Sent money to a fraudulent Turkish company? Learn how foreign victims can trace bank transfers, file criminal complaints, freeze accounts, seek interim attachment, recover assets and pursue company directors in Turkey in 2026.

A foreign individual or foreign company that transfers money to a fraudulent business in Turkey may have several legal routes to recover the funds. The available remedies can include immediate bank intervention, a criminal complaint for fraud, seizure or suspension of accounts during the criminal investigation, civil or commercial litigation, interim attachment, enforcement proceedings and claims against individuals behind the company.

The most important factor is often speed.

Fraudulent companies rarely leave money untouched in the first receiving bank account. Funds may quickly be transferred to another company, withdrawn in cash, sent to third-party accounts, converted into cryptocurrency or moved abroad.

For this reason, a foreign victim should not treat the dispute merely as an ordinary unpaid debt.

The first objective should be to determine where the money went and whether it can still be preserved.

This has become particularly important following significant changes to Turkish criminal procedure entering into force in late 2025 and further fraud-related amendments in 2026.

When Is a Turkish Company Considered Fraudulent?

Not every company that fails to perform a contract has committed fraud.

This distinction is critical.

Suppose a foreign investor pays USD 200,000 to a Turkish manufacturer for machinery. The manufacturer genuinely intends to manufacture the machinery but later experiences financial difficulties and cannot deliver.

That may primarily constitute a contractual or commercial dispute.

Now consider a different scenario.

The supposed manufacturer sends fabricated factory photographs, false certificates and fictitious references. It receives USD 200,000, immediately transfers the money to the director’s relatives and never possessed any manufacturing facilities.

That may provide substantially stronger grounds for a fraud allegation.

Under Article 157 of the Turkish Criminal Code, fraud fundamentally involves deceptive conduct causing another person to act to their detriment while producing an unlawful benefit for the perpetrator or another person. Certain circumstances can elevate the conduct to aggravated fraud under Article 158. (Türkiye Büyük Millet Meclisi)

Can Fraud Through a Turkish Company Constitute Aggravated Fraud?

Potentially, yes.

Article 158 of the Turkish Criminal Code identifies several aggravated forms of fraud.

Of particular importance in international commercial cases, aggravated fraud provisions can become relevant where fraud is committed through information systems or banks, or where a merchant, company manager or person acting on behalf of a company commits fraud during commercial activities. (Türkiye Büyük Millet Meclisi)

This means that using a registered Turkish company does not protect the individuals behind the operation from criminal investigation.

The actual conduct must be examined.

What Should the Foreign Victim Do Immediately After Discovering the Fraud?

The first hours and days can be decisive.

The victim should immediately preserve all evidence relating to the transaction, including the bank transfer receipt, SWIFT documentation, invoice, contract, pro forma invoice, correspondence, WhatsApp messages, emails, website screenshots, company documents, payment instructions and details of every bank account involved.

The victim should also contact the sending bank immediately and report the suspected fraudulent transaction.

Where the transfer is sufficiently recent, banks may be able to communicate with the receiving institution and attempt a recall or fraud-related intervention.

A bank recall is not guaranteed to recover the money, particularly if the funds have already left the recipient account.

But waiting weeks before reporting the transaction can dramatically reduce practical recovery opportunities.

Can the Foreign Victim Contact the Turkish Bank?

Yes, although the Turkish bank may not provide confidential customer information directly to the victim.

The victim should nevertheless ensure that the transaction is formally reported through the appropriate banking channels.

The sending bank can also initiate relevant interbank procedures.

Where a criminal investigation begins, prosecutors can obtain banking information that the foreign victim cannot obtain privately.

This distinction is important.

The foreign victim may know only the first Turkish IBAN. Prosecutorial investigation can potentially reveal where the money moved after reaching that account.

Can a Turkish Bank Account Be Suspended Quickly in a Fraud Case?

This is particularly important under the 2026 procedural framework.

Article 128/A of the Turkish Criminal Procedure Code, introduced in late December 2025, created a specific mechanism concerning accounts used in certain information-system-related offences.

