongest protections.

Foreign investors should independently verify financial statements, debts, litigation, company ownership, management authority, assets, important contracts and related-party transactions.

They should not rely exclusively on documents prepared by the seller.

Post-investment governance is equally important.

Foreign shareholders should maintain independent visibility over banking, accounting and major corporate decisions.

Frequently Asked Questions

1. Can a foreign investor file a criminal complaint against a company in Turkey?

A foreign investor can report suspected criminal conduct. The complaint should identify the individuals involved and the specific allegedly fraudulent transactions rather than simply stating that an investment failed.

2. Can I recover money lost through company fraud?

Potentially. Recovery may require a combination of criminal, commercial, contractual and enforcement remedies.

3. Does a criminal complaint automatically return my investment?

No. Criminal responsibility and financial recovery are related but distinct issues.

4. Can suspicious company bank transfers be investigated?

Potentially. Bank records can become central evidence in financial fraud investigations.

5. Can company assets be frozen?

Potentially, where the statutory requirements for the relevant protective measure are satisfied. Filing a complaint does not automatically freeze assets.

6. Can directors be personally liable?

Potentially, depending on their individual conduct and the legal basis of the claim. Being a director alone does not automatically create personal liability for every company obligation.

7. Can minority foreign shareholders investigate suspicious transactions?

Potentially. Turkey’s 2026 company guide confirms mechanisms including special-audit rights subject to statutory requirements.

8. Can a special auditor investigate company fraud?

A special audit can help clarify specific corporate events and transactions. It is a corporate mechanism rather than a substitute for a criminal investigation.

9. Can I pursue recovery while living outside Turkey?

Potentially. Legal representation can allow many steps to be pursued while the foreign investor remains abroad, although personal participation may occasionally be necessary.

10. Should I wait for the criminal investigation before filing a commercial claim?

Not automatically. Commercial and corporate remedies may have their own procedural requirements and deadlines. The strategies should be evaluated together.

Legal Assistance for Foreign Investors Facing Company Fraud in Turkey

Company fraud in Turkey can leave a foreign investor facing two urgent problems simultaneously: proving what happened and preventing the remaining assets from disappearing before financial recovery becomes possible.

An effective strategy should establish what representations induced the investment, where the investor’s money went, which directors or shareholders controlled the transactions, whether company records were manipulated, whether funds reached related companies and what assets remain available for recovery.

Foreign investors should also consider corporate investigative mechanisms. The Ministry of Trade’s current 2026 guidance confirms the availability of shareholder special-audit procedures subject to the statutory conditions.

Fırat Fesih Kaya Law Office provides legal assistance to foreign investors, international companies and foreign shareholders concerning company fraud, investment fraud, shareholder fraud, fraudulent company acquisitions, misuse of investment funds, fake invoices, unauthorized transfers, corporate asset diversion, criminal complaints, asset tracing and recovery of investment losses in Turkey.

Legal assistance may include reviewing the investment transaction, investigating company and financial records, preserving evidence, preparing criminal complaints, tracing suspicious payments, exercising shareholder rights, coordinating special-audit procedures, challenging fraudulent corporate actions and pursuing appropriate commercial, compensation and financial recovery remedies.

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 who suspect that their money is actively being diverted, waiting can materially reduce the possibility of recovery. Early preservation of corporate records, reconstruction of the payment trail and coordinated criminal and commercial action can be decisive.