

Has a Turkish prosecutor frozen your bank account? Learn how foreigners can challenge a seizure order, request judicial review, prove the lawful source of funds, seek partial release and recover frozen money during a criminal investigation in Turkey.
A foreign national whose Turkish bank account has been frozen by a public prosecutor during a criminal investigation should act quickly. A prosecutor’s seizure order is not necessarily final, and Turkish criminal procedure provides mechanisms for judicial review, objection and requests for release of seized assets.
The first priority is to identify the precise legal basis of the restriction.
Not every account described by a bank employee as “frozen by the prosecutor” is governed by exactly the same procedure. Depending on the investigation, the restriction may arise under the general seizure provisions of the Turkish Criminal Procedure Code No. 5271 (CMK), special rules concerning proceeds of crime, fraud-related account measures, anti-money-laundering legislation or another statutory mechanism.
This distinction determines which authority reviews the decision, what deadline applies, what evidence should be submitted and whether the prosecutor’s measure requires judicial approval.
Foreign account holders should therefore avoid relying solely on information provided verbally by a bank branch.
The investigation file and actual seizure decision should be identified and examined.
Potentially, yes.
Foreign nationality does not prevent Turkish criminal authorities from taking protective measures against assets held in Turkey.
Turkish prosecutors are responsible during the investigation stage for investigating suspected offences and collecting evidence both for and against the suspect. The Ministry of Justice reiterated this prosecutorial obligation in its March 2026 explanation of the investigation framework. (BASIN VE HALKLA İLİŞKİLER MÜŞAVİRLİĞİ)
Depending on the statutory basis and urgency of the case, a prosecutor may have authority to order or initiate certain seizure measures, although some measures require a judge’s decision or subsequent judicial approval.
Accordingly, the critical question is not whether the account holder is foreign.
It is whether the statutory requirements for the particular seizure have been satisfied.
No.
A seizure is a protective criminal-procedure measure.
It is not a conviction and does not establish that the account holder committed fraud, money laundering, tax crime or another offence.
The purpose of a seizure may be to preserve assets believed to represent criminal proceeds, prevent disappearance of relevant property or maintain the effectiveness of an ongoing investigation.
The foreign account holder still benefits from the procedural protections applicable under Turkish criminal law.
The first step should be to determine exactly what happened.
The foreign account holder should establish whether the restriction covers the entire account or only a specified amount, whether incoming transactions remain possible, whether only outgoing transactions are prohibited, and whether the restriction originates from a prosecutor, judge, criminal court, MASAK-related procedure or the bank’s own compliance department.
Where possible, the account holder should identify the Public Prosecutor’s Office, investigation number, date of the decision and legal provision relied upon.
Without this information, it is difficult to prepare an effective challenge.
Because the bank generally does not decide whether a prosecutorial seizure should continue.
Once an external criminal authority has imposed the restriction, repeatedly asking the branch manager to release the money will usually accomplish little.
The legal challenge must normally be made within the criminal proceedings.
The investigation number allows counsel to identify the relevant prosecutor’s file and determine the nature of the allegations, subject to any applicable confidentiality or restriction decision.
Yes, where the applicable criminal-procedure rules provide an objection against the decision.
The Turkish Criminal Procedure Code contains a general objection mechanism known as “itiraz” for qualifying judicial decisions. The procedure is principally regulated under Articles 267 and following of the CMK.
The exact route must be determined from the particular seizure decision because different statutory mechanisms can have different requirements.
The objection should not merely say:
“I am a foreigner and I need access to my money.”
A stronger objection addresses why the legal requirements for the seizure were absent or why continuation of the measure is unnecessary or disproportionate.
Yes, criminal-procedure remedies are subject to statutory deadlines.
This is why the date on which the relevant decision was learned or notified must be recorded immediately.
Foreigners should not assume that they can wait several months and challenge the seizure whenever convenient.
The applicable deadline must be checked against the exact type and date of the decision.
Procedural deadlines are particularly important because a potentially strong substantive challenge can fail if the available remedy is not exercised in time.
The appropriate authority depends on the type of decision and procedural stage.
Under the general CMK objection framework, the application is submitted through the authority whose decision is challenged, and the matter may then be reviewed by the legally competent judicial authority.
The precise competent authority should be identified from the decision rather than guessed.
This is particularly important after amendments affecting the structure and operation of Turkish criminal procedure.
In some circumstances, yes.