Where there is reasonable suspicion concerning specified offences, including certain aggravated fraud offences, banks, payment service providers and crypto-asset service providers can suspend relevant accounts for up to 48 hours under the statutory framework and must report the measure and account activity to the public prosecutor.

The provision also allows seizure procedures to follow. (Türkoğlu Avukatlık Ofisi)

For foreign victims of recent online-transfer fraud, this makes immediate reporting substantially more important than simply sending a demand letter to the company.

Can Frozen Fraud Money Be Returned to the Foreign Victim?

Potentially, yes.

An especially important feature of Article 128/A is that where seized criminal proceeds are established to belong to the victim, they may be returned to the owner during the investigation or prosecution. (Türkoğlu Avukatlık Ofisi)

This can create a much more direct recovery opportunity than waiting years for a final civil judgment.

However, the victim must still demonstrate that the seized money is connected with the fraudulent transaction and belongs to them.

Tracing therefore remains critical.

What If the Money Has Already Left the First Bank Account?

The investigation should follow the money.

Foreign victims sometimes focus entirely on the name printed beside the first Turkish IBAN.

That can be a mistake.

Fraud operations frequently use intermediary accounts.

For example:

Foreign Company A transfers EUR 300,000 to Turkish Company B.

Within two hours, Company B sends EUR 100,000 to Company C, converts part into cryptocurrency and sends the remaining amount to an individual’s account.

The recovery investigation should not stop with Company B.

The subsequent transactions can be crucial for identifying the individuals who ultimately benefited.

What Changed in Turkish Fraud Law in 2026?

Turkey introduced another significant amendment in July 2026.

A new paragraph was added to Article 158 of the Turkish Criminal Code concerning participation in fraud through providing payment instruments or access information relating to bank, brokerage, payment-service or crypto-asset accounts for the purpose of obtaining unlawful benefit.

The amendment reflects the increasing role of third-party accounts in modern fraud structures. (Türkoğlu Avukatlık Ofisi)

For foreign victims, the practical lesson is straightforward:

The person or company owning the first receiving account may not be the final beneficiary.

The entire financial chain should be investigated.

Should the Foreign Victim File a Criminal Complaint?

Where the evidence indicates deliberate deception rather than a simple contractual default, a criminal complaint may be an important part of the recovery strategy.

The complaint should explain exactly what the deception was.

Merely stating:

“We paid and they did not deliver”

may not adequately demonstrate fraud.

A stronger fraud complaint might explain that the company fabricated documents, falsely represented ownership of assets, provided fictitious references, concealed insolvency, impersonated another business, issued fraudulent certificates or diverted the payment immediately after receiving it.

The chronology should show that the deception induced the victim to transfer the money.

Where Can the Criminal Complaint Be Filed?

A criminal complaint concerning conduct connected with Turkey can generally be submitted to the competent Turkish prosecutorial authorities.

A foreign victim does not necessarily need to be permanently resident in Turkey merely to pursue criminal remedies.

Representation through a Turkish lawyer can often allow substantial parts of the process to be handled without repeated travel to Turkey, subject to the procedural requirements of the particular case.

An appropriately prepared power of attorney may therefore be important for an overseas victim.

Can a Foreign Company Be the Victim?

Yes.

The victim does not have to be an individual.

Foreign companies frequently become victims of Turkish commercial fraud involving advance payments, machinery purchases, commodity trades, distributorship agreements, construction projects, investment transactions and international supply agreements.

The foreign company’s corporate documents and authorization of its representative should be prepared properly for use in Turkish proceedings.

Can the Turkish Company Itself Be Prosecuted?

Turkish criminal responsibility principally attaches to natural persons.

Therefore, investigation usually focuses on the directors, managers, shareholders, employees or other individuals who allegedly participated in the fraudulent conduct.

The fact that payment was made to a corporate bank account does not mean the investigation ends with the legal entity.

Authorities can investigate who controlled the company, who communicated with the victim, who authorized the payment instructions and where the funds ultimately went.

Can Company Directors Be Personally Responsible?

Potentially.

Limited liability should not be confused with immunity for personal wrongdoing.

A company director is not ordinarily personally liable for every commercial debt merely because the company cannot pay.

