Turkish Manager Creates Fake Employees and Takes Company Money: Criminal Complaint by a Foreign Employer (2026 Updated Guide)

A Turkish manager creates fictitious employees and diverts company funds. Learn how a foreign employer can preserve payroll and bank evidence, file a criminal complaint, recover losses and protect the company in Turkey.

A foreign-owned company operating in Turkey may discover that a local manager has allegedly created fake employees, fictitious payroll records or sham personnel payments and diverted company money for personal benefit. The scheme may continue for months or years if the manager controls payroll, banking instructions, accounting records or personnel files. When the misconduct is discovered, the foreign employer should treat the situation as more than an internal employment dispute. Depending on how the money was obtained and the documents or systems used, the conduct may raise issues involving fraud, breach of trust, document-related offences, unauthorized transactions and other criminal allegations under Turkish law. The company should move quickly to preserve evidence, prevent further transfers, identify the total loss and prepare a properly documented criminal complaint.

How Can a Fake Employee Scheme Work?

The exact method differs from company to company. A manager may create fictitious employee profiles, keep former employees active in payroll systems, manipulate salary information, use bank accounts controlled by associates, prepare false expense records or cause the company to make payments for employees who never performed any work.

The legal analysis should therefore begin with the actual movement of money rather than simply the label “fake employee.”

First Secure the Company’s Systems

Before confronting the suspected manager, the foreign employer should consider protecting company systems and records.

Access to payroll software, accounting platforms, corporate email, banking systems, personnel databases and document repositories may need to be reviewed immediately.

Evidence should be preserved before accounts are deleted or records are altered.

Do Not Destroy or Alter Digital Evidence

Preserving evidence does not mean editing the suspect’s computer or manually reorganizing files.

Where digital evidence may become important in criminal proceedings, the company should preserve the original material and maintain a reliable record of how it was obtained.

Identify Every Allegedly Fake Employee

Prepare a separate file for each suspicious employee record.

Determine the person’s name, identification information, alleged employment dates, salary, bank account, job title, personnel documents and total amount paid.

This makes it easier to distinguish genuine employees from fictitious records.

Check Whether the Person Actually Exists

Some schemes involve completely invented identities. Others use real individuals who never worked for the company.

A third possibility is that the individual worked briefly but continued appearing on payroll after leaving.

These scenarios should not be treated as factually identical.

Review Employment Contracts

Locate the employment agreement for every suspicious employee.

If no contract exists, determine who authorized the person’s addition to payroll and what documentation was supposedly used.

If a contract exists, examine signatures and whether the document may have been fabricated.

Review Personnel Files

Personnel records may contain identification documents, employment forms, leave records, salary information and other materials.

A fictitious personnel file assembled by the suspected manager can become significant evidence.

Examine Payroll Records

Create a month-by-month analysis showing gross salary, net salary, additional payments, bonuses and other amounts attributed to each suspicious employee.

The objective is to calculate precisely how much company money was transferred.

Trace the Bank Accounts

Bank records can be among the most important evidence in these cases.

Determine which accounts received the allegedly fictitious salary payments and whether several fake employees were paid into the same or connected accounts.

Follow the Money After Payment

Where legally obtainable, subsequent transfers may help identify the ultimate beneficiary.

For example, money transferred as a salary may later move to the manager, a relative, an associate or another connected account.

This can materially strengthen the evidentiary picture.

Compare Payroll With Actual Workplace Records

Access-card data, shift records, workplace attendance systems, internal directories, email accounts and other legitimate corporate records may help determine whether the alleged employee ever actually worked.

The company should collect this information lawfully and preserve it systematically.

Check Corporate Email Accounts

Was an email address created for the alleged employee? Was it ever used? Did the person participate in ordinary company communications?

The absence of all operational traces may support the company’s allegations when considered together with other evidence.

Review Managerial Authorization

Determine how the suspected manager was able to create or approve employees.

Was the manager authorized to recruit personnel? Could the manager approve salaries alone? Was a second signature required?

The answers can help reconstruct the method of the alleged offence.

Examine Internal Approval Chains

The company should identify every person who approved payroll, bank transfers and accounting entries.

This does not mean that everyone in the approval chain committed an offence. Some employees may have relied on false information supplied by the manager.

Determine Whether the Manager Acted Alone

A fake payroll scheme may involve accounting personnel, human-resources employees, external accountants or other participants.

The company should avoid accusing individuals merely because they processed transactions. Evidence should distinguish intentional participation from ordinary administrative involvement.

Preserve Accounting Records

General ledger entries, payroll journals, payment records and account reconciliations should be secured.

The criminal complaint should be capable of showing how the suspicious transactions entered the company’s books.

Compare Payroll With Social Security Records

Where relevant, examine whether the alleged employees were reported through the applicable social-security system and whether contribution payments were made.

Fictitious registrations can increase the financial and regulatory complexity of the matter.

Tax Records May Also Require Review

False payroll expenses may have affected corporate accounting or tax declarations.