Turkish criminal procedure distinguishes between measures directly ordered by judicial authorities and urgent measures that may initially be taken by a prosecutor subject to judicial control.
Where the applicable statutory provision requires subsequent approval, compliance with that approval procedure should be examined carefully.
A failure to obtain required judicial approval within the statutory framework can become highly significant when challenging continued seizure.
Therefore, counsel should review not merely the first prosecutorial instruction but the entire sequence of decisions following it.
There is no universal template.
The strongest grounds depend on the investigation.
Common arguments can concern absence of a sufficient connection between the money and alleged criminal activity, inadequate evidence, legitimate ownership of the funds, lawful source of money, excessive scope of the restriction, procedural defects or lack of continuing necessity.
A well-prepared application should combine legal arguments with financial evidence.
This is often the most important practical issue.
The account holder should reconstruct the complete source-of-funds chain.
For example:
Employment → salary payments → foreign savings account → SWIFT transfer → Turkish bank account.
Or:
Ownership of foreign property → property sale → sale proceeds deposited abroad → international transfer → Turkish bank account.
Or:
Company ownership → lawful dividend resolution → dividend payment → transfer into Turkey.
The objective is to show that the disputed money has a legitimate and independently verifiable economic origin.
The appropriate evidence depends on the source of funds.
A foreign investor may need bank statements, SWIFT records, contracts, invoices, tax records, company resolutions, share purchase agreements or investment documents.
A person relying on property-sale proceeds may need the sale agreement, title documents and evidence showing receipt of the purchase price.
An employee may rely on an employment contract, payroll records and bank statements.
A business owner may require invoices, commercial agreements, accounting documents and corporate records.
The documents should establish a coherent financial chronology rather than simply overwhelm the prosecutor or court with hundreds of unrelated pages.
Foreign documentation can still be extremely important.
Depending on the document and proceeding, Turkish translation and potentially other formalities may be necessary.
A foreign account holder should preserve the original records as well as electronic copies.
Bank documents containing transaction dates, account numbers, sender identities and amounts can be especially useful because they allow the money trail to be reconstructed objectively.
Yes.
This distinction can be strategically important.
The foreigner does not necessarily need to prove immediately that the entire criminal investigation is unfounded.
Instead, the application can focus on the narrower issue:
Why should this particular money remain frozen?
For example, even if an investigation legitimately continues into one suspicious transfer, it does not automatically follow that every independently documented asset belonging to the account holder must remain restricted.
Potentially.
Consider a foreign investor with EUR 800,000 in a Turkish account.
The investigation concerns a EUR 75,000 incoming payment.
The remaining EUR 725,000 can be traced to documented proceeds from the sale of a foreign company.
Rather than requesting only an all-or-nothing decision, the account holder may seek narrowing of the measure so that demonstrably unrelated legitimate funds can be released.
Whether this is possible depends on the statutory basis and wording of the seizure decision.
A bank-account seizure interferes significantly with property rights.
Therefore, the scope and duration of the measure should remain connected to the legitimate objectives of the criminal investigation.
If the investigation concerns a relatively limited transaction but millions in unrelated funds remain inaccessible, the account holder may argue that continuation of the restriction in its existing scope is unnecessary or disproportionate.
The argument becomes considerably stronger when the lawful origin of the unrelated funds can be documented.
Potentially.
Salary funds are not automatically immune from every criminal-procedure measure merely because they are salary.
However, the foreign account holder can document the source through an employment agreement, payroll documentation and corresponding bank transfers.
If the frozen account is also used for ordinary living expenses, the application can explain the consequences of the restriction.
Potentially, depending on the circumstances.
A foreigner may have no alternative Turkish account and may be unable to pay rent, utilities, school fees, medical expenses or ordinary living costs.
These circumstances can support a request for modification of the measure.
However, hardship alone may not be enough.
The stronger argument is generally:
The funds are legitimate, unrelated to the alleged offence, and continuing to restrict them causes unnecessary and disproportionate hardship.
Potentially.
A frozen corporate account can prevent payment of salaries, suppliers, taxes and operating expenses.
If the investigation concerns only particular transactions, the company may seek to demonstrate that ordinary operating funds have independent legitimate origins.
Corporate accounting records become especially important in these cases.
The applicant should distinguish ordinary business revenue from transactions allegedly connected with the criminal investigation.
Third-party ownership should be raised immediately.
Suppose a Turkish company account is seized during an investigation into one shareholder, but some funds demonstrably belong to an unrelated third party.