However, where an individual personally participates in fraud, makes fraudulent representations or commits another wrongful act, the corporate structure does not necessarily shield that individual from personal civil or criminal consequences.

This distinction can dramatically expand the assets potentially relevant to recovery.

Can the Foreign Victim Sue the Company for Repayment?

Yes, depending on the underlying transaction.

Civil or commercial proceedings may seek repayment based on contractual breach, invalidity, unjust enrichment, tortious conduct or other applicable grounds.

The correct cause of action depends on what actually happened.

For example, where an advance payment was made under a genuine contract but the Turkish company failed to deliver, contractual remedies may be central.

Where the entire transaction was fabricated from the beginning, fraud-related civil and criminal remedies may operate together.

Should the Victim Choose Between Criminal and Civil Proceedings?

Not necessarily.

In substantial fraud cases, treating the issue as either “criminal” or “civil” can be a strategic mistake.

The criminal proceedings investigate and punish the alleged offence.

Civil or commercial proceedings can establish repayment and compensation obligations.

Enforcement proceedings pursue assets.

Interim measures can attempt to preserve those assets before the main case concludes.

A serious asset-recovery strategy may therefore use several procedures simultaneously.

Can the Foreign Victim Obtain Interim Attachment?

Potentially.

Interim attachment (ihtiyati haciz) is one of the most important tools for securing qualifying monetary claims in Turkey.

If the statutory requirements are satisfied, the creditor can seek provisional attachment of assets before completing the underlying debt litigation.

This may include assets such as bank funds, vehicles, real estate or receivables belonging to the relevant debtor.

The objective is simple:

Prevent a future judgment from becoming worthless because the debtor disposed of all recoverable assets while the case was pending.

Is Interim Attachment Automatically Granted Because Fraud Is Alleged?

No.

The applicant must establish the statutory conditions and provide sufficient evidence supporting the monetary claim and grounds for provisional protection.

Security may also be required.

The application should therefore be supported with strong documentary evidence, including payment records, contracts, correspondence, admissions and evidence concerning the circumstances of the fraud.

A vague allegation that the company “looks suspicious” will generally be much weaker.

Can an Interim Injunction Also Be Used?

Potentially, but an interim injunction and interim attachment perform different functions.

An interim injunction (ihtiyati tedbir) generally protects a disputed right or asset.

An interim attachment (ihtiyati haciz) principally secures a monetary receivable.

For a foreign victim seeking repayment of EUR 500,000 transferred to a fraudulent company, interim attachment may often be particularly relevant.

Where ownership of a specific property or another non-monetary right is disputed, an injunction may become more appropriate.

Selecting the correct measure is important.

Can Turkish Real Estate Owned by the Fraudsters Be Attached?

Potentially.

If the person or company legally responsible for the debt owns real estate in Turkey, that property may become an important recovery target.

Land Registry information and enforcement mechanisms can therefore play a central role in asset recovery.

Where urgent provisional protection is legally available, action before the property is sold can be significantly more effective than trying to recover it after several transfers.

Can Vehicles Be Attached?

Potentially, yes.

Vehicles registered to the debtor can be relevant enforcement assets.

The same applies to other attachable assets depending on the circumstances.

A recovery investigation should therefore look beyond bank accounts.

Fraudsters may deliberately keep relatively little money in bank accounts while holding value through real estate, vehicles, corporate shares or receivables.

Can the Fraudulent Company’s Receivables Be Attached?

Potentially.

Suppose the fraudulent company has almost no cash but is owed substantial amounts by customers.

Those third-party receivables may become relevant during enforcement proceedings.

This can sometimes provide a recovery route even where the company’s bank accounts appear empty.

The company’s customers, contractual receivables and other payment rights should therefore be considered when mapping assets.

What If the Fraudulent Company Transfers Its Assets to Another Company?

This should be investigated immediately.

Fraudulent businesses sometimes transfer assets to a newly established related company once claims begin.

For example, Company A receives the foreign investor’s money.

After receiving a legal demand, its machinery, vehicles and customers are transferred to Company B controlled by the same individuals.

Such transfers should not simply be accepted as making recovery impossible.

Depending on the facts, Turkish enforcement and substantive law may provide mechanisms for challenging transactions designed to prejudice creditors.