The company should determine whether corrective accounting or tax measures are necessary without destroying evidence relevant to the criminal investigation.

Could the Conduct Constitute Fraud?

Potentially, depending on the method used.

If deceptive acts caused the company to make payments that it otherwise would not have made, fraud-related criminal allegations may need to be examined.

The exact offence cannot be determined merely from the existence of an unauthorized payment.

Could Breach of Trust Be Relevant?

Potentially. Where a manager was entrusted with company assets, authority or financial responsibilities and allegedly misused that position, breach-of-trust issues may arise depending on the factual structure.

The prosecutor will evaluate the legal characterization based on the evidence.

What If False Documents Were Created?

If employment contracts, payroll documents, expense records or other documents were fabricated or altered, document-related criminal offences may also become relevant.

The original documents should be preserved for examination.

What If Electronic Records Were Manipulated?

Changes to payroll, accounting or other computer systems may create an additional digital-evidence dimension.

System logs, user accounts, timestamps and access histories should be preserved before ordinary IT processes overwrite them.

Should the Manager Be Confronted Immediately?

Not necessarily.

An uncontrolled confrontation can alert the suspect, create an opportunity to delete records or cause further movement of funds.

The company should first secure critical evidence and protect its financial systems.

Suspend Banking Authority Where Necessary

If the suspected manager still has access to company bank accounts, payment systems or corporate cards, the company should evaluate immediate lawful measures to prevent further unauthorized transactions.

Internal corporate authorization procedures should be followed carefully.

Review Powers of Attorney

A Turkish manager may hold powers of attorney permitting banking, contracting or other transactions on behalf of the foreign-owned company.

Determine whether those powers should be revoked or restricted.

Review Corporate Signature Authority

Check trade registry and internal corporate records to determine the manager’s formal authority.

Terminating employment alone may not necessarily address every external corporate authority held by the individual.

Can the Foreign Employer File a Criminal Complaint?

Yes. A foreign-owned company that believes it has suffered criminal conduct in Turkey can pursue the available criminal complaint mechanisms through its authorized representatives.

The complaint should explain the alleged scheme clearly and attach organized evidence.

What Should the Criminal Complaint Contain?

The complaint should identify the company, suspected persons where known, relevant period, method of the alleged misconduct, suspicious employee records, money transfers and available evidence.

A chronological presentation is generally more useful than an unstructured collection of documents.

Prepare a Transaction Table

A useful evidence schedule can identify the date, fake employee, payroll amount, receiving bank account, approving manager and supporting document for each transaction.

This allows investigators to understand the alleged loss much more quickly.

Calculate the Total Company Loss

The company should distinguish direct unauthorized payments from related losses.

Direct losses may include salary payments and other amounts transferred because of fictitious employment records. Additional losses should be documented separately rather than estimated without evidence.

Can Bank Records Be Obtained During the Investigation?

Relevant banking records may be obtained through the legally authorized criminal procedure where the statutory conditions are satisfied.

The company should identify the accounts and transactions it believes are relevant so that the prosecutor can evaluate appropriate investigative requests.

Can the Manager’s Assets Be Secured?

Depending on the alleged offences, evidence and applicable procedural requirements, protective measures concerning assets may potentially become relevant.

Such measures are not automatic merely because a criminal complaint has been filed.

Can the Company Recover the Stolen Money?

Potentially. Recovery strategy should be considered separately from criminal punishment.

Depending on the circumstances, the company may need to evaluate civil, commercial, employment or enforcement remedies in addition to participating in the criminal proceedings.

A Criminal Complaint Does Not Automatically Return the Money

Even if an investigation begins, the company should not assume that all losses will automatically be reimbursed through the criminal file.

Asset identification and parallel recovery planning may be necessary.

Employment Termination Must Be Handled Separately

If the manager remains employed, the company should evaluate the employment-law consequences of the suspected conduct.

Criminal proceedings and employment termination involve different legal questions and procedures.

Preserve the Manager’s Defense Rights

The company should present evidence rather than treating allegations as established facts.

The prosecutor and ultimately the competent court determine criminal responsibility.

This is particularly important where several employees had access to the relevant systems.

Witness Statements Can Be Important

Employees who handled payroll, recruitment, accounting or bank payments may provide relevant information.

Identify who personally observed suspicious instructions or transactions and distinguish firsthand knowledge from workplace rumors.

Former Employees May Also Hold Evidence

Employees who previously worked in human resources or accounting may know when suspicious personnel records were created.

Their contact information should be preserved where lawfully available.

External Accountants Should Be Contacted Carefully

If an external accounting firm processed payroll based on information supplied by the manager, its records may help establish what instructions it received.

Preserve correspondence and source documents.

Conduct a Wider Internal Review

Once one fictitious employee is discovered, examine whether the same method was used elsewhere.

Review other payroll accounts, expense reimbursements, suppliers, bonuses and payments approved by the same manager.

Do Not Limit the Investigation to Payroll

A manager willing to create fictitious employees may potentially have used similar controls for fake suppliers, inflated expenses or unauthorized payments.