Or suppose a foreigner’s account contains money held temporarily for a documented commercial purpose.
The legal ownership of the funds can materially affect the analysis.
However, merely claiming that money “belongs to someone else” will usually be insufficient. Documentary evidence should establish the ownership relationship.
This does not automatically prevent an account from becoming involved in a criminal investigation.
Money allegedly connected with criminal activity can move through third-party accounts.
However, a genuine third party who can demonstrate lawful ownership, lack of involvement and an independent legitimate source of funds may have strong grounds for seeking release.
The application should distinguish clearly between the alleged offender, the investigated transaction and the innocent owner of the money.
Potentially, yes.
Turkish criminal procedure provides mechanisms for the return of seized property when continued retention is no longer necessary or the property will not be subject to confiscation.
This means that an account holder should not focus exclusively on the initial objection.
Even where an earlier challenge was unsuccessful, subsequent developments in the investigation may support a renewed request for release.
For example, expert analysis or bank records obtained later may establish that the money has no connection with the alleged offence.
Rejection does not necessarily mean the account must remain frozen until the criminal case ends.
The investigation can change.
New evidence may become available.
A different suspect may be identified.
Financial tracing may establish that the questioned proceeds never entered the foreigner’s account.
The legal necessity for continuing the measure should therefore be reassessed as the investigation develops.
A new release request based on materially new evidence can be much stronger than repeatedly filing the same objection.
The answer depends on procedural status and whether a restriction on access exists.
A lawyer can generally seek information concerning the investigation subject to the rules governing defence access and any confidentiality or restriction decision.
The prosecutor has an obligation to investigate the truth and collect both incriminating and exculpatory evidence, not merely evidence supporting an accusation. The Ministry of Justice expressly restated this duty in 2026. (BASIN VE HALKLA İLİŞKİLER MÜŞAVİRLİĞİ)
This can be important where banking records actually support the foreigner’s explanation.
Access to parts of an investigation file can sometimes be restricted under Turkish criminal procedure.
This can make challenging an asset seizure more difficult because the foreigner may not initially know the full allegations.
Even in such cases, the available seizure decision, banking history and source-of-funds evidence should be analyzed.
The defence can challenge the measure using the information legally available while continuing to seek appropriate access to the file.
Usually not on its own.
Once a valid criminal authority has ordered the bank to restrict the account, the bank generally implements that instruction.
A branch manager cannot simply override it because the customer provides a contract or explains the transaction.
The documents may instead need to be submitted to the competent prosecutor or judicial authority.
The bank becomes important again once it receives an official decision modifying or lifting the restriction.
Usually this is not the most productive strategy once a prosecutorial order has been confirmed.
The essential problem is no longer the bank’s customer-service decision.
It is the criminal-procedure measure.
The focus should therefore shift toward identifying and challenging the underlying order.
The precise legal basis should still be identified.
“MASAK freeze” is often used loosely to describe several different situations.
A bank compliance restriction, MASAK-related financial investigation, temporary statutory account restriction and prosecutor’s seizure order can require different legal responses.
Foreigners should therefore request whatever information the bank can legally provide and determine whether a criminal investigation number exists.
Fraud investigations frequently involve bank-account tracing.
The authorities may examine whether the account received money from victims, whether the money was transferred onward and whether the account holder received any commission.
A foreigner whose account was used as an intermediary should preserve communications showing why they received the money.
The investigation may focus heavily on whether the foreigner knew the source of the funds.
Evidence of deception can be extremely important.
Suppose a business acquaintance tells a foreign national that a payment represents legitimate customer revenue.
The foreigner receives the money and forwards it as instructed.
Later, the payment is identified as alleged fraud proceeds.
WhatsApp messages, invoices and prior business dealings may help demonstrate why the foreigner believed the transaction was legitimate.
The account holder should preserve those records rather than delete them.
This can increase scrutiny.
Investigators may ask why the account holder received compensation merely for allowing money to pass through their account.
A commission does not automatically establish criminal intent, but it may require a credible explanation.
Repeated transactions involving unrelated senders and immediate onward transfers can create greater risk than an isolated legitimate commercial payment.
The financial trail should be reconstructed from beginning to end.
Relevant evidence may include exchange account statements, transaction histories, wallet records where necessary, proof of acquisition and sale, and bank records showing conversion into fiat currency.
If money moved from a Turkish account into crypto shortly after an alleged fraud, investigators may examine whether the conversion was intended to conceal or move criminal proceeds.