What If Assets Are Transferred to the Director’s Family?

Again, the transaction should be investigated rather than automatically treated as effective against the creditor.

Timing, consideration paid, relationship between the parties and purpose of the transfer can all become relevant.

A transfer of valuable property to a spouse or relative immediately after a fraud complaint can present a very different situation from an ordinary arm’s-length transaction made years earlier.

Can Fraudulent Asset Transfers Be Challenged?

Potentially, yes.

Turkish enforcement law contains mechanisms for challenging certain transactions prejudicing creditors.

The exact requirements depend on the transaction, parties, timing and enforcement position.

These proceedings can become particularly important where a debtor technically appears to own nothing because valuable assets were moved to related persons.

Asset tracing should therefore include historical transfers, not merely current ownership.

What If the Company Has Become Insolvent?

Recovery becomes more complicated but is not automatically impossible.

The creditor should determine whether the company is subject to bankruptcy, concordat proceedings or ordinary enforcement.

If bankruptcy proceedings exist, claims may need to be registered within the bankruptcy framework.

The victim should also investigate whether the individuals behind the company have separate liability.

A fraudulent operator should not automatically escape personal exposure merely by allowing the corporate vehicle to become insolvent.

Can the Victim Start Turkish Enforcement Proceedings?

Depending on the nature and documentation of the debt, enforcement proceedings may be available.

If the debtor objects, further proceedings may be necessary to establish or enforce the claim.

For substantial international commercial claims, the strategy should be selected after reviewing jurisdiction clauses, arbitration clauses, governing-law provisions and the available evidence.

Starting the wrong proceeding can waste valuable time while assets disappear.

What If the Contract Contains an Arbitration Clause?

Then the dispute-resolution clause must be examined carefully.

The underlying repayment or damages claim may belong before arbitration rather than an ordinary Turkish court.

However, arbitration does not necessarily mean that assets in Turkey must remain unprotected until the tribunal issues a final award.

Depending on the circumstances, Turkish courts may still have a role concerning provisional protection and subsequent enforcement.

Foreign victims should therefore examine the arbitration clause immediately rather than discovering it after filing the wrong lawsuit.

What If There Is a Foreign Court Judgment Against the Turkish Company?

A foreign judgment generally requires recognition or enforcement in Turkey before compulsory execution can proceed against Turkish assets.

However, the possibility of seeking interim protection while enforcement proceedings are being pursued can require separate consideration. Recent Turkish legal analysis continues to recognize interim attachment as potentially relevant before a foreign judgment becomes executable, subject to the applicable requirements concerning the claim, evidence, security and procedural continuation. (Mondaq)

This can be crucial where the Turkish debtor is disposing of assets during the recognition or enforcement process.

What If There Is a Foreign Arbitration Award?

A similar distinction arises with arbitral awards.

The award may require enforcement procedures before compulsory execution against assets in Turkey.

The applicable international convention, seat of arbitration and Turkish private international law framework must be examined.

Where substantial Turkish assets exist, asset-preservation strategy should be considered before completing a potentially lengthy enforcement process.

Can Money Sent Through Cryptocurrency Be Recovered?

Potentially, although tracing can become more technically complex.

Turkey’s updated procedural framework expressly addresses accounts held with crypto-asset service providers in certain fraud investigations.

Article 128/A refers not only to banks and payment service providers but also to crypto-asset service providers when regulating account suspension, information and seizure mechanisms for specified offences. (Türkoğlu Avukatlık Ofisi)

Therefore, a conversion from Turkish bank funds into cryptocurrency does not necessarily mean that investigation must stop.

What Evidence Should Foreign Victims Preserve?

The victim should preserve the complete transaction history rather than only the final payment receipt.

Important material commonly includes the signed contract, invoices, SWIFT records, IBAN details, beneficiary name, bank correspondence, emails, WhatsApp messages, website screenshots, advertisements, company presentations, Trade Registry information, identification details of representatives and documents used to persuade the victim to make payment.

Voice messages and legally obtained digital communications may also become relevant.

Original files should be preserved where possible.

Should the Company’s Turkish Trade Registry Records Be Investigated?

Yes.