Any broader review should remain evidence-based.

Check Payments to Relatives and Connected Persons

Where suspicious recipients appear connected to the manager, preserve evidence establishing the relationship where lawfully obtainable.

Do not assume that a family relationship alone proves criminal participation.

Foreign Headquarters Should Preserve Its Own Records

The parent company may possess emails, audit reports, approval requests and financial reports that are not stored in Turkey.

These documents should also be preserved.

Translation of Foreign Corporate Documents

Foreign-language documents used in Turkish proceedings may require appropriate translation depending on their procedural use.

Translations should accurately preserve financial and technical terminology.

Internal Investigation Reports Should Be Carefully Prepared

The company may prepare an internal chronology and findings report, but factual findings should be distinguished from legal conclusions.

Avoid overstating uncertain allegations.

Data Protection Must Be Considered

An internal fraud investigation does not create unlimited authority to examine every employee’s personal data.

Corporate evidence collection should remain connected with legitimate investigative purposes and applicable legal requirements.

What If the Manager Deletes Evidence?

If evidence has already been deleted, backups, server records, audit logs, email archives and other sources may still contain relevant information.

Digital evidence should be handled carefully to preserve reliability.

What If the Manager Leaves Turkey?

Departure from Turkey does not automatically terminate a criminal investigation.

The consequences depend on the alleged offence, procedural status and decisions of the competent judicial authorities.

What If the Manager Claims the Payments Were Authorized?

The company should preserve board resolutions, internal policies, approval limits and correspondence showing who had authority to create employees and approve payments.

Corporate governance evidence can become decisive.

What If the Foreign Employer Previously Approved Payroll?

Approval of a payroll summary does not necessarily resolve whether management was deceived about the existence of employees.

The factual question becomes what information was presented to the approving person.

Insurance Coverage Should Be Checked

Where the company maintains crime, fidelity, employee dishonesty or another potentially relevant policy, notification requirements should be reviewed promptly.

Coverage depends on the wording and circumstances of the particular policy.

Parallel Civil Recovery May Be Necessary

A foreign employer should consider whether waiting for the criminal case alone is commercially sensible.

Depending on available evidence and assets, separate recovery proceedings may need to be evaluated.

Immediate Action Plan for the Foreign Employer

When a Turkish manager is suspected of creating fake employees and taking company money, the foreign employer should immediately secure banking and system access, preserve payroll and accounting records, identify every suspicious employee, trace payments, secure digital logs, review corporate authorities and powers of attorney, calculate the loss, identify witnesses, notify relevant insurers where appropriate, prepare a chronological criminal complaint and evaluate parallel asset-recovery measures.

Frequently Asked Questions

Can a foreign-owned company file a criminal complaint against its Turkish manager?

Yes. A company that believes it has been harmed by criminal conduct in Turkey may pursue the available complaint procedures through its authorized representatives.

Is creating fake employees automatically fraud?

The exact criminal characterization depends on how the scheme operated, what deception occurred, what authority the manager possessed and how the money was obtained.

Are payroll records sufficient evidence?

They can be important, but stronger cases usually connect payroll records with bank transfers, personnel files, accounting entries, digital records and other evidence.

Can company bank records be used?

Yes, relevant company banking records can be important evidence concerning the movement of funds.

Can the manager’s personal bank transactions be investigated?

Where legally justified, competent criminal authorities may obtain relevant financial evidence through the procedures permitted by law.

Should the manager be dismissed immediately?

Employment measures require a separate labor-law assessment. The company should also consider evidence preservation, corporate authority and ongoing financial access before taking action.

Can the company recover money through the criminal investigation?

Recovery may be possible in appropriate circumstances, but the company should not assume that filing a complaint automatically returns its losses. Parallel recovery options may need to be evaluated.

What if fake employment contracts contain forged signatures?

The authenticity of the documents should be investigated and the originals preserved. Document-related criminal allegations may become relevant depending on the evidence.

What if several employees participated?

Each person’s conduct should be examined individually. Processing a transaction does not by itself establish intentional participation in the alleged scheme.

What should the foreign employer do first?

Secure the evidence and stop further financial exposure before confronting the suspected manager. Payroll data, bank transfers, accounting records, system logs and corporate authorization documents should then be combined into a transaction-by-transaction chronology capable of showing investigators exactly how the alleged scheme operated.

Client-Focused Legal Support for Foreign Employers Facing Internal Fraud in Turkey

Internal fraud by a local manager can expose a foreign-owned company to direct financial loss, falsified payroll records, unauthorized banking transactions, employment disputes, accounting problems and complex criminal proceedings. Fırat Fesih Kaya Law Office assists foreign companies and international investors in Turkey with internal fraud investigations, criminal complaints, evidence preservation and asset-recovery strategies. Lawyer Fırat Fesih Kaya provides legal assistance in coordinating payroll, banking and digital evidence, preparing criminal complaints against company managers, protecting corporate assets and evaluating parallel civil, commercial and employment-law remedies.

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