The account holder’s explanation should therefore be supported by objective transaction data.
This can provide a strong source-of-funds explanation where properly documented.
For example, a British citizen sells a property for GBP 500,000.
The sale proceeds enter the person’s UK bank account and GBP 350,000 is subsequently transferred to Turkey.
The relevant documentation can establish:
ownership → sale → payment → foreign bank deposit → SWIFT transfer → Turkish account.
That chain can be presented to demonstrate that the money is unrelated to the alleged Turkish criminal activity.
The precise legal reason for the payment should be documented.
It might represent salary, dividends, consultancy fees, repayment of a shareholder loan, sale proceeds or return of investment capital.
Corporate resolutions, invoices, contracts and accounting records can help establish the transaction.
A large transfer from a foreign company to an individual’s Turkish personal account without documentation can be considerably harder to explain.
Yes, depending on the procedure.
A foreign account holder does not necessarily have to relocate to Turkey simply to pursue an objection or release application.
A Turkish lawyer can often undertake significant procedural steps under an appropriately prepared power of attorney.
However, the prosecutor may separately require the account holder to provide a statement during the criminal investigation.
The two issues should not be confused.
The account holder should review the financial transactions before giving a detailed statement.
Banking investigations can involve many transactions over long periods.
Guessing dates or amounts from memory can create unnecessary inconsistencies.
The account holder should reconstruct the relevant transaction chronology using bank records, contracts and communications before explaining the disputed payments.
Yes, Turkish criminal procedure contains rules governing interpretation for persons who cannot adequately understand or communicate in Turkish.
The Ministry of Justice continues to administer the interpreter framework under Article 202 of the Criminal Procedure Code. (İSTANBUL ADLİYESİ)
A foreigner should not sign a statement they do not understand merely to complete the procedure quickly.
Depending on the scope and legal basis of the investigation, restrictions can potentially affect multiple accounts.
However, each continuing restriction must still have a lawful basis.
Where one bank account contains questioned funds while another contains clearly documented unrelated income, the foreigner should consider whether the scope of the measure can be challenged.
The legal analysis should focus on actual ownership and connection with the alleged offence.
Potentially.
Criminal asset-seizure measures are not necessarily limited to bank accounts.
Where the statutory requirements are satisfied, other assets can also become subject to protective measures.
This makes early analysis particularly important where the investigation concerns a foreign investor with substantial Turkish assets.
The defence should identify the full scope of the asset restrictions rather than focusing only on the first frozen bank account.
No attempt should be made to circumvent a lawful seizure.
Trying to move assets through other accounts, relatives, companies or cryptocurrency after learning of an investigation can create substantially greater legal risk.
The appropriate route is to challenge the measure and demonstrate lawful ownership through the criminal-procedure mechanisms available.
There is no single duration applicable to every bank-account seizure.
The answer depends on the statutory basis, nature of the investigation and whether the reasons justifying the measure continue to exist.
This is why the account holder should not simply wait indefinitely.
If the investigation develops and the connection between the money and alleged offence disappears, a renewed application for release should be considered.
Potentially.
The longer a measure continues, the more important it becomes to assess whether the original reasons still justify the interference.
This is especially significant where the account holder has supplied strong evidence of legitimate ownership but the funds remain inaccessible without meaningful development in the investigation.
A proportionality challenge should address the specific circumstances rather than rely only on the passage of time.
Potentially, where the requirements of the Turkish Criminal Procedure Code concerning compensation for unlawful protective measures are satisfied.
This is a separate question from obtaining immediate release.
A person may first seek lifting of the seizure and later examine whether the circumstances support a compensation claim for losses caused by an unlawful measure.
Documentation of financial losses should therefore be preserved.
Potentially, depending on the legal basis of a later compensation claim and proof of causation.
For example, a company may claim that an improperly frozen operating account prevented it from completing contracts or paying suppliers.
However, proving lost profits is substantially more difficult than simply demonstrating that money was temporarily inaccessible.
Accounting records and evidence of specific lost transactions would be important.
No.
Using a statutory legal remedy is not an admission of guilt.
A person whose assets have been restricted has the right to challenge the measure and submit exculpatory evidence.
Indeed, quickly documenting the legitimate source of the money may assist the investigation by distinguishing lawful assets from genuinely suspicious transactions.
Not necessarily.
The immediate issue in a seizure challenge can be narrower than ultimate criminal liability.
The applicant may demonstrate that a particular asset has no sufficient connection with the alleged offence or that continued seizure is unnecessary.