Corporate records can reveal important information about the company.

They can help identify shareholders, managers, representation authority, capital changes, registered address and historical corporate changes.

This information can then be compared against what the company told the foreign victim.

For example, if the alleged “CEO and owner” who negotiated a EUR 1 million transaction had no corporate authority whatsoever, that discrepancy may become important evidence.

What If the Company Was Created Shortly Before Receiving the Money?

That fact alone does not prove fraud.

Many legitimate businesses are newly incorporated.

However, when combined with other circumstances—false addresses, nominal shareholders, fabricated documents, immediate transfers, no employees and disappearance after payment—the timing can become important.

Fraud cases are generally built from the overall pattern rather than one isolated fact.

What If Several Foreign Victims Paid the Same Company?

This can significantly change the investigation.

Multiple victims describing the same representations and payment structure may indicate a systematic fraudulent operation rather than an isolated contractual failure.

The authorities should be informed of known related victims and transactions.

Connections between recipient accounts, directors, websites, telephone numbers and related companies can reveal the broader structure.

Can a Foreign Victim Recover Legal Costs and Interest?

Potentially, depending on the proceedings and outcome.

Claims may include the principal amount, applicable interest and recoverable litigation or enforcement expenses.

Additional damages may also become relevant where the statutory requirements are satisfied.

The calculation should be made carefully where the original payment was made in foreign currency.

Can the Claim Be Made in Foreign Currency?

This depends on the underlying obligation and applicable law.

Where the original transaction was denominated in USD, EUR, GBP or another currency, the contractual terms and Turkish rules concerning foreign-currency obligations must be examined.

Exchange-rate fluctuations can become extremely significant in long-running disputes.

The requested relief should therefore be formulated carefully from the beginning.

Do Foreign Victims Have to Travel to Turkey?

Not necessarily for every stage.

Many legal procedures can be handled through a Turkish lawyer acting under an appropriately prepared power of attorney.

Depending on where the power of attorney is executed, apostille or Turkish consular formalities may be required.

However, specific proceedings may require the victim or company representative to provide statements or participate personally at certain stages.

The need for travel should therefore be evaluated case by case.

Should the Victim Send a Warning Letter First?

Sometimes, but not automatically.

In an ordinary commercial dispute, a formal demand may be useful.

In a suspected fraud case where money is actively being moved, giving the fraudsters advance warning can potentially provide time to dispose of assets.

The sequence of actions therefore matters.

Where urgent asset preservation is possible, the foreign victim should assess whether protective steps should precede an ordinary demand for payment.

Should the Victim Negotiate With the Fraudulent Company?

Settlement may sometimes recover money faster than litigation.

But promises such as “we will pay next week” should be treated cautiously where fraud indicators already exist.

A fraudulent operator may use settlement discussions merely to gain enough time to transfer remaining assets.

Where instalment repayment is genuinely being considered, appropriate security should be sought.

The victim should not surrender important claims merely in exchange for another unsecured promise.

Practical Example: Foreign Investor Sends USD 500,000 to a Turkish Company

Assume a foreign company is offered an investment opportunity in Turkey.

The Turkish company provides financial statements, property documents and contracts allegedly proving that it owns a profitable project.

The foreign investor transfers USD 500,000.

Within 24 hours, USD 300,000 is transferred to accounts connected with the company’s manager. Another USD 100,000 is moved to a related company, and part of the remaining funds is converted into cryptocurrency.

The property documents later appear to be false.

This should not be approached merely as:

“The Turkish company owes USD 500,000.”

The case may require immediate bank reporting, a criminal complaint explaining the original deception, requests for tracing and preservation of the financial proceeds, investigation of the directors and recipient accounts, civil or commercial recovery proceedings and provisional protection over identifiable assets.

The sooner this process begins, the greater the possibility that recoverable assets can still be located.

Criminal Complaint vs Asset Recovery

Foreign victims should understand an important practical distinction.

Winning the criminal case does not automatically mean the money will still exist.

Likewise, obtaining a civil judgment does not guarantee recovery if the debtor owns nothing when enforcement begins.

The strongest strategy therefore asks two questions simultaneously:

Can we prove the fraud?

and

Where are the recoverable assets right now?

This is why tracing and provisional protection should begin as early as possible.

2026 Legal Position for Foreign Fraud Victims in Turkey

The Turkish legal framework in 2026 provides several potentially important recovery mechanisms.

Fraud and aggravated fraud remain regulated principally by Articles 157 and 158 of the Turkish Criminal Code. Fraud involving company managers during commercial activities, banking or information systems may fall within aggravated circumstances depending on the facts. (Türkiye Büyük Millet Meclisi)

The newer Article 128/A of the Criminal Procedure Code has added an especially significant mechanism for certain technology-related aggravated fraud cases. Relevant bank, payment and crypto accounts may be temporarily suspended, and criminal proceeds established to belong to the victim can potentially be returned during the investigation or prosecution. (Türkoğlu Avukatlık Ofisi)

The July 2026 amendment to Article 158 also specifically addresses participation through providing payment instruments or account-access information, reflecting the importance of intermediary accounts in contemporary fraud schemes. (Türkoğlu Avukatlık Ofisi)

For foreign victims, therefore, the best approach is usually criminal investigation plus financial tracing plus civil/enforcement recovery, rather than relying on only one proceeding.

Frequently Asked Questions

1. Can a foreigner recover money transferred to a fraudulent Turkish company?

Potentially, yes. Recovery may involve bank intervention, criminal proceedings, civil or commercial claims, interim attachment and enforcement against identifiable assets.

2. What should I do immediately after discovering the fraud?

Contact the sending bank, preserve all transaction evidence and obtain urgent legal assessment concerning criminal reporting and asset preservation. Delay can allow funds to move through additional accounts.

3. Can a Turkish bank freeze the recipient’s account?

In qualifying fraud cases, Turkish criminal procedure now contains mechanisms allowing temporary suspension of relevant accounts and subsequent seizure procedures. The precise mechanism depends on the suspected offence and circumstances. (Türkoğlu Avukatlık Ofisi)

4. Can seized money be returned before the criminal trial ends?

Potentially. Under Article 128/A, where seized criminal proceeds are established as belonging to the victim, the legislation permits return during the investigation or prosecution. (Türkoğlu Avukatlık Ofisi)

5. What if the money was immediately transferred to another account?

The financial investigation should follow subsequent transfers. The first receiving IBAN may only be an intermediary account.

6. Can company directors be pursued personally?

Potentially, particularly where directors personally participated in fraudulent representations or other wrongful conduct. Ordinary corporate limited liability does not provide blanket immunity for personal wrongdoing.

7. Can assets be frozen before the civil lawsuit finishes?

Potentially. Interim attachment or other provisional measures may be available where the applicable statutory requirements are satisfied.

8. What if the Turkish company has no money left?

Other assets should be investigated, including real estate, vehicles, receivables, corporate interests and potentially assets connected with personally liable individuals. Historical transfers to related parties may also require investigation.

9. Can I pursue the case without living in Turkey?

Generally, substantial parts of the proceedings can be handled through properly authorized Turkish counsel. The procedural requirements depend on the particular case.

10. Is a criminal complaint enough to recover my money?

Not always. Criminal prosecution and financial recovery are related but distinct objectives. Civil, commercial, enforcement and provisional-measure proceedings may also be necessary.

Legal Support for Foreign Victims of Company Fraud in Turkey

When a foreign individual or international company has transferred substantial funds to a suspected fraudulent company in Turkey, the case should be approached as an asset-recovery matter from the first day, not merely as a future criminal prosecution.

Fırat Fesih Kaya Law Office provides legal assistance to foreign individuals, investors and companies concerning fraudulent bank transfers, Turkish company fraud, international commercial fraud, criminal complaints, account tracing, interim attachment, civil and commercial litigation and enforcement against assets in Turkey.

Where funds have recently been transferred, Fırat Fesih Kaya can assess the transaction chronology, recipient company, Turkish bank accounts, corporate records, individuals involved and identifiable assets to determine which criminal and civil measures should be pursued.

Cases involving large transfers, multiple recipient accounts, related companies, cryptocurrency or suspected transfers abroad require particularly rapid assessment because each additional transaction can make recovery more difficult.

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