The criminal investigation itself may continue independently.
The strongest applications usually combine procedural arguments and financial evidence.
A useful structure is to explain the investigation, identify the seizure decision, identify exactly which money is restricted, reconstruct the lawful source of those funds, address the alleged connection with the offence and explain why continued restriction is unnecessary or disproportionate.
Evidence should be organized chronologically.
The court should be able to follow the money without having to reconstruct the entire financial history itself.
Assume a French investor holds EUR 1 million in a Turkish bank account.
The account is frozen during an investigation into a Turkish company from which the investor previously received EUR 100,000.
The remaining EUR 900,000 came from the documented sale of the investor’s business in France.
A weak application simply states:
“The EUR 1 million belongs to me. Please release it.”
A substantially stronger application separates the transactions.
It provides the foreign business sale agreement, bank records showing receipt of EUR 900,000, SWIFT documentation showing the transfer into Turkey and evidence demonstrating that these funds existed independently of the Turkish company under investigation.
The request can then challenge whether freezing the unrelated EUR 900,000 remains necessary.
Suppose a foreign national allows a Turkish acquaintance to receive payments through their account.
Ten unrelated people send money.
The foreigner transfers the funds onward and receives 3% of each transaction.
The account is then frozen by a prosecutor investigating online fraud.
Here, requesting release of the account is only one part of the problem.
The foreigner may also face questions concerning knowledge and participation in the alleged fraud.
The defence must therefore examine messages, previous transactions, relationship with the acquaintance and reason for the commission before deciding how to approach the prosecutor.
In 2026, the most effective approach for a foreign account holder is usually not to file a generic one-page request saying that the money is legitimate.
The response should proceed in stages:
Identify the authority and investigation. Establish the precise legal basis of the seizure. Check whether judicial approval was required and properly obtained. Determine the applicable objection procedure and deadline. Separate questioned transactions from unrelated funds. Prepare complete source-of-funds evidence. Challenge procedural defects where they exist. Request full or partial release based on necessity and proportionality.
The Turkish criminal investigation framework continues to place prosecutors under a duty to investigate the material truth and collect both incriminating and exculpatory evidence. (BASIN VE HALKLA İLİŞKİLER MÜŞAVİRLİĞİ)
Accordingly, documentary evidence demonstrating the lawful origin of the foreigner’s money should form a central part of the response.
Yes, where the applicable criminal-procedure provisions permit objection or judicial review. The exact remedy should be determined from the seizure decision and its statutory basis.
Immediately. Criminal-procedure remedies can have strict deadlines, so the date of notification or learning of the decision should be established without delay.
Potentially. If part of the balance can be independently documented as unrelated legitimate funds, a request to narrow the seizure may be considered.
Bank statements, SWIFT records, contracts, property-sale documents, employment records, invoices, corporate documents and other evidence establishing a complete lawful source-of-funds chain.
Generally, the bank cannot simply disregard a valid criminal authority’s order. The underlying judicial or prosecutorial measure normally needs to be modified or lifted through the appropriate procedure.
Potentially, yes. Third parties whose property has been affected can have rights concerning the seizure, particularly where they can establish independent ownership and legitimate origin.
A rejected initial objection does not necessarily prevent later applications where circumstances change or new evidence demonstrates that continued seizure is unnecessary.
In many cases, legal applications can be handled through Turkish counsel under an appropriate power of attorney, although the prosecutor may separately require a personal statement.
Potentially, where the statutory requirements for compensation arising from unlawful protective measures are satisfied.
Not necessarily. Bank compliance restrictions, MASAK-related measures and criminal-procedure seizure orders can have different legal bases and remedies.
When a foreigner’s Turkish bank account is frozen by a prosecutor, the case should be approached through the criminal investigation file, not merely through correspondence with the bank.
The key questions are who ordered the seizure, whether the necessary statutory conditions existed, whether judicial approval was required, which transactions are actually under investigation and whether legitimate funds can be separated from the disputed money.
Fırat Fesih Kaya Law Office provides legal assistance to foreign individuals, investors and company directors concerning prosecutor-ordered bank account seizures, fraud and financial-crime investigations, MASAK-related proceedings, source-of-funds evidence, objections against protective measures and applications seeking full or partial release of frozen funds.
Where substantial foreign-currency balances are affected, Fırat Fesih Kaya can assess the investigation and prepare a transaction-based strategy distinguishing legitimate assets from the payments under investigation.
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